Case 1:16-cv-02690-AT Document 122 Filed 08/08/16 Page 1 of 36
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`IN THE UNITED STATES DISTRICT COURT
`FOR THE NORTHERN DISTRICT OF GEORGIA
`ATLANTA DIVISION
`
`
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`SIPCO, LLC, et al,
`
`
`Plaintiffs,
`
`
`v.
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`EMERSON ELECTRIC CO., et al,
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`
`
`
`
`
`CIVIL ACTION NO.
` 1:16-CV-2690-AT
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`
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`
`:
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`:
`:
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`STANDING ORDER:
`GUIDELINES TO PARTIES AND COUNSEL
`IN CASES PROCEEDING BEFORE
`THE HONORABLE AMY TOTENBERG
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`This case has been assigned to Judge Amy Totenberg. These guidelines are
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`Defendants.
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`
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`furnished to inform the parties and their counsel of the Court’s policies,
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`procedures, and practice, and to promote the just, speedy, and economical
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`disposition of cases. This order, in combination with the Local Rules of this
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`Court and the Federal Rules of Civil Procedure, shall govern this case. You are
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`required to sign and file a Certificate of Compliance in a format
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`consistent with the Certificate of Compliance attached hereto.
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`

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`Case 1:16-cv-02690-AT Document 122 Filed 08/08/16 Page 2 of 36
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`Table of Contents
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`I. General Matters ......................................................................................... 4
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`II. Case Administration ................................................................................... 4
`a. Contacting Chambers ............................................................................ 4
`b. Courtesy Copies of Documents................................................................5
`c. Attorneys .............................................................................................. 6
`i. Admission of Counsel Pro Hac Vice................................................... 6
`ii. Electronic Registration for All Counsel.............................................. 6
`iii. Leaves of Absence ..............................................................................7
`iv. Withdrawal or Substitution of Counsel...............................................7
`v. Corporate Representation ..................................................................7
`d. Pro Se Litigants ..................................................................................... 8
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`III. Case Management ..................................................................................... 11
`a. Motions for Temporary Restraining Orders or Preliminary Injunctive
`Relief ................................................................................................... 11
`b. Extensions of Time ............................................................................... 11
`c. Conferences.......................................................................................... 12
`d. Discovery ............................................................................................. 12
`i. General Principles of Discovery........................................................ 12
`ii. Discovery Responses: Boilerplate and General Objections ................ 14
`iii. Interrogatories ................................................................................ 15
`iv. Requests for Production or Inspection ............................................. 17
`v. Requests for Admission ................................................................... 18
`vi. Depositions ..................................................................................... 18
`e. Discovery Disputes .............................................................................. 20
`f.
`Confidentiality Agreements, Protective Orders, and Motions to Seal .....22
`i.
`Legal Standards Governing Public Access to Judicial Proceedings ....22
`ii. Procedure for Requesting the Court to Seal Information Designated as
`“Confidential” ..................................................................................24
`g. Electronic Filing of Exhibits and Attachments.......................................25
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`Case 1:16-cv-02690-AT Document 122 Filed 08/08/16 Page 3 of 36
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`h. Motions for Summary Judgment ..........................................................25
`i.
`Form of Statement of Material Facts & Response to Statement of Material
`Facts ................................................................................................... 26
`j. Amended Complaints and Motions to Dismiss ...................................... 27
`k. Requests for Oral Argument on Motions ............................................... 27
`l.
`Pretrial Conference............................................................................... 27
`m. Proposed Findings of Fact and Conclusions of Law .............................. 28
`n. Jury Trial ............................................................................................ 29
`o.
`Jury Charges ........................................................................................34
`p. Courtroom Technology .........................................................................34
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`Appendix: Certificate of Compliance
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`3
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`Case 1:16-cv-02690-AT Document 122 Filed 08/08/16 Page 4 of 36
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`I.
