All motions to compel disclosure or discovery pursuant to Fed. R. Civ. P. 26
through 37 must be accompanied by a written certification by the movant that, after
the movant in good faith has conferred or attempted to confer with the person or party
failing to make disclosure or discovery in an effort to obtain it without court action,
the parties are unable to reach an accord. The statement must recite the date and
time of the conference or conferences and the names of all parties participating in the
conference or conferences.
Committee Comment: Under Fed. R. Civ. P. 16(b)(3)(B)(v) effective December
1, 2015, absent contrary Congressional action, practitioners are encouraged to seek a
pre-motion conference with the Court.
VI. TRIALS
