a. Declaration Required. No motion relating to discovery may be filed unless counsel for the
moving party electronically attaches to the motion a declaration attesting to the following:
1. Counsel, in good faith, has conferred personally with counsel for the opposing party in an
attempt to resolve or narrow by agreement the issues raised by the motion;
2. The lawyers have been unable to reach an agreement; and
3. The nature of the disagreement.
An exchange of written communications or a single telephone message will not, by itself,
satisfy the requirements of this section.
In the alternative, counsel for the moving party may certify in a written declaration, subscribed
under penalty of perjury pursuant to 28 U.S.C. § 1746, that a personal conference with
opposing counsel was impossible, and describe the efforts undertaken to schedule the
conference.
No declaration is required under this rule where one party to the discovery dispute is
proceeding pro se.
b. Attachments to Motions. A party filing a motion objecting to a discovery request or to the
sufficiency of a response to a discovery request must attach to the motion a copy of the disputed
request and any response.
c. Deadline for Motions to Compel. Motions to compel must be filed as soon as practicable. In
any event, except for good cause shown, motions to compel must be filed within 14 days after
the discovery deadline.
