Rule 6.4 - Failure to make discovery and motion to compel discovery(A) 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 or to which no response or insufficient response is provided; (2) Include the specific objection or response claimed to be insufficient; (3) Include the grounds for the objection (if not apparent from the objection); and, (4) Include the reasons supporting the motion. Any objections shall be addressed to the specific interrogatory, request for admission, or request for production and shall not be made generally.(B) Prior to filing a motion seeking resolution of a discovery dispute, counsel for the moving party shall confer with counsel for the opposing party and any objecting person or entity 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. This rule also applies to motions to quash, motions for protective order and cases where no discovery has been provided.Amended effective November 28, 1996; amended effective May 15, 2014.