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1 verbatim requirement on discovery.
Second Judicial Circuit — Judge Andrew Sheeran only. Practices change without notice; the court's own published text controls. Procedural information only; not legal advice.
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Unlock free →2.2 Certificate of Good Faith Conference - Before filing any motion, the movant must confer with opposing counsel in an effort to resolve the issue(s) raised by the motion.
Reviewer note: Source sha256: fe6a5137127b3f7d615225e75ce668e15df574fae54eba45e9fa022b3ac775c5, 9165b327d522e3154a731d5e2ecd6a9df70a6fdf8960d3e46adf6d6ae64a9388. Corpus categories: discovery_disputes. Published during the 2026-07-24 completeness pass.
Every party setting a hearing in Division AO must first confer in a good-faith effort to resolve the matter, and every hearing notice must include a certificate of that conferral. The division instructions state that conferral requires counsel to actually talk.
Under the 2025 case-management amendments, a movant must confer with the opposing party in a good-faith effort to resolve a nondispositive motion before filing it, and must include a certificate of conferral.
CV-E layers a second conferral on top of Rule 1.202: certify conferral before filing the motion (Exhibit A) and again before scheduling it for hearing (Exhibit B).