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Court Rules
Judge Alicia Garcia Priovolos
Judge

Judge Alicia Garcia Priovolos

Individual Rules, Standing Orders & Policies

Eleventh Judicial Circuit of Florida, Miami-Dade County

Limits & Logistics

Courtesy Copies

Motion

  • 1 copy • Email • With Hearing Request

Communication

Email

Chambers

palopez@jud11.flcourts.org
Scheduling
Email

Chambers

apuente@jud11.flcourts.org
Email

Chambers

apriovolos@jud11.flcourts.org
Phone

Chambers

(305) 349-5674
Scheduling
Filters:

Document Format Requirements4 rules

FormattingImportant

The e-mail should also include the motion seeking to be heard and a proposed Order, in Microsoft Word format.

File type
Word
Applies to
  • Proposed order
Miami Dade:e638279418784363af6540a0
|SectionTo request a hearing date: email Judicial Assistant Paula Lopez
FormattingImportant

The e-mail should also include the motion seeking to be heard and a proposed Order, in Microsoft Word format.

File type
Word
Applies to
  • Proposed order
Miami Dade:97b5b8be0e4fb8c20cd6d89e
|SectionTo request a hearing date
FormattingImportantCriminal cases

attach the Motion and a proposed Order, in Microsoft Word format.

File type
Word
Applies to
  • Motion
  • Proposed order
21662460340-Standing Order Criminal Court · p. 4
|SectionNON-EVIDENTIARY MOTION CALENDAR (WEDNESDAYS @ 10:00 AM)
FormattingImportant

The e-mail should also include the motion seeking to be heard and a proposed Order, in Microsoft Word format.

File type
Word
Applies to
  • Proposed order
Miami Dade:a8f7c399cc4552e06fe78a37
|SectionWEDNESDAYS - MOTION CALENDAR

Document Filing Requirements9 rules

Filing RequirementsMandatory

The e-mail should also include the motion seeking to be heard and a proposed Order, in Microsoft Word format.

Document
Hearing request email

Should include

  • Proposed order
Miami Dade:e638279418784363af6540a0
|SectionTo request a hearing date: email Judicial Assistant Paula Lopez
Filing RequirementsMandatory

The e-mail should also include the motion seeking to be heard and a proposed Order, in Microsoft Word format.

Document
Hearing request email

Should include

  • Proposed order
Miami Dade:97b5b8be0e4fb8c20cd6d89e
|SectionTo request a hearing date
Filing RequirementsMandatoryCriminal cases

If counsel is accepting a plea in abstentia, there must be an affidavit in the court file authorizing counsel to accept the plea on behalf of the defendant. The affidavit must also address all subsections found in Rule 3.172 of the Florida Rules of Criminal Procedure.

Filing RequirementsMandatoryCriminal cases

Please copy opposing counsel on the email and attach the Motion and a proposed Order, in Microsoft Word format.

Document
Non-evidentiary hearing request email

Include

  • Proposed order
21662460340-Standing Order Criminal Court · p. 4
|SectionNON-EVIDENTIARY MOTION CALENDAR (WEDNESDAYS @ 10:00 AM)
Filing RequirementsMandatoryCriminal cases

Please also include the following information on the request: 1. three potential hearing dates, 2. whether the defendant is in custody, 3. how many witnesses will be called, and 4. how much time you are requesting the court to reserve for the motion.

21662460340-Standing Order Criminal Court · p. 4
|SectionEVIDENTIARY MOTION CALENDAR (WEDNESDAYS @ 10:30 AM and 2:00 PM)
Filing RequirementsMandatoryCriminal cases

If a party has case law they are relying on for the motion, the case law must be cited in the motion and/or in the response.

Filing RequirementsMandatoryCriminal cases

Motions for Return of Property must be in writing and the moving party must provide the agency holding the property with notice of the hearing date.

21662460340-Standing Order Criminal Court · p. 5
|SectionCONTESTED MOTIONS FOR RETURN OF PROPERTY
Filing RequirementsMandatoryCriminal cases

Motions to compel discovery shall be in writing and will be heard at sounding calendar. A written motion to compel shall include: 1. The discovery sought with specificity. 2. The date upon which the discovery was propounded and due. 3. The dates the moving party has conferred, or attempted to confer, with the party failing to provide the discovery sought. 4. Any reasons, responses and/or failures to respond by the party failing to provide the discovery. 5. The moving party shall also certify that counsel has attempted in good faith to resolve the issues with opposing counsel on a minimum of two occasions, prior to the motion to compel being filed, and has been unable to reach a resolution. 6. Finally, the motion should also describe a movant's independent efforts (if any) to obtain the discovery sought prior to seeking court action.

