The court believes that the import of the Federal Rules of Civil Procedure is to place discovery in the hands of counsel. If a motion addresses discovery issues, counsel shall meet and confer in accordance with E.D. Mich. LR 37.1 in an attempt to resolve, or at least narrow, the issues of dispute. The court encourages counsel to attempt to resolve all discovery matters before a motion is heard, and submit a Stipulation and Order Resolving Motion. In addition, prior to filing a motion to compel, the court is willing to conduct a telephone conference with the parties in an attempt to resolve the dispute. The parties should contact the case manager to make the necessary arrangements.
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]
No exhibits or attachments shall be filed with the Joint List. The list should be e-filed two (2) business days prior to the hearing.
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.
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