The foregoing requirement shall not apply where there has been a complete and total failure to respond to a discovery request or set of discovery requests.
Counsel and/or the party seeking relief, in the separate statement of moving counsel, shall specify the particulars of the personal consultation, or efforts towards personal communication if such personal consultation did not occur, in support of any request for attorney's fees as a sanction.
L. R. Prac. Sup. Ct. CV-1