The rule does not state that a pre-motion letter is required, but it sets the applicable pre-motion procedure. Parties must confer in good faith before seeking discovery relief, with at least one personal communication (in person, videoconference, or telephone).
Judge Ellen Frances D'Angelo's rule states these limits: 5 pages. Discovery motions limited to 5 pages and must include certificate of good faith efforts.
The rule requires certificate of conference. Discovery motions must include certificate of good faith efforts to resolve dispute.
Yes. Judge Ellen Frances D'Angelo's rules include a junior lawyer participation incentive. Junior lawyers (5 years or less experience) may argue with multiple attorneys if notified in advance.
Parties must confer in good faith before seeking discovery relief, with at least one personal communication (in person, videoconference, or telephone).
Discovery motions limited to 5 pages and must include certificate of good faith efforts.
Discovery motions must include certificate of good faith efforts to resolve dispute.
Non-compliant discovery motions will be stricken from the docket.
Junior lawyers (5 years or less experience) may argue with multiple attorneys if notified in advance.