A motion relative to discovery will not be accepted for filing unless accompanied by a certificate of
counsel for the moving party stating that counsel have conferred in person or by telephone for
purposes of amicably resolving the issues and stating why they are unable to agree or stating that
opposing counsel has refused to so confer after reasonable notice. Counsel for the moving party must
arrange the conference. A proposed order must accompany each motion filed under this paragraph.
If the court finds that opposing counsel has willfully refused to meet and confer, or, having met,
willfully refused or failed to confer in good faith, the court may impose such sanctions as it deems
proper.
LOCAL CIVIL RULE 38 - JURY TRIAL OF RIGHT
