Conclusory objections without factual basis will be summarily rejected or deemed waived.

Pro forma discovery plans lacking substantive discussion are prohibited.

Issues not raised in discovery plan but first raised in motion to compel may be deemed waived.

Ex parte applications to shorten time for motion to compel are prohibited without showing due diligence and good cause.

Parties must seek relief from scheduling order before filing motion to compel if no due diligence shown.

Failure to obtain non-waiver agreement/order under Rule 502 may be considered in privilege disputes.

Counsel must follow amended Rule 37(e) when seeking sanctions for ESI spoliation.

Pre-2015 Rule 37(e) sanctions cases should be used cautiously due to rule changes.

Chambers copy must be delivered by noon next day after submission.

File both complete and redacted versions when possible.

Redacted portions must be bracketed and highlighted on unredacted copies.

Each sealed item must be individually justified; blanket claims not allowed.

Meritless sealing requests may result in complete rejection.

Mandatory chambers copies and proposed orders required for sealed documents

Application and proposed order are public; declaration and sealed documents are not.

Application for leave to file under seal requires declaration, proposed order, redacted and unredacted documents.

Protective order parties must file sealed declaration explaining need for sealing.

Sealed documents not accessible via NEF; filing party must serve by other means with certificate of service.

Sealed documents are restricted from viewing through NEF.

Sealed documents filed in CM/ECF are only viewable by the filing attorney and court personnel.

Only specific sealed docket entries create sealed documents.

Sealed documents must be marked with filing under seal language.

Docket entries for sealed documents are public even if the document is sealed.

Chambers copies of sealed documents must be in sealed envelopes with title page attached.

Redacted documents must have 'REDACTED' in caption and docket text.

Paper filing of sealed documents requires sealed envelopes and PDF on CD.

CM/ECF screen turns red when using sealed document events.

Application for Leave to File Under Seal requires declaration, proposed order, redacted and unredacted documents.

Application and redacted documents are public; declaration and unredacted documents are sealed.

Serve sealed documents by printing NEF and delivering sealed declaration and unredacted document to opposing counsel.