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`GENERAL MATTERS
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`Attorneys and pro se litigants appearing in this court in civil litigation must
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`observe three sets of rules:
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`1. The Federal Rules of Civil Procedure. These rules are available at
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`www.uscourts.gov/RulesAndPolicies/FederalRulemaking/Overview.aspx.
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`2. The local rules of this District Court and Instructions Regarding Pretrial
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`Proceedings. The local rules of this Court are available for downloading at
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`www.gand.uscourts.gov/local-rules. Various forms and the Court’s pretrial
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`instruction package are available at http://www.gand.uscourts.gov/rules-
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`standing-orders-forms.
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`3. The rules and practices of the district judge, and magistrate judge if
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`appropriate, assigned to your case.
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`II. CASE ADMINISTRATION
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`a.
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`Contacting Chambers
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`Amy Cash McConochie, the Courtroom Deputy Clerk, is your principal
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`point of contact on matters related to this case. Where possible, communications
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`with Ms. McConochie
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`should
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`be
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`via
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`email
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`(Amy McConochie@
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`gand.uscourts.gov) or telephone (404-215-1437).
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` Please note that Ms.
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`McConochie is often in the courtroom, so telephone messages may not be
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`returned for 24 hours. Any mail, couriered, or hand-delivered communications
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`should be addressed as follows:
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`Amy Cash McConochie
`Courtroom Deputy Clerk
`2388 United States Courthouse
`75 Ted Turner Drive, SW
`Atlanta, GA 30303-3309
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`Neither the parties nor their counsel should discuss the merits of the case with
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`Ms. McConochie or any of the Court’s law clerks.
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`b.
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`Courtesy Copies of Documents
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`Parties frequently forward copies of motions or other filings directly to
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`chambers for the Court’s convenience. Courtesy copies are not required except
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`for emergency motions filed pursuant to Local Rule 7.2B, NDGa, motions for
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`temporary restraining orders and/or preliminary injunctions, motions for
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`summary judgment, or motions with voluminous exhibits. Courtesy paper copies
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`of emergency motions, motions for temporary restraining orders, and/or motions
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`for preliminary injunctions should be hand-delivered to chambers in Room 2388
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`on the 23rd floor of the Richard B. Russell Federal Building located at 75 Ted
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`Turner Drive, SW. Courtesy paper copies of motions for summary judgments,
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`including all exhibits, or motions with voluminous exhibits, may be either hand-
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`delivered to chambers in Room 2388 or submitted via regular mail to attention of
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`the Courtroom Deputy Clerk at the above provided address. Courtesy copies of
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`motions and exhibits should be printed double-sided directly from the docket on
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`the CM/ECF system with the docket header across the top of the document so
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`that the case number, docket number, and page numbers appear on each page.
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`Courtesy copies should be assembled in a tabbed, indexed three-ring binder.
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`c.
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`Attorneys
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`i.
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`Admission of Counsel Pro Hac Vice
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`In the event that lead counsel had been admitted pro hac vice, local counsel
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`is required to be familiar with the case, and may be called upon to attend
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`hearings or participate in conferences on behalf of the lead counsel.
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`ii.
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`Electronic Registration for All Counsel
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`All counsel — including counsel admitted pro hac vice — must register and
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`participate
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`in
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`the Court’s
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`electronic
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`filing
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`system, CM/ECF
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`(Case
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`Management/Electronic Case Filing). Standing Order 04-01 states,
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`Effective July 15, 2005, absent good cause shown and the
`permission of the Court, attorneys in good standing admitted
`to practice before the Bar of this Court, to include attorneys
`admitted pro hac vice, will file, sign, and verify documents
`only by electronic means to the extent and in the manner
`authorized by this Standing Order, Local Rule 5.1 A. NDGa.,
`and the administrative procedures attached hereto as Exhibits
`A and B, Administrative Procedures for Filing, Signing, and
`Verifying Pleadings and Papers by Electronic Means in Civil
`and Criminal Cases in the United States District Court for the
`Northern District of Georgia (Administrative Procedures).
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`iii.
