The Federal Rules of Civil Procedure are designed to make the discovery process party-driven. The court expects the parties and counsel to conduct discovery cooperatively and fairly. If it becomes necessary to file a motion related to discovery matters, counsel shall meet and confer in accordance with E.D. Mich. LR 37.1 in an attempt to resolve, or at least narrow, the disputed issues. The court encourages counsel to engage in a good-faith attempt to resolve all discovery matters before a motion is heard, and to submit a Stipulation and Order Resolving Motion.

If counsel are unable to resolve their differences, the movant shall prepare a Joint List of Unresolved Issues setting forth the issues that remain unresolved. The Joint List shall not exceed five (5) pages, and should be structured as follows:

Unresolved Issue No. 1: [Recite Issue]

• Movant’s position:
• Respondent’s position (including any proposal made to resolve movant’s request):

No exhibits or attachments shall be filed with the Joint List. The list should be e-filed at least two (2) business days prior to the hearing.

When the district judge has expressly referred all discovery disputes to the magistrate judge, the court is available to conduct an informal discovery conference to resolve pressing discovery disputes.

In a particular case, where there are multiple discovery disputes or where many motions are filed, the court may set the matter for a general discovery conference or direct the parties to conduct a Rule 26(f) conference.