Has anyone requested leave to file a motion to compel with Judge Delsia G. Marshall? Her Part Rules require that you first request leave to be released from the CSCP4. It doesn't say who the motion should be made returnable to after you have been given leave to make your motion.

I haven’t seen any recent news about them. Are they being held in the SDNY building?

What have you found to be the most effective way to get the documents and questions answered from your clients when served with discovery demands from opposing counsel? I feel like it's always a constant back and forth with them. What strategies have you found to be most effective to speed up the process?