21662460340-Standing Order Criminal Court · p. 5
|SectionDISCOVERY MOTIONS & MOTIONS TO COMPEL
Filing RequirementsMandatory

The e-mail should also include the motion seeking to be heard and a proposed Order, in Microsoft Word format.

Document
Hearing request email

Should include

  • Proposed order
Miami Dade:a8f7c399cc4552e06fe78a37
|SectionWEDNESDAYS - MOTION CALENDAR

Filing & Service rules

Electronic Filing Rules

Before requesting a hearing, the motion must be filed with the Clerk of Court.

Make sure the motion has been filed with the Clerk of Court and all parties are included on the electronic mail correspondence.

Page 1 | For scheduling: Please email the Judicial Assistant, Paula Lopez

E-filing a motion does not deliver a copy to the court, even if the court's email address is added to the e-filing service, so the motion must be emailed separately to the Judicial Assistant.

Please note e-filing motions will not provide the court with a copy, even if you add the court's email address in the e-filing service.

Page 1 | To request a hearing date

E-filing a motion does not deliver a copy to the court, even when the court's email address is added in the e-filing service, so the motion must be emailed to the Judicial Assistant.

Please note e-filing motions will not provide the court with a copy, even if you add the court’s email address in the e-filing service.

Page 1 | To request a hearing date: email Judicial Assistant Paula Lopez

E-filing a motion does not provide the court with a copy, even if the court's email address is added in the e-filing service, so a separate email to chambers is required.

Please note e-filing motions will not provide the court with a copy, even if you add the court's email address in the e-filing service.

Criminal cases

Page 5 | ALL MOTIONS MUST BE E-MAILED TO CHAMBERS

Filing Timing and Cure Windows

Hearing requests must be received by noon on Friday to be placed on the following Wednesday's calendar.

All hearing requests must be received no later than noon on Friday for them to make the following Wednesday's calendar.

Criminal cases

Page 4 | NON-EVIDENTIARY MOTION CALENDAR (WEDNESDAYS @ 10:00 AM)

Court staff will notify parties by end of day Monday whether a motion will be heard that week or the following week.

Court staff will notify you no later than by the end of day on Monday if your motion will be heard that week or the following.

Criminal cases

Page 4 | NON-EVIDENTIARY MOTION CALENDAR (WEDNESDAYS @ 10:00 AM)

Court staff will notify parties when an evidentiary motion will be heard based on urgency and availability.

Depending on the urgency of the motion and availability, court staff will notify the parties when the motion will be heard.

Criminal cases

Page 4 | EVIDENTIARY MOTION CALENDAR (WEDNESDAYS @ 10:30 AM and 2:00 PM)

Service and Proof of Service Rules

Hearing request emails must copy opposing counsel.

To request a hearing date: email Judicial Assistant Paula Lopez palopez@jud11.flcourts.org and copy opposing counsel.

Page 1 | To request a hearing date: email Judicial Assistant Paula Lopez

All parties must be included on the email correspondence when requesting a hearing.

Make sure the motion has been filed with the Clerk of Court and all parties are included on the electronic mail correspondence.

Page 1 | For scheduling: Please email the Judicial Assistant, Paula Lopez

The moving party on a motion for return of property must provide the agency holding the property with notice of the hearing date.

Motions for Return of Property must be in writing and the moving party must provide the agency holding the property with notice of the hearing date.

Criminal cases

Page 5 | CONTESTED MOTIONS FOR RETURN OF PROPERTY

E-filing a motion does not deliver a copy to the court, even if the court's email address is added to the e-filing service, so a separate email to the Judicial Assistant is required.

Please note e-filing motions will not provide the court with a copy, even if you add the court's email address in the e-filing service.

Page 1 | WEDNESDAYS - MOTION CALENDAR

Motions to compel should be filed and served within a reasonable time before hearing, to permit opposing counsel an opportunity to prepare for the hearing and/or obtain the discovery being requested.

Motions to compel should be filed and served within a reasonable time before hearing, to permit opposing counsel an opportunity to prepare for the hearing and/or obtain the discovery being requested.

