Discovery - Disputes

40 (a) Parties Must Confer -- Affidavit Except in circumstances where one party to a discovery dispute is appearing pro se, a motion relating to discovery will not be considered by the Court unless counsel for the moving party has filed an affidavit stating that he or she has conferred personally in good faith with counsel for the opposing party in an effort to resolve the discovery dispute without court intervention and that the parties have been unable to reach such an agreement. Alternatively, counsel must certify what efforts were made to confer with opposing counsel or why such conference was not held. (b) Discovery Disputes (1) (2) A motion to compel discovery must have attached to it the relevant discovery requests and responses. A motion seeking the imposition of sanctions under Federal Rule of Civil Procedure 37(b), (c), or (d) must have attached to it all documents considered by movant to be relevant to the motion.