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LR 26.1 Time Limitations. Discovery shall proceed as follows:

(a) The parties shall confer by the earlier of 60 days after any defendant has been served with the complaint or 45 days after any defendant has appeared.

(b) Within 14 days after the required conference pursuant to Fed. R. Civ. P. 26(f), the parties shall submit to the Court a written report outlining their proposed discovery plan. This report shall conform to the language and format of the standard form included in the Appendix of Forms to these rules (and furnished by the Clerk to the plaintiff upon the filing of the complaint).

(c) Upon receipt and review of the parties' written report, and within the time set by Fed. R. Civ. P. 16(b), the Court, through the Judge or Magistrate Judge, will promptly enter its Scheduling Order as provided in Fed. R. Civ. P. 16(b).

(d) Unless otherwise stated in the Scheduling Order issued pursuant to Fed. R. Civ. P. 16(b):

(i) the parties shall serve all written discovery on opposing parties and shall complete all depositions within 140 days of the filing of the last answer of the defendants named in the original complaint;

(ii) the plaintiff must furnish the expert witness reports required by Fed. R. Civ. P. 26(a)(2)(B) and provide the disclosures required by Fed. R. Civ. P. 26(a)(2)(C) within 60 days after the Fed. R. Civ. P. 26(f) conference or, in cases exempt from the Fed. R. Civ. P. 26(f) conference, within 60 days after the filing of the last answer of the defendants named in the original complaint;

(iii) the defendant must furnish the expert witness reports required by Fed. R. Civ. P. 26(a)(2)(B) and provide the disclosures required by Fed. R. Civ. P. 26(a)(2)(C) within 90 days after the Fed. R. Civ. P. 26(f) conference or 60 days after filing his answer, whichever is later, or in cases exempt from the Fed. R. Civ. P. 26(f) conference, within 90 days after the answer.

(e) In removed cases, the Fed. R. Civ. P. 26(f) conference shall be held within 21 days of the date of filing of the notice of removal or within 21 days of filing of the last answer of the defendants, whichever is later but in no event later than 45 days after the first appearance by answer or motion under Fed. R. Civ. P. 12 of a defendant named in the original complaint.

(f) In cases transferred from another district, the Fed. R. Civ. P. 26(f) conference shall be held within 21 days of the docketing of the case in this district.