If any attorney anticipates that he or she or a member of the attorney’s firm may be required
to testify as a witness under circumstances that would not require disqualification as
counsel under the applicable Rule of Professional Conduct, the attorney shall immediately
notify the Court and opposing counsel in writing and set forth: (1) the issues on which the
attorney or a member of the attorney’s firm may be required to testify, and (2) a general
plan for handling the testimony.