(a)      Applicability of Federal Rule of Civil Procedure 26. Unless the court orders otherwise, Fed. R. Civ. P. 26(a), (d) and (f) apply to adversary proceedings only to the extent set forth in the court’s Order Setting Scheduling Conference and Establishing Procedures and Deadlines, and Order Setting Filing and Disclosure Requirements for Pretrial and Trial.

(b)     Discovery Disputes.

(1)      Motion to Compel.  Except for a motion based on complete failure to respond – or assertion of a general or blanket objection – a motion to compel discovery under Fed. R. Civ. P. 37(a) must:

(A)      quote in full each interrogatory, request for admission, or request for production to which the motion to compel is directed;

(B)      quote in full each response or objection to which the motion to compel is directed; and

(C)      state why the motion should be granted.

(2)      Motion for Protective Order.  A motion for protective order under Fed. R. Civ. P. 26(c) filed before the time to respond to a written discovery request under Fed. R. Civ. P. 33, 34, or 36 or the date of a deposition noticed under Fed. R. Civ. P. 30, stays the response deadline or the deposition until the court rules on the motion.

(c)      Claiming a Privilege or Protection as Trial-Preparation Material. If a party withholds information otherwise discoverable by claiming that the information is privileged or subject to protection as trial-preparation material under Fed. R. Civ. P. 26(b)(5), the party must prepare and serve on the requesting party a privilege log.

(d)     Exception. A privilege log is not required if the information withheld as privileged or subject to protection as trial-preparation material constitutes written or oral communications between a party and its attorney made – or trial-preparation material created – after the commencement of the adversary proceeding or contested matter in which the discovery request was made.

(e)      Privilege Log. A privilege log required by (c) must:

(1)      identify the privilege or protection as trial-preparation material being claimed; and

(2)      unless divulging it would cause disclosure of the allegedly privileged or protected information, provide the following information (which may be asserted by group or category of documents, ESI or communications):

(A)      for documents or ESI, to the extent the information is readily obtainable:

(i)       the type of document and, if ESI, the file type;

(ii)      the general subject matter of the document or ESI;

(iii)     the date of the document or ESI; and

(iv)     any other information sufficient to identify the document or ESI, including the author and recipients of the document or ESI, and the relationship of the author and recipients to each other; and

(B)      for oral communications:

(i)       the name of the person making the communication and the names of persons present while the communication was made and the relationship of the persons present to the person making the communication;

(ii)      the date and the place of the communication; and

(iii)     the general subject matter of the communication.