(a) Maryland Rule 2-401(c) encourages parties to agree on a plan for scheduling and completing discovery. Among other things, parties should communicate regarding the efficient sequencing of discovery; alternatives or modifications to discovery otherwise permitted that would permit discovery to be completed in a more just, speedy and inexpensive manner; and means by which discovery may be completed within time periods set forth in any scheduling order issued by the Court or as otherwise set forth in the Maryland Rules.

(b) When conducting discovery, all parties and attorneys are expected to act in a professional and courteous manner to other counsel, other parties, and non-parties. At a minimum, counsel should be open to, and reasonably available for, discussions concerning legitimate differences in order to achieve the just, speedy, and inexpensive completion of the discovery process and the resolution of any disputes that may arise during that process.