Motion Requirements a. Discovery Motions The Court believes that parties can and should work out most discovery disputes and thus discourages the filing of discovery motions. The Court will not hear or consider any discovery motions unless the parties have complied with the meet and confer requirement under Local Rule 37.2 . Any discovery motion must state with specificity when and how the movant complied with Local Rule 37.2 . In addition, the motion must briefly summarize the substance of the parties' discussions. Parties are reminded that compliance with Local Rule 37.2 requires a good faith effort to resolve discovery disputes and, other than in exceptional circumstances, timely communication that takes place face to face or by telephone conference is required. The mere exchange of correspondence will not normally be sufficient to comply with Local Rule 37.2 . All parties must be fully prepared to orally argue any discovery motion on the date that it is scheduled to be heard. The Court most often will decide most discovery motions after oral argument at the motion call and without briefing. If after argument the Court believes that the motion requires briefing, the Court normally will set an expedited briefing schedule so that the matter can be resolved promptly. All discovery disputes should be brought to the Court's attention well before the relevant discovery deadline passes. The parties may not raise a discovery dispute with the Court after the discovery deadline unless they meet the relevant legal standard necessary to extend the schedule. If the parties informally agree to conduct discovery after the discovery deadline but do not move for an extension, any discovery disputes raised after the expiration of the deadline will be deemed waived.