Criminal cases

Page 5 | DISCOVERY MOTIONS & MOTIONS TO COMPEL

Courtesy Copy Requirements

When requesting a hearing, a copy of the motion and proposed order must be emailed to the Judicial Assistant because e-filing does not provide the court with a copy.

To request a hearing date: email Judicial Assistant Paula Lopez palopez@jud11.flcourts.org and copy opposing counsel. The e-mail should also include the motion seeking to be heard and a proposed Order, in Microsoft Word format. Please note e-filing motions will not provide the court with a copy, even if you add the court’s email address in the e-filing service.

Page 1 | To request a hearing date: email Judicial Assistant Paula Lopez

Pre-Motion Conference Requirements

Parties must make a good faith effort to coordinate a hearing date with opposing counsel before requesting a non-evidentiary hearing.

The requesting party must make a good faith effort to coordinate a hearing date with the opposing party, prior to requesting the hearing.

Criminal cases

Page 4 | NON-EVIDENTIARY MOTION CALENDAR (WEDNESDAYS @ 10:00 AM)

Parties must make a good faith effort to coordinate a hearing date with opposing counsel before requesting an evidentiary hearing (motions requiring more than 5 minutes or any evidence).

To request a hearing on a motion that will require more than 5 minutes or which will require the court to consider any form of evidence, including sworn testimony, the requesting party must make a good faith effort to coordinate a hearing date with the opposing party, prior to requesting the hearing.

Criminal cases

Page 4 | EVIDENTIARY MOTION CALENDAR (WEDNESDAYS @ 10:30 AM and 2:00 PM)

Adjournment & Extension Requirements

Motions for continuance may be made orally (ore tenus) or in writing at sounding calendar.

Motions for Continuance may be made ore tenus or in writing at sounding calendar.

Criminal cases

Page 4 | CONTINUANCES

Chambers Communication Rules

To request a hearing date, counsel must email Judicial Assistant Paula Lopez, copy opposing counsel, and include the motion to be heard and a proposed order in Microsoft Word format.

To request a hearing date: email Judicial Assistant Paula Lopez palopez@jud11.flcourts.org and copy opposing counsel. The e-mail should also include the motion seeking to be heard and a proposed Order, in Microsoft Word format.

Page 1 | To request a hearing date: email Judicial Assistant Paula Lopez

Hearing scheduling requests must be emailed to Judicial Assistant Paula Lopez together with the Request for Hearing and a copy of the motion.

For scheduling: Please email the Judicial Assistant, Paula Lopez at palopez@jud11.flcourts.org, with the Request for Hearing and a copy of the motion.

Page 1 | For scheduling: Please email the Judicial Assistant, Paula Lopez

Hearing scheduling requests must be emailed to Judicial Assistant Paula Lopez with the Request for Hearing and a copy of the motion, which must already be filed with the Clerk, and all parties must be included on the email.

For scheduling: Please email the Judicial Assistant, Paula Lopez at palopez@jud11.flcourts.org, with the Request for Hearing and a copy of the motion. Make sure the motion has been filed with the Clerk of Court and all parties are included on the electronic mail correspondence.

Page 1 | For scheduling: Please email the Judicial Assistant, Paula Lopez

Hearing date requests must be emailed to Judicial Assistant Paula Lopez with opposing counsel copied, and the email must include the motion to be heard and a proposed Order in Microsoft Word format.

To request a hearing date: email Judicial Assistant Paula Lopez palopez@jud11.flcourts.org and copy opposing counsel. The e-mail should also include the motion seeking to be heard and a proposed Order, in Microsoft Word format.

Page 1 | To request a hearing date

Judge's name & e-mail: Judge Alicia Garcia Priovolos, apriovolos@jud11.flcourts.org Please copy the Judicial Assistant on emails regarding court business, as well as opposing counsel.

Judge's name & e-mail: Judge Alicia Garcia Priovolos, apriovolos@jud11.flcourts.org Please copy the Judicial Assistant on emails regarding court business, as well as opposing counsel.

Criminal cases

Page 1 | GENERAL

Evidentiary hearing requests must be emailed to the Judicial Assistant at palopez@jud11.flcourts.org, copying opposing counsel and attaching the written motion.

The requesting party shall then email Judicial Assistant Paula Lopez palopez@jud11.flcourts.org and request a hearing date, copying opposing counsel and attaching the written motion.

