Updated 10/10/2019
[JOINT] MOTION FOR TELECONFERENCE
TO RESOLVE [PROTECTIVE ORDER or DISCOVERY] DISPUTE
[Name or Names of parties] respectfully move this Court to schedule a teleconference
to address outstanding disputes regarding the following [discovery / protective order] matters:
• [LIST ISSUES TO BE RESOLVED]
The following attorneys, including at least one Delaware Counsel and at least one Lead
Counsel per party, participated in a verbal meet-and-confer (in person and/or by telephone) on
the following date(s): [LIST DATE(S)].
Delaware Counsel:
[LIST COUNSEL]
Lead Counsel:
[LIST COUNSEL]
The parties are available for a teleconference on the following dates: [LIST THREE
DATES].
