The rule does not state that a pre-motion letter is required, but it sets the applicable pre-motion procedure. Discovery disputes require in-person or phone conference before seeking court intervention.
Judge Jared M. Strauss' rule states these limits: 5 pages. Discovery motions involving non-parties are limited to 5 pages (double-spaced) with no reply unless ordered.
The rule requires specific explanation. Objections based on 'reasonably calculated to lead to admissible evidence' are meritless; must include specific explanation for relevance/proportionality objections.
The rule requires partial response. Parties must respond to undisputed portions of discovery requests even when objecting to other parts.
Requests should be made at least 28 calendar days in advance when this rule applies before Judge Jared M. Strauss. Discovery disputes must be brought to court within 28 days of when grounds for relief occur.
No. The rule prohibits holding covered papers for bundling. Written discovery motions between parties are prohibited unless specifically authorized by court order.
Yes. Judge Jared M. Strauss's rules include a junior lawyer participation incentive. Parties must notify court if lawyer with 5 or fewer years experience will argue.
Objections based on 'reasonably calculated to lead to admissible evidence' are meritless; must include specific explanation for relevance/proportionality objections.
All discovery objections must be specific; generalized, vague, or boilerplate objections are not permitted and will not be sustained.
Objections stating 'vague, overbroad, or unduly burdensome' without explanation are meaningless and will be stricken.
Objections must specify whether request is irrelevant or disproportionate and provide explanation.
Parties must confer in good faith to narrow scope before asserting objections for irrelevant, disproportionate, or unduly burdensome requests.
Parties must respond to undisputed portions of discovery requests even when objecting to other parts.
Discovery disputes require in-person or phone conference before seeking court intervention.
Discovery disputes must be brought to court within 28 days of when grounds for relief occur.
Discovery disputes must be brought to court at least 7 days before discovery cutoff, absent exceptional circumstances.
Written discovery motions between parties are prohibited unless specifically authorized by court order.
Discovery disputes must be filed as "Notice of Discovery Dispute" after good faith conferral, not as motions.
Discovery motions involving non-parties are limited to 5 pages (double-spaced) with no reply unless ordered.
Parties must notify court if lawyer with 5 or fewer years experience will argue.
Court allows multiple lawyers to argue if junior lawyer is presenting.
Stipulated orders require joint motion and Word version emailed to judge.