(A) Form. A motion to compel a disclosure under LR 26.1 or to compel a response
to discovery conducted pursuant to the Federal Rules of Civil Procedure shall:
(1) Include the certification of counsel with regard to the duty to confer
required by Fed. R. Civ. P. 37(a)(2)(A)(B);
(2) Quote verbatim each disclosure, interrogatory, deposition question,
request for designation of deponent, or request for inspection to which objection is
taken;
(3) State the specific objection;
(4) State the grounds assigned for the objection (if not apparent from the
objection); and
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(5) Cite authority and include a discussion of the reasons assigned as
supporting the motion.
The motion shall be arranged so that the objection, grounds, authority, and
supporting reasons follow the verbatim statement of each specific disclosure,
interrogatory, deposition question, request for designation of deponent, or request for
inspection to which an objection is raised.
(B) Time for Filing. Unless otherwise ordered by the Court, a motion to compel a
disclosure or discovery must be filed within the time remaining prior to the close of
discovery or, if longer, within fourteen (14) days after service of the disclosure or
discovery response upon which the objection is based. The close of discovery is
established by the expiration of the original or extended discovery period or by written
notice of all counsel, filed with the Court, indicating that discovery was completed
earlier.
(C) Procedures. Motions to compel are subject to the general motion requirements
set forth in LR 7.1.
VI. TRIALS
Editor’s Note: See also LR 83.1, Attorneys: Admission to Practice before the
Court.
