Updated: 7/24/2022
GUIDELINES FOR DISCOVERY MATTERS
Should counsel find they are unable to resolve a discovery matter or a matter regarding a
protective order, 1 the parties shall file a “[Joint] Motion for Conference To Resolve [Protective
Order or Discovery] Dispute.” The suggested text for this motion can be found on the court’s
website in the “Forms” tab, under the heading “Discovery Matters–Motion to Resolve Discovery
Dispute.”
The following procedures shall apply:
1. Discovery dispute letter submissions shall not exceed four (4) pages, and all printed
matter, including footnotes, must appear in at least 12-point font.
2. The moving party should attach a proposed order to its letter brief as an exhibit. In
the proposed order, the moving party should clearly set out the nature of the requested
relief as to each dispute, including the date by which the requested relief is to be
completed.
3. Exhibits to discovery dispute letter submissions are limited to a total of no more than
200 pages, absent leave of court. The parties shall make reasonable efforts to attach
only those pages relevant to the discovery dispute as exhibits. Each exhibit shall be
filed as a separate, individual attachment within the docket entry for the associated
letter submission. The court may strike submissions which exceed the limitation on
exhibits, and the hearing may be canceled in that event.
1
Counsel are expected to first verbally discuss the issues/concerns before seeking the court’s
intervention.
4. If the discovery dispute relates to certain discovery requests (e.g., interrogatories or
requests for production of documents), then the moving party should attach those
discovery requests and any relevant responses as exhibits to its letter brief. The
responding party should include as exhibits to its letter brief any discovery requests
and/or responses that it believes are relevant and that the moving party did not already
submit.
5. Motions for sanctions under Fed. R. Civ. P. 37 pertaining to discovery shall be
brought in accordance with the Court’s discovery dispute procedures.
6. Courtesy copies of discovery dispute letter submissions are to be hand delivered to
the Clerk’s Office within one hour of e-filing. Should the court find further briefing
necessary upon conclusion of the conference, the court will order it.
