Rule 8.4 - Failure to make discovery and motion to compel discovery(A) Prior to filing a motion to compel discovery, counsel for the moving party shall confer with counsel for the opposing party in a good faith effort to resolve the matters involved. At the time of filing the motion, counsel shall also file a statement certifying that such conference has occurred, and that the effort to resolve by agreement the issues raised failed. If some of the issues have been resolved by agreement, the statement shall specify the issues remaining unresolved. (B) Motions to compel discovery in accordance with OCGA § 9-11-37 shall: 1. Quote verbatim or attach a copy as an exhibit of each interrogatory, request for admission, or request for production to which objection is taken; 2. Include the specific objection or response said to be insufficient; 3. Include the grounds assigned for the objection (if not apparent from the objection); and 4. Include the reasons assigned as supporting the motion. Such objections and grounds shall be addressed to the specific interrogatory, request for admission, or request for production and may not be made generally.