Hon. Eleanor G. Tennyson

The following attorneys, including at least one Delaware Counsel and at least one Lead Counsel per party, participated in a verbal meet-and-confer.

Each party is permitted to file as many case dispositive motions as desired, but each SIDE will be limited to a combined total of 40 pages for all opening briefs, a combined total of 40 pages for all answering briefs, and a combined total of 20 pages for all reply briefs, regardless of the number of case dispositive motions that are filed. In the event that a party files, in addition to a case dispositive motion, a Daubert motion to exclude or preclude all or any portion of an expert's testimony, the total amount of pages permitted for each SIDE for all case dispositive and Daubert motions shall be increased to 50 pages for all opening briefs, 50 pages for all answering briefs, and 25 pages for all reply briefs.

(c) Page limits combined with Daubert motion page limits. Each party is permitted to file as many case dispositive motions as desired, but each SIDE will be limited to a combined total of 40 pages for all opening briefs, a combined total of 40 pages for all answering briefs, and a combined total of 20 pages for all reply briefs, regardless of the number of case dispositive motions that are filed. In the event that a party files, in addition to a case dispositive motion, a Daubert motion to exclude or preclude all or any portion of an expert's testimony, the total amount of pages permitted for each SIDE for all case dispositive and Daubert motions shall be increased to 50 pages for all opening briefs, 50 pages for all answering briefs, and 25 pages for all reply briefs.

(c) Page limits combined with Daubert motion page limits. Each party is permitted to file as many case dispositive motions as desired, but each SIDE will be limited to a combined total of 40 pages for all opening briefs, a combined total of 40 pages for all answering briefs, and a combined total of 20 pages for all reply briefs, regardless of the number of case dispositive motions that are filed. In the event that a party files, in addition to a case dispositive motion, a Daubert motion to exclude or preclude all or any portion of an expert's testimony, the total amount of pages permitted for each SIDE for all case dispositive and Daubert motions shall be increased to 50 pages for all opening briefs, 50 pages for all answering briefs, and 25 pages for all reply briefs.

the party seeking relief shall file with the Court a letter not to exceed three (3) pages in 12-point font outlining the issues in dispute and that party's position on those issues... any party opposing the application for relief may file a letter not to exceed three (3) pages in 12-point font outlining that party's reason for its opposition.

Courtesy Copies. The parties shall provide to the Court two (2) courtesy copies of all briefs and any other document filed in support of any briefs (i.e., appendices, exhibits, declarations, affidavits, etc.). This provision also applies to papers filed under seal. All courtesy copies shall be double-sided. Exhibits and attachments must be separated by tabs, and the parties should highlight the portions of the exhibits and attachments that they wish the Court to read.

This submission shall include as exhibits (1) a proposed order that identifies with specificity the relief sought on an issue-by-issue basis and (2) copies of any discovery requests and responses relating to the dispute.

Papers Filed Under Seal. In accordance with section G of the Revised Administrative Procedures Governing Filing and Service by Electronic Means, a redacted version of any sealed document must be filed electronically within seven (7) days of the filing of the sealed document. Should any party intend to request to seal or redact all or any portion of a transcript of a court proceeding (including a teleconference), such party should expressly note that intent at the start of the court proceeding. Should any party subsequently choose to make a request for sealing or redaction, it must, promptly after the completion of the transcript, file with the Court a motion for sealing/redaction, and include as attachments (1) a copy of the complete transcript highlighted so the Court can easily identify and read the text proposed to be sealed/redacted and (2) a copy of the proposed redacted/sealed transcript. With such request, the party seeking redactions must demonstrate why good cause exists for the redactions and why disclosure of the redacted material would work a clearly defined and serious injury to the party seeking redaction.

ADR Process. This matter is NOT referred to a magistrate judge to explore the possibility of alternative dispute resolution.

(i) Any discovery motion filed without first complying with the following procedures will be denied without prejudice to renew pursuant to these procedures. (ii) Should counsel find that, after reasonable efforts pursuant to Local Rule 7.1.1, they are unable to resolve a discovery matter or a dispute relating to a protective order, the moving party (i.e., the party seeking relief from the Court) should file a Motion for Teleconference to Resolve a Discovery or Protective Order Dispute. The text for this motion can be found in the "Forms" section of Magistrate Judge Tennyson's portion of the Court's website. (iii) After reviewing the motion, the Court will issue an order setting a discovery conference and outlining the specific dispute procedure to be used. On the date set by court order, generally not less than seventy-two (72) hours prior to the conference, the party seeking relief shall file with the Court a letter not to exceed three (3) pages in 12-point font outlining the issues in dispute and that party's position on those issues. This submission shall include as exhibits (1) a proposed order that identifies with specificity the relief sought on an issue-by-issue basis and (2) copies of any discovery requests and responses relating to the dispute. On the date set by court order, generally not less than forty-eight (48) hours prior to the conference, any party opposing the application for relief may file a letter not to exceed three (3) pages in 12-point font outlining that party's reason for its opposition. (iv) Should the Court find further briefing necessary upon conclusion of the conference, the Court will order it. Alternatively, the Court may choose to resolve the dispute prior to the conference and will, in that event, cancel the conference.

Any discovery motion filed without first complying with the following procedures will be denied without prejudice to renew pursuant to these procedures.