DISCOVERY - GENERAL

A.Filing of pleadings and other papers, including certain discovery papers, is governed by Local Rule 7005-2. B.Every motion or objection relating to a discovery dispute shall contain a statement that counsel for the moving party or pro se litigant has consulted with counsel for the adverse party or pro se litigant concerning the motion or objection and the parties have failed to resolve the discovery dispute despite good faith efforts. If the parties agree that certain discovery orders such as discovery scheduling orders or protective orders should be entered, the parties may submit a joint motion and a proposed agreed order. The proposed agreed order shall be submitted to the Court in accordance with Local Rule 9072-1(A) and (D).

RULE 7030-1.

DEPOSITIONS

Before filing a notice of deposition of a party, counsel for the party seeking to take the deposition shall make a good faith effort to confer with the proposed deponent through deponent’s counsel, if any, to arrange an agreeable date, time, and place for the deposition.