Criminal cases

Page 4 | EVIDENTIARY MOTION CALENDAR (WEDNESDAYS @ 10:30 AM and 2:00 PM)

Non-evidentiary hearings of five minutes or less must be requested by emailing the Judicial Assistant at palopez@jud11.flcourts.org with opposing counsel copied.

To request a non-evidentiary hearing that can be heard in five minutes or less, please email Judicial Assistant Paula Lopez palopez@jud11.flcourts.org. Please copy opposing counsel on the email and attach the Motion and a proposed Order, in Microsoft Word format.

Criminal cases

Page 4 | NON-EVIDENTIARY MOTION CALENDAR (WEDNESDAYS @ 10:00 AM)

All motions must be e-mailed to chambers because e-filing does not deliver a copy to the court, even if the court's email address is added to the e-filing service.

ALL MOTIONS MUST BE E-MAILED TO CHAMBERS Please note e-filing motions will not provide the court with a copy, even if you add the court's email address in the e-filing service.

Criminal cases

Page 5 | ALL MOTIONS MUST BE E-MAILED TO CHAMBERS

Hearing requests in the Unified Family Court must be made by emailing Judicial Assistant Paula Lopez with the request for hearing and a copy of the motion, only after the motion has been filed with the Clerk and with all parties included on the email.

For scheduling: Please email the Judicial Assistant, Paula Lopez at palopez@jud11.flcourts.org, with the Request for Hearing and a copy of the motion. Make sure the motion has been filed with the Clerk of Court and all parties are included on the electronic mail correspondence.

Page 1 | Division: Circuit Unified Family Court - Scheduling and Zoom Instructions

Criminal hearing date requests must be made by emailing Judicial Assistant Paula Lopez with opposing counsel copied, attaching the motion to be heard and a proposed Order in Microsoft Word format.

To request a hearing date: email Judicial Assistant Paula Lopez palopez@jud11.flcourts.org and copy opposing counsel. The e-mail should also include the motion seeking to be heard and a proposed Order, in Microsoft Word format.

Page 1 | WEDNESDAYS - MOTION CALENDAR

For hearings set for Zoom appearance, parties must contact the Judicial Assistant by phone to obtain the Zoom Meeting ID.

Division Zoom Instructions: If a hearing is set for Zoom appearance, please contact the Judicial Assistant at the phone number listed on this page for the Zoom Meeting ID.

Page 1 | Division Zoom Instructions

For hearings set for Zoom appearance, parties must contact the Judicial Assistant by phone to obtain the Zoom Meeting ID.

Division Zoom Instructions: If a hearing is set for Zoom appearance, please contact the Judicial Assistant at the phone number listed on this page for the Zoom Meeting ID.

Page 1 | Division: Circuit Unified Family Court - Scheduling and Zoom Instructions

For hearings set for Zoom appearance, parties must contact the Judicial Assistant by phone to obtain the Zoom Meeting ID.

Division Zoom Instructions: If a hearing is set for Zoom appearance, please contact the Judicial Assistant at the phone number listed on this page for the Zoom Meeting ID.

Page 1 | Division Zoom Instructions

Chambers is located at the Lawson E. Thomas Courthouse, 175 N.W. 1st Avenue, 2920, Miami, FL 33128, and can be reached by telephone at (305) 349-5674.

Chambers address: Lawson E. Thomas Courthouse, 175 N.W. 1st Avenue, 2920, Miami, FL 33128. Chambers telephone number: (305) 349-5674.

Criminal cases

Page 1 | GENERAL

The Judicial Assistant is Paula Lopez and she can be reached at palopez@jud11.flcourts.org.

Judicial Assistant's name & email: Paula Lopez, palopez@jud11.flcourts.org

Criminal cases

Page 1 | GENERAL

The bailiff is Alvaro Puente and he can be reached at apuente@jud11.flcourts.org.

Bailiff's name: Alvaro Puente, apuente@jud11.flcourts.org

Criminal cases

Page 1 | GENERAL

Criminal cases in division 89 are not heard on Thursdays or Fridays, but court staff is available to assist with scheduling matters in an emergency.

THURSDAYS AND FRIDAYS, this court conducts civil proceedings. Criminal cases are not heard for division 89 during these days. If an emergency arises, this court's staff is available to assist with scheduling matters.

