Duty to Consult Before Filing Any Motion. Absent exemption in the governing

federal or local civil rule or as set forth below, all motions shall contain an affirmation by the movant’s counsel that prior to filing the motion he or she conferred or attempted to confer with opposing counsel and attempted in good faith to resolve the matter contained in the motion. If a conference could not be held despite an attempt to do so, counsel shall explain why such 5 Scheduling orders generally allow a minimum amount of time between the various deadlines listed in Local Civ. Rules 16.01, 16.02 (D.S.C.) to ensure the orderly progress of the case. (For example, sufficient time is required between the motion deadline and trial date to brief and resolve any motion.) 6 conference could not be held. Counsel is under no duty to consult with a pro se litigant.

The following motions are excluded from this rule: (A) Motion to dismiss. (B) Motion for summary judgment. (C) Motion for new trial or judgment as a matter of law. (D) Other similar dispositive motions.

(E) Motions filed in real estate mortgage foreclosure cases. (F) Motion to stay under Local Civ. Rule 16.00(C) (D.S.C.).