Counsel must meet and confer before requesting in-person ENE/CMC.

Laptops/desktops preferred over mobile devices for Zoom conferences.

Zoom help resources available at support.zoom.us.

Zoom Breakout Room information available at support.zoom.us.

Parties may request in-person ENE/CMC by joint call or email to chambers after meeting and conferring.

Participants should join Zoom conference 5 minutes before ENE start time.

Counsel responsible for ensuring client participation in ENE.

Participants must maintain professionalism and full attention during ENE.

Participants should ensure devices are charged or have charging cable available.

Rule 26(f) conference required for civil cases to discuss discovery topics.

Discuss protective order necessity and timing before discovery exchange.

Confirm ESI preservation and litigation holds are in place.

Discuss search methodologies for ESI including search terms and TAR.

Boilerplate objections like 'overly burdensome' are inadequate unless explained with reasons.

General objections to discovery are not tolerated and should not appear in responses.

Objections based on 'reasonably calculated to lead to admissible evidence' are prohibited.

Privilege objections must be supported with sufficient information to assess the claim.

Discovery requests must be limited by time and scope; parties should narrow overly broad requests during meet and confer.

Court will not rewrite discovery requests; counsel must draft optimal requests.

Rule 34 responses must state a reasonable date for full production; uncertain dates are improper.