Local Rule 37.1 seems to often be forgotten. It requires a party bringing a discovery motion (which would include a discovery dispute) to recite or attach the discovery request or responses they are moving about:
Any discovery motion filed pursuant to Fed. R. Civ. P. 26 through 37 shall include, in the motion itself or in a memorandum, a verbatim recitation of each interrogatory, request, answer, response, or objection which is the subject of the motion or shall have attached a copy of the actual discovery document which is the subject of the motion.
D. Del. LR 37.1. Judge Burke's Guidelines for Discovery Disputes include a very similar requirement (and a requirement for the opposing party to do so if the moving party fails to), suggesting this is a common problem.
What happens if you forget? When I've seen it happen, the Court gave some leeway and allowed a party to submit them after the fact. But the Court could potentially deny the motion for failing to follow the local rules. I highly recommend reciting or attaching the underlying discovery in the first instance.
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