(a) Objections to Disclosures or Discovery.
Objections to disclosures or discovery that are not filed within the response time
allowed by the Federal Rules of Civil Procedure, the scheduling order(s), or
stipulation of the parties pursuant to FR Civ P 29, whichever governs, are waived
unless otherwise ordered for good cause shown. Objections shall comply with FR
Civ P 26(g) and any claim of privilege or objection shall comply with
FR Civ P 26(b)(5).
(b) Duty to Confer.
Before filing any discovery motion, including any motion for sanctions or for a
protective order, counsel for each party shall make a good faith effort to confer in
person or by telephone to narrow the areas of disagreement to the greatest possible
extent. It shall be the responsibility of counsel for the moving party to arrange for
the meeting.
(c) Motions to Compel.
A motion to compel disclosure or discovery must be accompanied by a statement
setting forth verbatim each discovery request or disclosure requirement and any
response thereto to which an exception is taken. In addition, the movant may
include a statement of the grounds and pertinent authorities relied upon and shall
file such a statement if requested by the court. If the discovery request or disclosure
requirement is ignored, the movant need only file a motion to compel without
setting forth verbatim the discovery request or disclosure requirement. Motions to
compel or other motions in aid of discovery not filed within 30 days after the
discovery response or disclosure requirement was due are waived, and in no event
provide an excuse, good cause or reason to delay trial or modify the scheduling
order. The 30-day deadline may be extended by court order for good cause shown,
or by stipulation of the parties, so long as the extension does not interfere with the
scheduling order. Any such stipulation must be filed pursuant to LR Civ P 11.2.
(d) Telephonic Conferences During Discovery Events.
If a dispute arises during a discovery event, the parties must attempt in good faith
to resolve the matter without judicial intervention. If a good faith conferral fails to
resolve the dispute and if its disposition during the discovery event is likely to result
in savings of substantial time and expense, a party or counsel may contact the
chambers= staff of the magistrate judge to whom the case is assigned to request a
telephone conference during the discovery event.
Page 30 of 83
