The court believes that the import of the Federal Rules of Civil Procedure is to place discovery in the hands of counsel. The court encourages counsel to attempt to resolve all discovery matters before a motion is filed. If a motion addresses discovery issues, counsel shall meet and confer in accordance with E.D. Mich. LR 37.1. If counsel are unable to resolve their differences, the movant shall prepare a JOINT Statement of unresolved issues setting forth the issues that remain unresolved. The Joint Statement should be e-filed 5 business days prior to the hearing.