B-9013-1. MOTION PRACTICE; OBJECTIONS TO MOTIONS

(a)   Separate Motions and Objections

Every application, motion, or other request for an order from the Court, including motions initiating contested matters, shall be filed separately, except that requests for alternative relief may be filed together, subject to subparagraphs (b) and (c). All such requests shall be named in the caption, shall state with particularity the order or relief sought, and contain a short and plain statement concerning the factual basis or grounds for the motion. If the alternative relief requested has varying requirements for notice, the notice must provide the longest of the alternative periods. Objections to separately filed motions must also be filed separately.

(b)   Stay Relief or Adequate Protection Motions

Motions seeking relief from the automatic stay or adequate protection may not be joined with any other objection or request for relief except abandonment.

(c)   Motions Where Hearing Scheduled by “Block Scheduling

Where the hearing for the relief sought in the motion is subject to the “block scheduling” procedure established by the Court, the motion shall request only that type of relief, and a request for alternative relief may not be sought in the motion.

(d)   Content of Objections

As to any matter in which the Court may grant relief without a hearing in the absence of a timely objection, objections to the motion, application, or request shall contain a short, plain statement concerning the factual or legal basis for the objection. The failure to state a sufficient legal or factual basis for the objection may result in the objection being overruled without a hearing.

(e)   Duty to Confer

If a motion is contested, the movant shall confer with the respondent prior to the hearing to determine whether a consent order may be entered disposing of the motion, or in the alternative, to stipulate on as many facts and issues as possible.