Criminal cases

Page 2 | COURT: IN PERSON vs. ZOOM

Court-wide rules

Applies court-wide

These 7 rules apply across Eleventh Judicial Circuit of Florida, Miami-Dade County. Where this judge's own standing orders above address the same topic, the judge's requirement controls.

Filing Requirements

All 6
  • Applies to
    Pleadings and papers

    At the time of filing, pro se parties must have their pleadings and papers reviewed as to form by the Family Court Self Help Program, unless waived for good cause by the Administrative or Associate Administrative Judge.

  • Applies to
    Waiver request

    A waiver request under this Local Rule is treated as an emergency ex parte motion pursuant to Rule 12.741(b)(1), Family Law Rules of Procedure, and must be disposed of expeditiously.

  • Applies to
    Final hearing date

    All pro se parties must obtain a final hearing date from the Family Court Self Help Program, unless waived for good cause by the Administrative or Associate Administrative Judge.

Fees

All 1
  • Fee
    $35
    Applies to
    Forms packet

    The required forms packet is available from the Clerk's Office at a cost not to exceed $35.00, subject to good-cause waiver of the procedures by the Administrative or Associate Administrative Judge.

About Judge Alicia Garcia Priovolos

Alicia Garcia Priovolos is a judge on the Eleventh Judicial Circuit of Florida, which serves Miami-Dade County through its circuit and county court divisions.

This judge's published procedures include a standing order for criminal court.

Common questions about Judge Alicia Garcia Priovolos's rules

Are courtesy copies required for Judge Alicia Garcia Priovolos?

Courtesy-copy rule applies for motions. Details: 1 copy, delivery with hearing request, by email. When requesting a hearing, a copy of the motion and proposed order must be emailed to the Judicial Assistant because e-filing does not provide the court with a copy.

View ruleSource: page 1, section To request a hearing date: email Judicial Assistant Paula Lopez

Does Judge Alicia Garcia Priovolos require a pre-motion conference or letter before filing a motion?

Parties must make a good faith effort to coordinate a hearing date with opposing counsel before requesting a non-evidentiary hearing.

View ruleSource: page 4, section NON-EVIDENTIARY MOTION CALENDAR (WEDNESDAYS @ 10:00 AM)

What formatting rules apply to filings before Judge Alicia Garcia Priovolos?

Judge Alicia Garcia Priovolos' formatting rule includes file format docx. The e-mail should also include the motion seeking to be heard and a proposed Order, in Microsoft Word format.

View ruleSource: page 1, section To request a hearing date: email Judicial Assistant Paula Lopez

What must be included with hearing request email filings before Judge Alicia Garcia Priovolos?

The rule requires proposed order. The e-mail should also include the motion seeking to be heard and a proposed Order, in Microsoft Word format.

View ruleSource: page 1, section To request a hearing date: email Judicial Assistant Paula Lopez

What must be included with plea in abstentia affidavit filings before Judge Alicia Garcia Priovolos?

Counsel accepting a plea in abstentia must ensure an affidavit is in the court file authorizing counsel to accept the plea and addressing all Rule 3.172 subsections.

View ruleSource: page 3, section PLEAS

How may parties contact Judge Alicia Garcia Priovolos' chambers?

The rule lists email palopez@jud11.flcourts.org. Hearing scheduling requests must be emailed to Judicial Assistant Paula Lopez together with the Request for Hearing and a copy of the motion.

View ruleSource: page 1, section For scheduling: Please email the Judicial Assistant, Paula Lopez

How do I request an adjournment or extension before Judge Alicia Garcia Priovolos?

Motions for continuance may be made orally (ore tenus) or in writing at sounding calendar.

View ruleSource: page 4, section CONTINUANCES

Is electronic filing required before Judge Alicia Garcia Priovolos?

Before requesting a hearing, the motion must be filed with the Clerk of Court.

View ruleSource: page 1, section For scheduling: Please email the Judicial Assistant, Paula Lopez

When is a filing treated as filed before Judge Alicia Garcia Priovolos?

The rule states a 12:00 PM filing cutoff. Hearing requests must be received by noon on Friday to be placed on the following Wednesday's calendar.

View ruleSource: page 4, section NON-EVIDENTIARY MOTION CALENDAR (WEDNESDAYS @ 10:00 AM)

What rule applies to service by email for the opposing party before Judge Alicia Garcia Priovolos?

