(a) Filing of Discovery.
Unless otherwise ordered by the court, depositions upon oral examination and
interrogatories, requests for documents, requests for admissions, answers and responses and
disclosures made under Fed. R. Civ. P. 26(a) (1)-(3) or pursuant to scheduling orders, shall be
served upon other parties but shall not be filed with the court. The party that has served notices of
depositions or has served discovery papers shall be responsible for preserving and for insuring the
integrity of original transcripts and discovery papers for use by the court.
(b) Discovery Disputes.
A judicial officer shall not consider any discovery motion that is not accompanied by a
certification that the moving party has made a reasonable and good-faith effort to reach an
agreement with opposing counsel on the matters set forth in the motion. An attempt to confer
will not suffice.
After efforts to resolve the dispute have been exhausted, any dispute not resolved shall be
presented to the judicial officer by motion. If the parties are unable to resolve the dispute and
the discovery deadline is about to expire, or if the dispute arises during the taking of a deposition,
the dispute may be promptly presented to a judicial officer by telephone. In those cases, the judicial
officer shall resolve the dispute by telephone or order the parties to submit the matter by motion.
Unless otherwise ordered by the court, the complete discovery materials shall not be filed
with the court unless the discovery dispute cannot be decided without reference to the complete
discovery materials.
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