Meet & Confer
S.D.N.Y. — ## S5.
S5. Meet & Confer
Discovery Motions: Premotion Conference Required (Rule 37.2)
No discovery motion under FRCP 26-37 or 45 will be heard unless counsel has first:
- Requested an informal conference with the court by letter-motion for a premotion discovery conference, AND
- That request was either denied or the dispute was not resolved at the conference
This is a mandatory prerequisite. Filing a discovery motion without first requesting the premotion conference will result in the motion not being heard.
Motions in Limine (Rule 6.4)
A certification of conferral is required -- the moving party must certify that it conferred or attempted to confer with the opposing party in a good faith effort to resolve the issues without court intervention.
Non-Discovery, Non-Limine Motions
The local rules do not impose a general conferral requirement for other motion types. However, individual judges may require pre-motion conferences per their individual practices. Always check the assigned judge's individual rules and standing orders.