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3 verbatim requirements on discovery.
Second Judicial Circuit — Judge Joshua M. Hawkes only. Practices change without notice; the court's own published text controls. Procedural information only; not legal advice.
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Unlock free →2.3 – Certificate of Good Faith Conference – Before filing any motion, except as noted in paragraph C., the moving party shall confer with counsel for the opposing party in a good faith effort to resolve the issues raised by the motion, and the motion shall contain a statement certifying that the moving party has conferred with opposing counsel and that counsel have been unable to agree on the resolution of the motion (the “Certificate”).
Reviewer note: Source sha256: 389f812a2f274f392cc028b5c3318e250350e9ca6081582d101c65f7dac13d18, 0e87d68dfa99a5f6b7733ca87ec009139a185f84af038fdf0080b7380cf94c97, 5f742304747cdfb78b2cc4897fbb93662df62525d505e8196b31203eeecdc7b2. 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).