To the extent a discovery disputes arise among the parties (or third parties), the Court discourages the filing of formal motions to compel or motions for protective orders. If after satisfying their meet and confer obligations under N.D. Ind. L.R. 37-1 the parties are unable to reach a resolution, they should instead file a Joint Motion for Discovery Ruling. The Joint Motion should be no more than five pages. It should succinctly summarize the unresolved issue(s) without extensive legal citation (unless particularly relevant to a particular issue) and state each party’s position and any proposed compromise with respect to each unresolved issue. The parties should also attach as exhibits (1) the written discovery at issue (if applicable), and (2) any prior correspondence between the parties relating to the issue(s).

In the rare instance where the parties are unable to file a joint motion, each party may submit their own Motion for Discovery Ruling of no more than three pages which should be filed simultaneously. The Court will then promptly set the matter for a telephonic hearing to resolve the issue and/or request further briefing or alert the parties that it will rule on the papers submitted.