The opinion of the court was delivered by: Esther Salas United States Magistrate Judge
CHAMBERS OF ESTHER SALAS UNITED STATES MAGISTRATE JUDGE MARTIN LUTHER KING COURTHOUSE 50 WALNUT ST. ROOM 2060 NEWARK, NJ 07101 973-297-4887
As discussed at the January 14, 2010 teleconference with this Court; and the Court having been advised that the parties have met and conferred with respect to certain issues and have not been able to resolve them; it is therefore ORDERED that
The parties will prepare and file a joint submission outlining any and all pending discovery disputes.
1) The joint submission shall be in the following format:
a. Disputes Regarding Documents. The parties shall prepare a three-column joint table. Each row of this joint table must: (i) identify a document or category of documents in dispute (if possible by bates-range), (ii) provide a brief synopsis of the complaining party's position, and (iii) provide a brief synopsis of the responding party's position. The brief synopsis should include references to the appendices prepared pursuant to paragraphs 3(d) and 3(e) of this Order, the memoranda of law prepared pursuant to paragraph 3(c) of this Order, and letters already submitted to this Court. If a claim of privilege is being asserted, the complaining party shall submit the privilege log associated with each document in question. The parties should also be prepared to argue the relevance of the documents.
b. Disputes Regarding Interrogatories. The parties shall prepare a three-column joint table. Each row of this joint table must: (i) identify an interrogatory in dispute, (ii) provide a brief synopsis of why the party propounding said interrogatory believes the response is inadequate, (iii) provide a brief synopsis of why the responding party believes the response is sufficient. The brief synopsis should include references to the appendices prepared pursuant to paragraphs 3(d) and 3(e) of this Order, the memoranda of law prepared pursuant to paragraph 3(c) of this Order, and letters already submitted to this Court.
c. Joint Memorandum of Law. The parties must submit a joint memorandum of law, which coincides with the joint tables, to supplement any position taken in either of the joint tables with more extensive legal argument that cites to relevant case law.
d. Joint Appendix. The parties shall compile in a single binder all documents, with the exception of documents subject to claims of privilege or work-product protection, that the Court must consider to resolve the pending discovery disputes.
e. Confidential Appendix. Each party shall also compile in a separate binder all documents subject to disputes regarding privilege or work product protection that the Court must consider in camera to resolve the pending discovery disputes.
2) Each party shall deliver their portion of the submission to the other on or before February 4, 2010
3) The joint submission is due to this Court on or before February 24, 2010 The submission does NOT need to be e-filed; please simply forward an ...