IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE
[PLAINTIFF], )
)
Plaintiff, )
)
v. ) C.A. No. ____________
)
[DEFENDANT], )
)
Defendant. )
MOTION FOR TELECONFERENCE TO RESOLVE
[DISCOVERY/PROTECTIVE ORDER] DISPUTE
[PARTY] respectfully moves this Court to schedule a teleconference to address
outstanding disputes regarding the following [discovery/protective order] matters:
• [list of 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 dates: [list date(s) and amount of time spent on each date].
Plaintiff’s Counsel:
Delaware Counsel: [list counsel]
Lead Counsel: [list counsel]
Defendant’s Counsel:
Delaware Counsel: [list counsel]
Lead Counsel: [list counsel]
The parties are available for a teleconference on the following dates: [list three proposed
dates].
This dispute is the [indicate whether first, second, etc.] time that a discovery or protective
order dispute has been brought before the Court.
