(a) All non-substantive motions, including discovery motions, shall include a
certificate of counsel affirming that, after consultation between the parties to the
controversy, they are unable to reach an accord as to all issues or that all other
parties are in agreement with the action requested by the motion. Failure to
attach such certification may be deemed good grounds for denying the motion.
The certificate must contain the names of participating counsel and the date and
manner of consultation. The burden will be on counsel filing the motion to
initiate the conference. If opposing counsel or party refuses to cooperate in the
conduct of a conference, counsel must file a certificate to that effect, setting out
counsel’s efforts to comply with this rule.
(b) Motions to suppress, for change of venue, to sever, and to dismiss shall include
memorandum of law and facts. The title of the motion must state that it is both a
motion and a memorandum.
(c) If a party opposes a motion, it shall file a response within 14 days after the motion
is received, which shall contain a memorandum of law and facts. Failure to file a
response will constitute a waiver of any objections which the party may have to a
motion.
(d) Memoranda in support of or in opposition to motions shall not exceed twenty
pages without prior court approval.
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