Obligations of All Parties

(a) Discovery Motions. Counsel must confer with opposing counsel in a good-faith effort to resolve any discovery dispute prior to filing a discovery motion, including, for example, any motion to compel disclosure of Brady materials, Giglio materials, confidential informants, Jencks Act materials, and reciprocal discovery. Counsel shall certify the good-faith effort in an exhibit attached to the discovery motion. (b) Voluminous Production.

A party producing a voluminous collection of discovery materials shall provide a table of contents generally describing the documents by origin, type, and location within the production. (c) Conference and Stipulations. At least 7 days prior to the pretrial conference, or if no pretrial conference is held, 7 days prior to trial, counsel shall confer regarding any stipulations of fact and stipulations to the authenticity or admissibility of exhibits. All stipulations shall be written and signed by Defendant, Defendant’s counsel, and counsel for the Government.

The parties shall file all stipulations at least 2 days before trial. The presiding judge may permit additional stipulations at trial. (d) Demonstrative, Summary, and Composite Exhibits. A party shall disclose all demonstrative, summary, and composite exhibits intended to be used in a party’s opening statement, case-in-chief, or cross-examination, including evidence under Federal Rule of Evidence 1006, at least 2 days before trial.

(e) Electronic Surveillance or Consensual Interception Recording Transcripts. Preliminary and final transcripts of electronic surveillance or consensual interception recordings should be disclosed promptly once the transcript has been prepared. Nothing in this Local Rule shall be construed to require a party to prepare preliminary or final transcripts. 27