and 37 of the Federal Rules of Civil Procedure and objections relating to discovery shall:
(a) quote verbatim each interrogatory, request for admission, or request for production to which a
motion or objection is taken;
(b) include the specific ground for the motion or objection; and
(c) include the reasons assigned as supporting the motion, which shall be written in immediate
succession to one another. Such objections and grounds shall be addressed to the specific
interrogatory, request for admission, or request for production and may not be made generally.
Counsel are reminded that Fed. R. Civ. P. 26(c) and 37(a)(1) require a party seeking a protective order or
moving to compel discovery to certify that a good faith effort has been made to resolve the dispute before
coming to court.
