Court of Common Pleas of Columbia County, Pennsylvania Pre-Motion Conference Requirements

Before seeking permission to submit more than 40 interrogatories, counsel must promptly consult opposing counsel in good faith and attempt to agree in writing; absent agreement, the party must move for relief and show necessity.

If counsel for a party believes that more than 40 interrogatories are necessary he shall consult with opposing counsel promptly and attempt to reach a written Stipulation as to a reasonable number of additional interrogatories. Counsel are expected to comply with this requirement in good faith. In the event a written Stipulation cannot be agreed upon, the party seeking to submit additional interrogatories shall file a Motion with the Court showing the necessity of relief.

Before seeking permission to submit more than 40 requests for admissions, counsel must promptly consult opposing counsel in good faith and attempt to agree in writing; absent agreement, the party must move for relief and show necessity.

If counsel for a party believes that more than (40) requests for admissions are necessary, counsel shall consult with opposing counsel promptly and attempt to reach a written Stipulation as to a reasonable number of additional requests for admissions. Counsel are expected to comply with this requirement in good faith. In the event a written Stipulation cannot be agreed upon, the party seeking to submit additional requests for admissions shall file a Motion with the Court showing the necessity for relief.