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`Leaves of Absence
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`Counsel are encouraged to review their calendars and submit as early as
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`possible any requests for leave of absence. Leave requests shall comply with
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`Local Rule 83.1, NDGa.
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`iv. Withdrawal or Substitution of Counsel
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`It is counsel’s responsibility to keep the Court informed of any change of its
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`status. Counsel should comply with Local Rule 83.1, NDGa, when substituting or
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`withdrawing as counsel. Counsel who do not comply with this Local Rule will not
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`be allowed to withdraw from the case until compliance is achieved.
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`v.
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`Corporate Representation
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`Corporate entities must be represented in court by an attorney. A
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`corporate officer may not represent the corporation unless that officer is also
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`licensed to practice law in the state of Georgia. Local Rule 83.1, NDGa, states:
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`a corporation may only be represented in court by an attorney,
`that a(n) attorney must sign all pleadings submitted to the
`court, and that a corporate officer may not represent the
`corporation in court unless that officer is also an attorney
`licensed to practice law in the state of Georgia, and that failure
`to comply with this rule could result in a default being entered
`against the corporate party.
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`Failure to comply with this rule can result in dismissal of a corporation’s
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`complaint or default being entered against the corporation.
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`d.
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`Pro Se Litigants
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`Parties proceeding pro se (without an attorney) are ADVISED that they
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`must comply with the Federal Rules of Civil Procedure (“Fed. R. Civ. P.”), as well
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`as the Local Rules of the United States District Court for the Northern District of
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`Georgia (“LR, NDGa.”). Pro se parties may obtain certain basic materials and
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`hand-outs from the Office of the Clerk of Court located on the 22nd Floor of the
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`United States Courthouse, 75 Ted Turner Drive, SW, Atlanta, Georgia. Many
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`documents are also available on the Court’s website at www.gand.uscourts.gov.
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`Pro se litigants may also utilize the law library located on the 23rd floor of the
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`United States Courthouse at the above provided address.
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`Counsel and parties representing themselves are prohibited from engaging
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`in ex parte communications with the Court or the Court’s staff. “Ex parte
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`communications” mean any form of contact with the Court outside the presence
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`of the opposing party or opposing party’s counsel. This includes, but is not
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`limited to, telephone calls, written correspondence, or in-person contact, by one
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`party or party’s counsel. If counsel or a pro se litigant seeks court action, the
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`appropriate procedure is to put the request in writing, in the form of a motion,
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`file the motion with the Clerk’s office and serve the opposing party or party’s
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`counsel. See Fed. R. Civ. P. 5; LR 5.1 and 5.2, NDGa.; see also LR 7.4, NDGa.
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`(“Communications to judges seeking a ruling or order, including an extension of
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`time, shall be by motion and not by letter. A letter seeking such action ordinarily
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`will not be treated as a motion. Counsel [and pro se litigants] shall not provide
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`the Court with copies of correspondence among themselves relating to matters in
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`dispute.”).
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`The Clerk of Court and the U.S. Marshals Service will not serve documents
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`filed by either party, unless expressly directed to do so by the Court. The Court
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`will only direct the Clerk or the U.S. Marshals Service to serve in the following
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`instances: (1) in the event a plaintiff is granted leave to proceed in forma
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`pauperis (without prepayment of fees), the Court will direct the Clerk to prepare
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`(and deliver to the U.S. Marshals Service if necessary) a service package
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`containing the case initiating document(s) or (2) in exceptional circumstances
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`under the Court’s discretion. The National Association of Professional Process
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`Servers provides a search engine for locating process servers across the nation at
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`its website (www.napps.org).
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`A pro se plaintiff is REQUIRED to provide the Clerk with an original of
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`any further pleadings or other papers filed with the Court after the complaint and
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`is further REQUIRED to SERVE upon the defendant(s) or counsel for the
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`defendant(s), 1 by mail or by hand delivery under Rule 5 of the Federal Rules of
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`Civil Procedure, a copy of every additional pleading or other paper described in
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`Rule 5 of the Federal Rules of Civil Procedure.
