Miss. L. Coun. Ct. R. 12
In all motions to compel discovery for whatever reason, all counsel shall be under a duty to confer in good faith to determine to what extent discovery disputes can be resolved before presenting the issue to the Judge. No such motion shall be heard by the Judge unless counsel for the moving party shall file a certificate that he has conferred in good faith with opposing counsel in an effort to resolve the dispute and has been unable to do so.
In the memorandum accompanying any motion to compel discovery, the moving party shall set forth the question, request or interrogatory, the response thereto and the specific deficiency of the response. General comments such as "the answer is incomplete or evasive" are not adequate. If a common specific deficiency allegedly occurs in the response to more than one interrogatory, question or request, then the moving party may discuss those interrogatories, questions, or requests together.
Miss. L. Coun. Ct. R. 12