Yes. A pre-motion letter is required for discovery. Discovery disputes require good faith conference and certification under Local Rule 7.1(a)(3).
The rule requires specific objection grounds. Boilerplate objections to discovery requests are prohibited; objections must state specific grounds.
The rule requires clear production statement. Discovery responses must include clear statement that all responsive documents have been produced.
Parties may contact Judge Edwin G. Torres' chambers by phone only as allowed by the rule. The rule lists phone (305) 523-5750. Contact chambers by noon Friday to schedule discovery calendar; 30 minutes per side allowed.
Requests should be made at least 28 calendar days in advance when this rule applies before Judge Edwin G. Torres. Discovery disputes must be raised within 28 days (with 7-day extension) and completed before discovery cutoff.
Yes. Judge Edwin G. Torres requires bundling for covered papers. Substantive discovery motions filed on docket will be stricken; use discovery calendar instead.
Boilerplate objections to discovery requests are prohibited; objections must state specific grounds.
Objections to discovery must include specific explanations for relevance challenges.
Formulaic objections followed by answers are prohibited and waste resources.
Objections must clearly indicate whether questions are fully answered.
Discovery responses must include clear statement that all responsive documents have been produced.
Privilege objections must identify specific privilege type and communication details.
Scope objections to 30(b)(6) notices must be served (not filed) before deposition.
Parties may sequence their own discovery without waiting for others.
Depositions must begin before the end of the discovery period.
Rule 26(a)(1) required disclosures must be made at discovery inception.
Inadequate disclosures must be raised with Court after conferral.
Supplemental depositions may be compelled for improper Rule 26(a)(1) compliance.
Objecting party bears burden to show specificity why request is unreasonable.
Failure to meet burden results in discovery compulsion under Rule 37.
Lack of substantial justification may result in monetary sanctions.
Requesting party must show relevance, necessity, and proportionality.
Discovery disputes require good faith conference and certification under Local Rule 7.1(a)(3).
Discovery disputes must be raised within 28 days (with 7-day extension) and completed before discovery cutoff.
Substantive discovery motions filed on docket will be stricken; use discovery calendar instead.
Contact chambers by noon Friday to schedule discovery calendar; 30 minutes per side allowed.
File Motion for Hearing on same day as calendar confirmation, including category and pre-filing status.