If an interrogatory is objectionable only in part, we will answer the unobjectionable portion. We will make every reasonable effort to resolve the issue before setting a motion for hearing. We will not force opposing counsel to make motions we do not intend to oppose unless circumstances require or the client requires. After a hearing, we will make a good faith effort to quickly agree or disagree upon a proposed order and submit the result to the court. Unless otherwise instructed by the court, or agreed to by counsel, all proposed orders shall be provided to other counsel for approval or comment prior to submission to the court.
Courts prefer to know that the order is either agreed upon or opposed.
We will not use post-hearing submissions of proposed orders as a guise to reargue the merits of the matter. We will avoid ex parte communications on the substance of a pending case with a judge before whom the case is pending. If an ex parte application or communication is permitted, we will make diligent efforts to notify the opposing party or a lawyer known or likely to represent the opposing party before making the application or communication. We will make reasonable efforts to accommodate the schedule of the lawyer so that the opposing party will be represented. We will make the application or communication only if there is a bona fide emergency whereby the client will be seriously prejudiced by a failure to make the application or communication on regular notice.