Discovery

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A. Statement of Resolved and Unresolved Issues in Discovery Motions.

The parties and counsel are expected to continue to discuss resolution of their dispute after any discovery motion is filed. If the parties are unable to resolve their differences prior to oral argument, the moving party shall prepare a written statement of resolved and unresolved issues of no more than 5 pages, certifying that good faith efforts to resolve the matters in controversy have been undertaken, and listing the issues with respect to which an agreement has been reached, as well as the issues yet to be resolved. This statement is NOT to be filed. No less than 5 days before the scheduled hearing, it should be sent directly to chambers through the “Utilities” section of CM/ECF, by fax, or emailed to the case manager.

Failure to timely submit the statement may result in adjournment of the hearing, or dismissal of the motion, as appropriate.

In the event that all disputed issues are resolved prior to the hearing, the moving party shall either withdraw the motion or prepare a stipulation incorporating the agreement of the parties prior to the scheduled hearing date.

B. Potential Informal Conferences

When the district judge has expressly referred all discovery disputes to the magistrate judge, the magistrate judge is available to conduct an informal conference to resolve any pressing discovery disputes. This conference may be in person, or by telephone.

Where there are multiple discovery disputes, or where many motions are filed, the Court may set the matter for a general discovery conference. This conference would be an in-person conference.