(a) Duty to Confer. Prior to filing any motion relating to discovery pursuant to Federal
Rules of Civil Procedure 26-37, counsel for the parties shall confer in a good faith effort to
eliminate the necessity for the motion or to eliminate as many of the disputes as possible. Such
conference shall include oral communication. It shall be the responsibility of counsel for the
moving party to arrange for this conference.
(b) Deadline for Completion. Unless otherwise provided by stipulation or by written order
of the Court, the conference of counsel shall be completed within 15 calendar days after the
moving party serves a written communication requesting such conference. The moving party’s
letter shall identify each issue and/or discovery request in dispute, state briefly with respect to
each the moving party’s position, providing any legal authority, and specify the terms of the
Case: 3:25-mc-00003-RAM-GAT Document #: 10-1 Filed: 01/30/26 Page 24 of 44
discovery order to be sought.
(c) Informal Conference with Magistrate Judge. In the event counsel are unable to
resolve the areas of dispute, a joint request shall be made for an informal conference with the
Magistrate Judge. The joint request should be submitted in email format to the Chambers email
address for the Magistrate Judge. It should briefly identify the issues that are in dispute without
citation to legal authority. The purpose of the paragraph is to explain the general nature of the
dispute rather than to brief the issues as one would do in a motion to compel. If a joint request
cannot be made, the party requesting the conference should explain why the request could not
be submitted jointly. Counsel are expected to come to the informal conference prepared and with
the authority to resolve the disputes.
