In addition to the requirements of Rules 37(a), Arizona Rules of Civil Procedure, a party moving to compel discovery must also set forth, separately from the memorandum of law in support of their Motion to Compel, the following in separate, distinct, numbered paragraphs:
The requirement does not apply where there has been a complete and total failure to respond to the propounded discovery.
L. R. Prac. Sup. Ct. 2.7