DISCOVERY DISPUTES

(a) Required Actions Prior to Court Involvement Counsel shall confer in a good faith attempt to resolve any discovery dispute prior to involving the Court. If a dispute cannot be resolved, counsel may contact the chambers of the assigned Judge to determine whether the Judge is available to resolve the discovery dispute by telephone conference or other proceeding prior to the filing of a formal discovery motion. When the dispute involves an objection raised during a deposition that threatens to prevent completion of the deposition, any party may recess the deposition to contact the Judge’s chambers. (b) Requirements of Motion to Compel If the discovery dispute is not resolved at the conference, counsel may file a motion to compel or other appropriate motion.

A motion raising a discovery dispute shall contain a statement setting forth the efforts taken to resolve the dispute, including the date, time, and place of any discovery conference and the names of all participating parties. The Court may deny a motion raising a discovery dispute that does not contain such a statement. 60 | P a g e (c) Pro Se Parties Discovery disputes involving pro se parties are not subject to this rule.