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B-7037-1. DISCOVERY DISPUTES

(a)   Required Actions Prior to Court Involvement

Prior to involving the Court in any discovery dispute, including disputes involving depositions, counsel must confer in a good faith attempt to resolve the dispute. If any such dispute cannot be resolved in this manner, counsel are encouraged to contact the chambers of the assigned Judge to determine whether the Judge is available to resolve the discovery dispute by way of a telephone conference or other proceeding prior to counsel filing a formal discovery motion. When the dispute involves an objection raised during a deposition that threatens to prevent completion of the deposition, any party may recess the deposition to contact the Judge's chambers.

(b)   Requirements of Motion to Compel

In the event that the discovery dispute is not resolved at the conference, counsel may file a motion to compel or other motion raising the dispute. Any motion raising a discovery dispute must contain a statement setting forth the efforts taken to resolve the dispute, including the date, time, and place of any discovery conference and the names of all participating parties. The Court may deny any motion raising a discovery dispute that does not contain such a statement.

(c)   Pro Se Parties

Discovery disputes involving pro se parties are not subject to this rule.