N.D. Miss. L.U. Civ. R. 37

(a) Good Faith Certificate. Before service of a discovery motion, counsel must

confer in good faith to determine to what extent the issue in question can be

resolved without court intervention. A Good Faith Certificate [Official Form No.

4] must be filed with all discovery motions. This certificate must specify whether

the motion is unopposed, and if opposed, by which party(ies), and the method by

which the matter has been submitted to the magistrate judge for resolution. The

certificate must bear the signatures/endorsements of all counsel. If a party fails to

cooperate in the attempt to resolve a discovery dispute or prepare the Good Faith

Certificate, the filed motion must be accompanied by an affidavit or a 28 U.S.C.

§ 1746 declaration by the moving party detailing the lack of cooperation and

requesting appropriate sanctions.

(b) Motions Must Quote Disputed Language. Motions raising issues concerning

discovery propounded under FED. R. CIV. P. 33, 34, 36, and 37 must quote

verbatim each interrogatory, request for production, or request for admission to

which the motion is addressed, and must state:

(1) the specific objection;

(2) the grounds assigned for the objection (if not apparent from the objection

itself); and

(3) the reasons assigned as supporting the motion.

The objections, grounds, and reasons must be written in immediate succession to

the quoted discovery request. The objections and grounds must be addressed to the

specific interrogatory, request for production, or request for admission and may not

be general in nature.

(c) Failure to comply with subsections (a) or (b) of this rule will result in a denial of

the motion without prejudice to the party, who may refile the motion upon

conformity with this rule.

(d) L.U. CIV. R. 37 Motion to Limit or Quash a Deposition. The filing of a motion

for a protective order to limit or quash a deposition does not operate as a stay of

the deposition. It is incumbent upon the party seeking the protection of the court to

obtain a ruling on the motion before the scheduled deposition.