W.D. Tenn. LCrR 12.1

(a) All non-substantive motions, including discovery motions, shall include a certificate

of counsel affirming that, after consultation between the parties to the controversy,

they are unable to reach an accord as to all issues or that all other parties are in

agreement with the action requested by the motion. Failure to attach such

certification may be deemed good grounds for denying the motion. The certificate

must contain the names of participating counsel and the date and manner of

consultation. The burden will be on counsel filing the motion to initiate the

conference. If opposing counsel or party refuses to cooperate in the conduct of a

conference, counsel must file a certificate to that effect, setting out counsel’s efforts

to comply with this rule.

(b) Motions to suppress, for change of venue, to sever, and to dismiss shall include

memorandum of law and facts. The title of the motion must state that it is both a

motion and a memorandum.

(c) If a party opposes a motion, it shall file a response within 14 days after the motion is

received, which shall contain a memorandum of law and facts. Failure to file a

response will constitute a waiver of any objections which the party may have to a

motion.

(d) Memoranda in support of or in opposition to motions shall not exceed twenty pages

without prior court approval.