Credit to KarinCA for the research... 4. Motion

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4. Motions

A. Pre-Motion Submissions in Civil Cases. Pre-motion submissions
are required for motions to dismiss, motions for summary
judgment, motions for judgment on the pleadings, motions for
sanctions, and motions concerning discovery. Motions concerning
discovery are discussed in Section 3(C) above.

To request a pre-motion conference for motions to dismiss,
motions for summary judgment, motions for judgment on the
pleadings, and motions for sanctions, the putative moving party
shall file a letter, not to exceed three pages, describing the grounds
for the proposed motion, and whether the motion is on consent of
all parties. If the motion is not on consent, any opposing party
should file a letter setting forth its position, not to exceed three
pages, within three business days after the request is received.
The Court will then determine whether to hold a pre-motion
conference in the matter. A courtesy copy of each letter must also
be provided to Chambers via e-mail.

The submission of a pre-motion letter does not stay any future
deadlines, except that submission of a pre-motion letter
concerning a motion to dismiss will stay the defendant’s time to
answer or otherwise move with respect to the Complaint.

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