Waukesha County Circuit Court Pre-Motion Conference Requirements

CRITICALCivil cases

A discovery motion to compel or for a protective order must be preceded by a good-faith effort to confer with the opposing party.

All motions to compel discovery or for a protective order precluding or limiting discovery must be accompanied by an affidavit by the movant certifying that, after the movant in good faith has conferred or attempted to confer with the opposing party to resolve the discovery dispute without court action, the parties are unable to reach an accord.

CRITICAL

Discovery motions to compel or for additional interrogatories must include an affidavit documenting unsuccessful consultation and the consultation's date, place, and participants.

All motions to compel discovery or production of documents pursuant to Wis. Stats. §804, or any motion to serve additional interrogatories pursuant to Rule 3.3 must be accompanied by an affidavit by the movant that, after 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 and the names of all parties participating therein.

WARNING

A party seeking additional interrogatories should promptly consult the other party and attempt to agree in writing on a reasonable number.

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.