Sheboygan County Circuit Court, Wisconsin Pre-Motion Conference Requirements

CRITICAL

Motions to compel discovery or document production and motions for additional interrogatories must include a written statement describing sincere consultation efforts, the inability to reach accord, and the date, place, and participants.

All motions to compel discovery or production of documents pursuant to Chapter 804, Wis. Stats., or any motion to serve additional interrogatories pursuant to rule 1603 must be accompanied by a statement in writing by the movant that, after consultation or repeated attempts at consultation in person or by telephone with the opposing party and sincere attempts to resolve their differences, the parties are unable to reach an accord. The statement shall recite, in addition, the date and place of such consultation or attempted consultation and the names of all parties participating therein.

CRITICAL

Unless the scheduling order provides otherwise, summary judgment motions and supporting papers are due at least 20 days before the hearing, and opposing papers are due at least five days before it.

Unless otherwise specified in the scheduling order, the motion along with a brief and other supporting documents shall be served and filed at least 20 days before the time fixed for the hearing, and the adverse party shall serve and file opposing affidavits, brief, and other supporting documents at least five days before the time fixed for hearing.

WARNING

A party seeking additional interrogatories should promptly consult and attempt to stipulate in writing; if no stipulation is reached, the party may move for permission and must show necessity.

If a party believes that additional interrogatories are necessary, he or she should promptly consult with the party to whom the additional interrogatories would be propounded and attempt to reach a written stipulation as to a reasonable number of additional interrogatories. If a proposed order permitting the propounding of additional interrogatories is agreed upon, it should promptly be served on all other parties and filed with the court. If a stipulation cannot be reached, the party seeking to serve additional interrogatories may move the court pursuant to rule 1604 for permission to serve additional interrogatories. The motion shall show the necessity for the relief requested.