Write the meet-and-confer letter that sets up the motion
Three turns and a check. Keep this open next to your chat: each step is the thing to paste next, with what you typed already carried across. Nothing is sent from here, and nothing on this page is a transcript. The conversation stays where you are having it.
By request number: what was asked, what came back, and what is wrong with it.
The claims and the time period in issue, so relevance can be argued rather than asserted.
The forum and anything it requires before a motion.
Prior letters, calls, and extensions, with dates.
The discovery cutoff and anything that makes the timing real.
Watch for, the whole way through
What counts as a conferral, and whether a letter alone satisfies it, varies by forum and by judge. A motion filed on an insufficient conferral gets denied without reaching the merits.
This letter becomes an exhibit. Every sentence should be one you would want a judge to read, including the ones written at the end of a bad week.
The model will invent dates, quotations from responses, and descriptions of calls. Check every factual assertion against the actual correspondence.
Naming a consequence you do not follow through on costs you the next letter and the one after it.