To curtail undue delay and expense in the administration of justice, this court shall hereafter refuse
to hear any and all motions for discovery and production of documents under Rules 26 through 37
of the Federal Rules of Civil Procedure, unless the motion includes a statement (1) that after
consultation in person or by telephone and good faith attempts to resolve differences they are
unable to reach an accord, or (2) counsel's attempts to engage in such consultation were
unsuccessful due to no fault of counsel's. Where the consultation occurred, this statement shall
recite, in addition, the date, time and place of such conference, and the names of all parties
participating therein. Where counsel was unsuccessful in engaging in such consultation, the
statement shall recite the efforts made by counsel to engage in consultation.