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`1 Once counsel for a defendant has appeared in the case, it is not necessary to serve the
`defendant individually; service on counsel is sufficient.
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`Each pleading or paper described in Rule 5, including pleadings, papers
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`related to discovery required to be served, motions, notices and similar papers,
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`shall include a certificate stating the date on which an accurate copy of that
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`pleading or document was mailed or hand-delivered to the defendant(s) or their
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`counsel. This Court shall disregard any papers submitted which have not been
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`properly filed with the Clerk, or which do not include a certificate of service. Pro
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`se parties are also ADVISED that, under Local Rule 7, NDGa, “PLEADINGS
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`ALLOWED; FORM OF MOTIONS,” if the deadline for a response to a motion
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`passes without a response being filed, the motion is treated as unopposed. See
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`LR 7.1B, NDGa. Furthermore, under Local Rule 56.1, NDGa, the failure by a
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`respondent to a motion for summary judgment to contest the movant’s statement
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`of material facts will be taken as an admission of those facts not objected to in
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`respondent’s statement.
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`Pro se parties are further REQUIRED to keep the Court advised of their
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`current address at all times during the pendency of the lawsuit. Local Rule
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`83.1D(3), NDGa provides that counsel and parties appearing pro se have, in all
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`cases, a duty to notify the Clerk’s Office by letter of any change in address and/or
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`telephone number. Per this rule, “a failure to keep the clerk’s office so informed
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`which causes a delay or otherwise adversely affects the management of a civil
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`case shall constitute grounds for dismissal without prejudice or entry of a
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`judgment by default.” Pro se parties are encouraged to provide the opposing
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`party/counsel with an email address for purposes of communicating regarding
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`the case and serving copies of pleadings filed and served via regular mail. If a pro
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`se party provides an email address, opposing counsel shall serve copies of all
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`pleadings via email and regular mail. Pro se parties are ADVISED, however,
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`that the Court serves via paper only and not via email.
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`III. CASE MANAGEMENT
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`a. Motions for Temporary Restraining Orders or Preliminary
`Injunctive Relief
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`The Court will not entertain granting a temporary restraining order or
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`preliminary injunctive relief absent a properly supported motion with attached
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`evidence pursuant to Fed. R. Civ. P. 65. See LR 7.1A(1), NDGa. If a party
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`requests such relief only in their complaint or other pleadings, but fails to file a
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`separate motion seeking the same, that request will not be considered until the
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`merits of the case are addressed.
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`b.
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`Extensions of Time
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`The Court, along with counsel for the parties, is responsible for processing
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`cases toward prompt and just resolutions. To that end, the Court seeks to set
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`reasonable but firm deadlines. Motions for extension, whether joint, unopposed,
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`or designated as consent, will not be granted as a matter of course. Parties
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`seeking an extension should explain with specificity the unanticipated or
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`unforeseen circumstances necessitating the extension and should set forth a
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`timetable for the completion of the tasks for which the extension is sought.
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`c.
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`Conferences
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`Scheduling, discovery, pre-trial, and settlement conferences promote the
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`speedy, just, and efficient resolution of cases. Therefore, the Court encourages
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`the parties to request a conference with the Court when counsel believes that a
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`conference will be helpful and counsel has specific goals and an agenda for the
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`conference. Conferences may be requested by contacting the Courtroom Deputy
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`Clerk via email or telephone.
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`d. Discovery
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`Initial disclosures should be as complete as possible based upon
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`information reasonably available. Responses may not be reserved for later
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`supplementation.
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`i.
