All motions arising out of a party's response (or non-response) to an interrogatory, request for admission, deposition question, or arising out of a party's response to, or asserted failure to comply with, a request for production of documents, shall be accompanied by a brief. With respect to each interrogatory, deposition question, or request at issue, the brief shall set forth separately and in the following order: (1) the text of the interrogatory, deposition question, or request, (2) the opponent's response, and (3) an argument. Alternatively, the text of the interrogatory, deposition question or request and the opponent's response may be contained in an appendix to the brief.

Effective July 1, 2005

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