D. Conn. L. Civ. R. 37

(a) No motion pursuant to Rules 26 through 37, Fed.R.Civ.P. shall be filed unless counsel

making the motion has conferred, in person or by telephone, with opposing counsel and

discussed the discovery issues between them in detail in a good faith effort to eliminate or

reduce the area of controversy, and to arrive at a mutually satisfactory resolution. In the event

the consultations of counsel do not fully resolve the discovery issues, counsel making a

discovery motion shall file with the Court, as a part of the motion papers, an affidavit certifying

that he or she has conferred with counsel for the opposing party in an effort in good faith to

resolve by agreement the issues raised by the motion without the intervention of the Court, and

has been unable to reach such an agreement. If some of the issues raised by the motion have

been resolved by agreement, the affidavit shall specify the issues so resolved and the issues

remaining unresolved. This rule shall also apply to self-represented parties making such motion

and to parties seeking to file any such motion against self-represented parties.

(b)1. Memoranda by both sides shall be filed with the Clerk in accordance with Rule 7(a)1 of

these Local Rules before any discovery motion is heard by the Court. Each memorandum shall

contain a concise statement of the nature of the case and a specific verbatim listing of each of

the items of discovery sought or opposed, and immediately following each specification shall set

forth the reason why the item should be allowed or disallowed. Where several different items of

discovery are in dispute, counsel shall, to the extent possible, group the items into categories in

lieu of an individual listing of each item. Every memorandum shall include, as exhibits, copies of

the discovery requests in dispute.

2. Where a discovery motion seeks disclosure of documents or electronically stored

information, and the moving party believes in good faith that there is a significant risk that

material information will be destroyed before the motion is decided in accordance with normal

procedure, the moving party shall have good cause to seek expedited consideration of the

motion in accordance with Rule 7(a)4.

(c) Where a party has sought or opposed discovery which has resulted in the filing of a

motion, and that party’s position is not warranted under existing law and cannot be supported by

good faith argument for extension, modification or reversal of existing law, sanctions will be

imposed in accordance with applicable law. If a sanction consists of or includes a reasonable

attorney’s fee, the amount of such attorney’s fee shall be calculated by using the normal hourly

rate of the attorney for the party in whose favor a sanction is imposed, unless the party against

whom a sanction is imposed can demonstrate that such amount is unreasonable in light of all the

circumstances.

(d) Unless a different time is set by the Court, compliance with discovery ordered by the

Court shall be made within fourteen (14) days of the filing of the Court’s order.