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`General Principles of Discovery
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`Counsel and pro se litigants should be guided by courtesy, candor and
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`common sense, and should conform to the Federal Rules of Civil Procedure, the
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`Local Rules and applicable orders in conducting discovery. In particular, counsel
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`and pro se litigants should have in mind the restrictions on the scope of discovery
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`stated in Fed. R. Civ. P. 26(b) and the good faith obligations implicit in Rule
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`26(g). Direct and informal communication between counsel is encouraged to
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`facilitate discovery and resolve disputes. In this regard, the Court refers counsel
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`and parties to the guidance offered by the district court for the Central District of
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`California in O’Connor v. Boeing North American, Inc., 185 F.R.D. 272, 284
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`(C.D. Cal. 1999) (citations omitted):
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`The Court would like to take this opportunity to address the
`parties and their counsel, to stress that “[t]he discovery system
`depends absolutely on good faith and common sense from
`counsel. The courts, sorely pressed by demands to try cases
`promptly and to rule thoughtfully on potentially case
`dispositive motions, simply do not have the resources to police
`closely the operation of the discovery process. The whole
`system of [c]ivil adjudication would be ground to a virtual halt
`if the courts were forced to intervene in even a modest
`percentage of discovery transactions. That fact should impose
`on counsel an acute sense of responsibility about how they
`handle discovery matters. They
`should
`strive
`to be
`cooperative, practical and sensible, and should turn to the
`courts (or take positions that force others to turn to the courts)
`only in extraordinary situations that implicate truly significant
`interests.”
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`All discovery must be served early enough so that the responses thereto are
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`due on or before the last day of the discovery period. Requests for extension of
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`the discovery period or deadlines within the discovery period must be made in
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`accordance with Local Rule 26.2B, NDGa. All requests for extensions of the
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`discovery period must be made via motion and must state: (1) the original (and if
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`applicable, current) date from which the extension is being sought; (2) the
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`number of previous requests for extensions, if any; (3) whether these previous
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`requests were granted or denied; and (4) whether the adversary consents, and if
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`not, the reasons given by the adversary for refusing to consent. An agreed upon
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`or consent motion to extend the discovery period or deadlines therein should be
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`clearly designated as a consent motion. Motions must be filed prior to the
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`expiration of the existing discovery period. The Court will not enforce the private
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`agreements between the parties and/or their counsel to conduct discovery
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`beyond conclusion of the discovery period.
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`The Court does not allow evidence at trial which was requested and not
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`revealed during the discovery period.
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`ii.
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`Discovery Responses: Boilerplate and General Objections
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`Boilerplate objections in response to discovery requests are strictly
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`prohibited. Parties should not carelessly invoke the usual litany of rote
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`objections, i.e., attorney-client privilege, work-product immunity from discovery,
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`overly broad/unduly burdensome, irrelevant, not reasonably calculated to lead to
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`the discovery of admissible evidence.
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`Moreover, general objections are prohibited, i.e., a party shall not include
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`in his response to a discovery request a “Preamble” or a “General Objections”
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`section stating that the party objects to the discovery request “to the extent that”
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`it violates some rule pertaining to discovery, e.g., the attorney-client privilege, the
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`work product immunity from discovery, the requirement that discovery requests
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`be reasonably calculated to lead to the discovery of admissible evidence, and the
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`prohibition against discovery requests that are vague, ambiguous, overly broad,
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`or unduly burdensome. Instead, each individual discovery request must be met
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`with every specific objection thereto – but only those objections that actually
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`apply to that particular request. Otherwise, it is impossible for the Court or the
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`party upon whom the discovery response is served to know exactly what
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`objections have been asserted to each individual request. All such general
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`objections shall be disregarded by the Court.
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`Finally, a party who objects to a discovery request but then responds to the
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`request must indicate whether the response is complete, i.e., whether additional
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`information or documents would have been provided but for the objection(s).
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`For example, in response to an interrogatory, a party is not permitted to raise
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`objections and then state, “Subject to these objections and without waiving them,
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`the response is as follows . . .” unless the party expressly indicates whether
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`additional information would have been included in the response but for the
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`objection(s).
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`iii.
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`Interrogatories
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`Whenever possible, counsel should try to exchange information informally.
