Bankruptcy Local Rule 7037.1
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(a)  Obligation to confer.

The Court will not consider a motion made pursuant to Fed. R. Bankr. P. 7026 to 7037 or Fed. R. Bankr. P. 9016 unless, prior to the filing of the motion the parties have conferred and attempted to resolve their differences in good faith.  The mere sending of a written, electronic, or voicemail communication does not satisfy this requirement.  Rather, this requirement can be satisfied only through direct dialogue and discussion in person or in a telephone conversation.

(b)  Certificate of compliance.

Counsel for the moving party shall include in the motion a certificate of compliance with this Rule. The certificate of compliance shall indicate that the parties have conferred  in good faith and shall set forth sufficient facts in the motion to allow the court to evaluate the adequacy of the compliance with this Rule.

(c)  Certificate of non-compliance.

In the event that the parties were unable to meet and confer as described in section (a) above, counsel for the moving party shall include in the motion a certificate setting forth sufficient facts to demonstrate that attempts to comply with this rule were made, and why the parties were unable to comply with this Rule.  The moving party shall set forth facts sufficient to allow the Court to evaluate the adequacy of the attempts to confer.

(d)  Failure to comply.

If counsel fails or refuses to comply with this Rule, the Court may deny any discovery motion and may order the payment of reasonable expenses, including attorneys’ fees.


Fed. R. Bankr. P. 7026-37, 9016