IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE
[PLAINTIFF], )
)
Plaintiff, )
)
v. ) C.A. No. 00-0000-JLH
)
[DEFENDANT], )
)
Defendant. )
MOTION FOR TELECONFERENCE TO RESOLVE
[DISCOVERY/PROTECTIVE ORDER] DISPUTES
[PARTY] respectfully moves 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].