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`The results of such exchanges, to the extent relevant, may then be made of record
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`by requests for admission.
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`The parties are expected to observe the limitations regarding the number
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`and scope of interrogatories as stated in Fed. R. Civ. P. 26(b) and 33. Counsel’s
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`or a pro se litigant’s signature on the interrogatories constitutes a certification of
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`compliance with
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`those
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`limitations.
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`
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`Interrogatories
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`should be brief,
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`straightforward, neutral, particularized, and capable of being understood by
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`jurors when read in conjunction with the answer. Ordinarily, they should be
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`limited to requesting objective facts, such as, the identification of persons or
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`documents, dates, places,
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`transactions, and amounts.
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` Argumentative
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`interrogatories,
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`attempts
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`to
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`cross-examine,
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`and multiple
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`repetitive
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`interrogatories are objectionable.
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`Fed. R. Civ. P. 33(b) requires the respondent to provide separate written
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`answers to each interrogatory unless it is objected to. If an objection is made, the
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`reason(s) for the objection shall be stated and the interrogatory is to be answered
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`to the extent it is not objectionable. When in doubt about the meaning of an
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`interrogatory, give it a reasonable interpretation (which may be specified in the
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`response) and answer it so as to provide rather than deny information.
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`Generally, the responding party is required to produce information only in the
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`form in which it is maintained or is available. If an answer is made by reference
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`to a document, attach it or identify it and make it available for inspection. (See
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`No. 9 below). Generalized cross-references, such as to a deposition, are not an
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`acceptable answer.
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`The parties are directed to consult Rules 26(b) and 33(b)-(d) about the
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`permissible scope of discovery and objections. Counsel’s or a pro se litigant’s
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`signature on the answer constitutes a certification of compliance with the
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`requirements of Fed. R. Civ. P. 26(g).
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`If an objection is based on privilege, the claim of privilege must be
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`supported by a statement of particulars sufficient to enable the Court to assess its
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`validity. In the case of a document, such a statement should specify the privilege
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`relied on and include the date, title, description, subject, and purpose of the
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`document; the name and position of the author; and the addresses of other
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`recipients. In the case of a communication, the statement should include the
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`privilege relied on; the date, place, subject, and purpose of the communication;
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`and the names and positions of all persons present. See Fed. R. Civ. P. 26(b)(5).
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`iv.
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`Requests for Production or Inspection
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`Please consult Fed. R. Civ. P. 26(b) and 34 about the permissible scope of
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`discovery and objections. To the extent possible, requests should specify with
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`particularity the title and description of documents or records requested.
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`(Information needed for specification can often be obtained by informal
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`discovery or by deposition or by interrogatories, if necessary.) The certification
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`requirement of Fed. R. Civ. P. 26(g) applies.
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`When responding to requests, materials (including electronically stored
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`information), should be produced in accordance with Fed. R. Civ. P. 34(b)(2)(E).
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`Documents should be produced either with labels corresponding to the categories
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`in the specific requests to which they respond or in the manner in which they are
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`kept in the usual course of business. Opening a warehouse for inspection by the
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`requesting party, burying the responsive documents in a mass of materials, and
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`Case 1:16-cv-02690-AT Document 122 Filed 08/08/16 Page 18 of 36
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`similar procedures do not meet the good faith requirements of the rules. The
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`certification procedure of Fed. R. Civ. P. 26(g) is applicable.
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`v.
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`Requests for Admission
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`Requests for admission are an economical and efficient means of making a
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`record of informal exchanges of information, stipulations, and matters subject to
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`judicial notice, and of narrowing issues. Each request should be brief, clear,
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`simple, addressed to a single point and stated in neutral, non-argumentative
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`words. Requests ordinarily should deal with only objective facts. They may be
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`combined with interrogatories to ask for the factual basis of a claim or a denial.
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`The attorney’s or pro se litigant’s signature certifies compliance with Fed. R. Civ.
