Rule 6.4.Failure to Make Discovery and Motion to Compel Discovery

Rule 6.4 makes a motion to compel discovery show its work. The motion has to quote each disputed interrogatory, request for admission, or request for production word for word — or attach a copy as an exhibit — for every item the moving party says drew an objection, no response, or an inadequate one. Alongside each item, the motion needs the specific objection or response being challenged, the grounds behind that objection if they aren’t already obvious, and the reasons supporting the motion. General, catch-all objections don’t survive under this rule — every objection has to be tied to the specific interrogatory, admission request, or production request it answers.

Before any of that reaches the judge, the rule demands a real conversation between the lawyers. Counsel for the party seeking to compel discovery has to confer with opposing counsel, and with any objecting nonparty, in a good faith attempt to work out the dispute without the court’s help. When the motion gets filed, it must come with a statement certifying that this conference happened and that the effort to resolve things by agreement came up short. The same meet-and-confer and certification requirements reach beyond motions to compel — they apply to motions to quash, motions for a protective order, and situations where no discovery has been produced at all.