DISCOVERY RELATED MOTIONS

A discovery motion under Bankruptcy Rules 7026 through 7037 shall be supported by an affidavit or affirmation certifying that the moving party has made a good faith effort to confer with the opposing party to resolve the issues raised by the motion by agreement and without judicial intervention, but has been unable to reach an agreement. The affidavit or affirmation shall describe the efforts to resolve the discovery dispute without judicial intervention. The affidavit or affirmation shall specify any issues so resolved and the issues remaining unresolved. The affidavit or affirmation shall be filed and served together with the motion.

No discovery-related motion under Bankruptcy Rules 7026 through 7037 shall be filed unless counsel for the moving party first requests a conference with the Court and either (i) the request has been denied, or (ii) the discovery dispute has not been resolved as a consequence of the conference. CROSS-REFERENCES: REFERENCES: E.D.N.Y. LBR 9006-1, 9013-1 Bankruptcy Rules 7026, 7037 7007.1-1 CORPORATE OWNERSHIP STATEMENT TO BE FILED BY A PARTNERSHIP OR JOINT VENTURE THAT IS A PARTY TO AN ADVERSARY PROCEEDING The Corporate Ownership Statement required under Bankruptcy Rule 7007.1 shall also be filed by any party to an adversary proceeding, other than the debtor or a governmental entity, that is a general or limited partnership or joint venture. Comment: Bankruptcy Rule 7007.1, effective December 1, 2003, requires a Corporate Ownership Statement to be filed for any corporation that is a party to an adversary proceeding other than the debtor or a governmental entity. “Corporation” is broadly defined under Bankruptcy Code § 101(9) (and includes, for instance, limited liability companies and other unincorporated companies or associations), but it does not cover general or limited partnerships.

The reasons for which this rule was enacted - to give the Judges of this Court information by which they can determine whether or not they need to recuse themselves - apply equally to general and limited partnerships, and joint ventures. This local rule requires a similar disclosure with respect to business organizations of that character. -57- 7012-1 EXTENSION OF TIME TO PLEAD OR FILE MOTION The deadline to plead or move in response to a complaint or other pleading in an adversary proceeding may be extended for a period of up to 30 days by stipulation of the parties docketed with the Court or, for a longer period of time, by order of the Court or further stipulation of the parties that has been so-ordered by the Court. Any motion for extension of time to plead or move in response to a complaint or other pleading in an adversary proceeding or a stipulation seeking entry of an order approving such extension shall be filed with the Court prior to the expiration of the deadline to be extended. Any deadline extended pursuant to this rule shall not affect any other deadlines set forth in any scheduling order entered by the Court.