A. Except with leave of Court for good cause shown or by agreed order, a party shall not conduct formal discovery pursuant to CR 30, CR 31, CR 33, CR 34 or CR 36 relative to matters addressed in the Preliminary Verified Disclosure Statement until that party's Statement has been served in accordance with FCRPP 2(3).

B. A Motion to compel disclosure statements, releases, discovery, for a protective order, or for sanctions may be filed pursuant to CR 26 and/or CR 37 only if counsel are unable to resolve between themselves the discovery dispute. The moving party shall attach to the motion a certification of counsel that he or she has attempted to resolve the dispute and has been unbale to do so.