Details: method: service by email, recipient: the opposing party. Hearing request emails must copy opposing counsel.

View ruleSource: page 1, section To request a hearing date: email Judicial Assistant Paula Lopez
Complete rules summary for Judge Alicia Garcia Priovolos

When requesting a hearing, a copy of the motion and proposed order must be emailed to the Judicial Assistant because e-filing does not provide the court with a copy.

Hearing scheduling requests must be emailed to Judicial Assistant Paula Lopez together with the Request for Hearing and a copy of the motion.

Before requesting a hearing, the motion must be filed with the Clerk of Court.

To request a hearing date, counsel must email Judicial Assistant Paula Lopez, copy opposing counsel, and include the motion to be heard and a proposed order in Microsoft Word format.

Hearing request emails must copy opposing counsel.

All parties must be included on the email correspondence when requesting a hearing.

The e-mail should also include the motion seeking to be heard and a proposed Order, in Microsoft Word format.

For hearings set for Zoom appearance, parties must contact the Judicial Assistant by phone to obtain the Zoom Meeting ID.

E-filing a motion does not deliver a copy to the court, even when the court's email address is added in the e-filing service, so the motion must be emailed to the Judicial Assistant.

The e-mail should also include the motion seeking to be heard and a proposed Order, in Microsoft Word format.

Hearing date requests must be emailed to Judicial Assistant Paula Lopez with opposing counsel copied, and the email must include the motion to be heard and a proposed Order in Microsoft Word format.

Hearing scheduling requests must be emailed to Judicial Assistant Paula Lopez with the Request for Hearing and a copy of the motion, which must already be filed with the Clerk, and all parties must be included on the email.

The e-mail should also include the motion seeking to be heard and a proposed Order, in Microsoft Word format.

E-filing a motion does not deliver a copy to the court, even if the court's email address is added to the e-filing service, so the motion must be emailed separately to the Judicial Assistant.

The e-mail should also include the motion seeking to be heard and a proposed Order, in Microsoft Word format.

For hearings set for Zoom appearance, parties must contact the Judicial Assistant by phone to obtain the Zoom Meeting ID.

The Judicial Assistant is Paula Lopez and she can be reached at palopez@jud11.flcourts.org.

The bailiff is Alvaro Puente and he can be reached at apuente@jud11.flcourts.org.

Chambers is located at the Lawson E. Thomas Courthouse, 175 N.W. 1st Avenue, 2920, Miami, FL 33128, and can be reached by telephone at (305) 349-5674.

Criminal cases in division 89 are not heard on Thursdays or Fridays, but court staff is available to assist with scheduling matters in an emergency.

Counsel accepting a plea in abstentia must ensure an affidavit is in the court file authorizing counsel to accept the plea and addressing all Rule 3.172 subsections.

Non-evidentiary hearings of five minutes or less must be requested by emailing the Judicial Assistant at palopez@jud11.flcourts.org with opposing counsel copied.

The motion and proposed order attached to a hearing request must be in Microsoft Word format.

Parties must make a good faith effort to coordinate a hearing date with opposing counsel before requesting a non-evidentiary hearing.

Hearing requests must be received by noon on Friday to be placed on the following Wednesday's calendar.

Evidentiary hearing requests must be emailed to the Judicial Assistant at palopez@jud11.flcourts.org, copying opposing counsel and attaching the written motion.

Parties must make a good faith effort to coordinate a hearing date with opposing counsel before requesting an evidentiary hearing (motions requiring more than 5 minutes or any evidence).

Court staff will notify parties by end of day Monday whether a motion will be heard that week or the following week.

Court staff will notify parties when an evidentiary motion will be heard based on urgency and availability.

Motions to compel discovery shall be in writing and will be heard at sounding calendar. A written motion to compel shall include: 1. The discovery sought with specificity. 2. The date upon which the discovery was propounded and due. 3. The dates the moving party has conferred, or attempted to confer, with the party failing to provide the discovery sought. 4. Any reasons, responses and/or failures to respond by the party failing to provide the discovery. 5. The moving party shall also certify that counsel has attempted in good faith to resolve the issues with opposing counsel on a minimum of two occasions, prior to the motion to compel being filed, and has been unable to reach a resolution. 6. Finally, the motion should also describe a movant's independent efforts (if any) to obtain the discovery sought prior to seeking court action.

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