A. Motions to Comply or Compel. The parties and their attorneys have a duty to make a good faith effort to resolve, by agreement among them, any disputes that arise in the course of discovery.

No motion pertaining to discovery shall be filed or heard unless there is appended to or included in such motion a certificate of counsel that s/he has conferred with opposing counsel, that the parties are unable to reconcile their differences on the matter, and that all extrajudicial means have been exhausted in an effort to reconcile their differences.

To the extent that extrajudicial means have not disposed of the matter, the party seeking discovery may then file a motion to obtain relief, to be heard on the Court's motion hour docket. The motion may be accompanied by supporting argument or explanation, with citation to legal authority if desired. The motion must include either a copy of or a reference to the discovery requests in dispute.

B. Sanctions. The Court considers willful, deceptive, deliberate, or protracted noncompliance with discovery to be a serious matter and will not hesitate to sanction parties and/or attorneys when appropriate. Sanctions will include remedies as outlined in the Kentucky Rules of Civil Procedure and as deemed suitable by the Kentucky Court of Justice in order to effectuate a just resolution.