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`P. 26(g). Fed. R. Civ. P. 36(a)(4) requires that a response shall specifically deny a
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`matter or set forth in detail the reasons why the party cannot admit or deny. A
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`denial shall fairly meet the substance of the request, and when good faith
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`requires, a party shall specify so much as is true and qualify or deny the
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`remainder. The responding party has a duty to make reasonable inquiry before
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`responding. The certification requirement of Fed. R. Civ. P. 26(g) applies.
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`vi.
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`Depositions
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`Barring extraordinary circumstances, opposing counsel and pro se litigants
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`should be consulted, and the convenience of counsel, witnesses, and the parties
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`accommodated, before a deposition is noticed. Concurrent depositions are not
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`permitted in the absence of stipulation or order.
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`When counsel enter (or a party enters) into stipulations at the beginning of
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`a deposition, the terms of the stipulation should be fully stated on the record of
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`the deposition.
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`Questions should be brief, clear, and simple. A deposition should not be
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`used to harass or intimidate a witness. Normally, except in the case of
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`impeachment, a witness should be shown a document before being questioned
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`about it.
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`Under Fed. R. Civ. P. 30(c)(2), objections to the manner of taking the
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`deposition, to the evidence, or to the conduct of a party shall be noted on the
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`record but the evidence objected to shall be taken subject to the objection. In the
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`absence of a good faith claim of privilege, instructions not to answer are rarely
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`justified and may lead to sanctions under Fed. R. Civ. P. 37. Speaking objections
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`and other tactics for coaching a witness during the deposition are not
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`permissible. If counsel or a pro se litigant believes that a motion to terminate or
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`limit the examination under Fed. R. Civ. P. 30(d) would be warranted, counsel
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`and/or the pro se litigant should promptly initiate a conference call to the Court
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`with opposing counsel for a pre-motion conference to attempt to resolve the
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`problem.
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`Fed. R. Civ. P. 26(b)(4) should be consulted regarding expert disclosures.
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`Experts who are prospective witnesses are normally produced for deposition by
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`the opposing party as a matter of course.
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`The parties are expected to observe the limitations on depositions specified
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`in Fed. R. Civ. P. 26(b) and 30 and, in particular, to avoid unnecessary
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`depositions.
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`e. Discovery Disputes
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`The parties shall not file discovery motions (including motions to compel,
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`motions for protective order, and motions for sanctions) without prior
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`permission from the Court. These disputes are often resolved in a conference
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`with the Court, thus avoiding a delay of discovery. In the event a discovery
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`dispute arises, the parties are required to meet and confer in an effort to resolve
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`the dispute. Counsel or pro se litigants are required to confer, by telephone or in
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`person, in good faith before bringing a discovery dispute to the Court. See Fed. R.
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`Civ. P. 26(c) and 37(a)(1); LR 37.1A, NDGa. The duty to confer is NOT satisfied
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`by sending a written document, such as a letter, email, or fax, to the adversary,
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`UNLESS repeated attempts to confer by telephone or in person are unsuccessful
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`due to the conduct of the adversary.
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`If the dispute cannot be resolved, the parties shall file a Consolidated/Joint
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`Discovery Statement outlining their positions on each of the discovery items in
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`dispute. The consolidated submission is not to exceed 6 pages if there are 4 or
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`less issues. For 5-10 issues, the statement should not exceed 10 pages, and if
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`there are more than 10 issues, the statement should not exceed 12 pages. The
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`statement should be formatted in a logical order, i.e., identify each issue in
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`dispute followed by a discussion from each of the parties setting forth an
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`explanation of its respective position on the issue as follows:
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`Identify Discovery Issue #1
`A. Party A’s Position
`B. Party B’s Response
`C. Party A’s Reply
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`I.
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`II.
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`The parties are required to attach as an exhibit to the Consolidated
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`Identify Discovery Issue #2
`A. Party A’s Position
`B. Party B’s Response
`C. Party A’s Reply
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`Statement an excerpt of the relevant discovery requests including only the
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`language of the specific requests and, potentiall