(A) The Court will not consider any motion relating to discovery and disclosure
unless it contains a statement that movant’s counsel has conferred in person or by telephone
with the opposing counsel in good faith or has made reasonable efforts to do so, but that after
sincere efforts to resolve their dispute, counsel are unable to reach an accord. This statement
also shall recite the date, time and manner of such conference, and the names of the individuals
participating therein, or shall state with specificity the efforts made to confer with opposing
counsel.
(B) Any motion relating to a deposition, including but not limited to a motion to
quash or modify a deposition subpoena or for a protective order, shall be filed before the
deposition date unless a belated notice of deposition renders this deadline impracticable.
(C) Upon the filing of a motion to compel, the Court may summarily overrule an
objection to any discovery request if the objection is not stated in detail.
(Amended July 10, 2006, effective August 28, 2006)
