Judge Jeffery T. McPherson
Individual Rules, Standing Orders & Policies
Document Filing Requirements2 rules
The joint memorandum must set forth the meeting date and format, attending attorneys' names and bar numbers, meeting length, a description of unresolved disputes with the discovery requests and objections attached, and a certification that clients were informed of the meeting and the inability to resolve the disputes without a court appearance.
1. the date of the meeting, and whether the meeting was in person or by video conference; 2. the names and bar numbers of the attorneys attending the meeting; 3. the length of the meeting; 4. a brief description of the discovery disputes not resolved at the meeting, with a copy of the discovery request(s) and the objection(s) thereto attached; and 5. a certification by counsel that their respective clients have been informed of the meeting and the inability of counsel to resolve their discovery disputes without a court appearance.
Document Type
Joint Memorandum
If opposing counsel refuses to meet and confer, the moving party's motion must state what sanctions it seeks against the non-complying party.
In the event of such refusal, the moving party shall advise the Court in its motion as to what sanctions it seeks against the non-complying party.
Document Type
Motion
Filing & Service rules
Pre-Motion Conference Requirements
Discovery disputes (including motions to compel or for sanctions) will not be heard unless counsel first meet at least once in person or by video conference and file a joint memorandum before obtaining a hearing date from the division clerk.
no discovery disputes (including motions to compel discovery responses or motions for sanctions) will be heard in Division 16 unless, prior to obtaining a hearing date from the division clerk, counsel for the parties meet at least once in person or by video conference in a good faith effort to resolve their discovery disputes and file a joint memorandum with the Court, substantially in the form attached hereto
Page 1 | DISCOVERY DISPUTES IN ALL CIVIL CASES
A party may be excused from the meet-and-confer requirement for good cause shown, such as opposing counsel's refusal to respond to requests to meet and confer.
A party may request excusal from the in-person meeting requirement of this order for good cause shown, such as opposing counsel's refusal to respond to requests to meet and confer.
Page 1 | Good Cause Exception and Sanctions