(a) Discovery requests and materials and deposition notices and requests served
pursuant to Federal Rules of Civil Procedure 30, 31, 33, 34, and 36 shall not be
filed with the court. The party serving the discovery material or taking the
deposition shall retain the original and be the custodian of it.
(b) Every motion pursuant to the Federal Rules of Civil Procedure governing
discovery shall identify and provide, verbatim, the relevant parts of the
interrogatory, request, answer, response, objection, notice, subpoena, or
depositions in the party’s memorandum. Counsel may also identify the
disputed discovery in an attached exhibit, provided that the exhibit clearly
identifies the relevant portions. Any party responding to the motion shall
provide, verbatim, any other part that the party believes necessary to the
court's consideration of the motion.
(c) If material in interrogatories, requests, answers, responses, or depositions is
used as evidence in connection with any motion, the relevant parts shall be
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UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF PA
set forth, verbatim, in the moving papers or in responding memoranda, or as
an exhibit attached thereto. If it is used as evidence at trial, the party offering
it shall read it into the record or, if directed to do so by the court, offer it as an
exhibit.
(d) The court shall resolve any dispute that may arise about the accuracy of any
quotation or discovery material used as provided in (b) and (c) and may
require production of the original paper or transcript.
(e) The court, on its own motion, on motion by any party, or on application by a
non-party, may require the filing of the original of any discovery paper or
deposition transcript. The parties may provide for such filing by stipulation.
(f) No motion or other application pursuant to the Federal Rules of Civil
Procedure governing discovery or pursuant to this rule shall be made unless
it contains a certification of counsel that the parties, after reasonable effort,
are unable to resolve the dispute.
(g) A routine motion to compel answers to interrogatories or to compel
compliance with a request for production under Federal Rule of Civil
Procedure 34, wherein it is averred that no response or objection has been
timely served, need have no accompanying brief, and need have no copy of
the interrogatories or Federal Rule of Civil Procedure 34 request attached. The
court may summarily grant or deny such motion without waiting for a
response.
