40.24 Scheduling Order
It is ORDERED:
1.	Discovery1 shall be conducted according to the following schedule:

			Discovery						Time2	
Interrogatories by all parties to ascertain
identity and location of witnesses and
documents, including computerized records			

Document production by all parties		

Lay-witness depositions
	• noticed by plaintiffs		
	• noticed by defendants		

Expert(s):
	• plaintiffs:
		– submission of reports		
		– depositions			
	• defendants:
		– submission of reports		
		– depositions			

Production of proposed computerized summaries
and samples:
	• by plaintiffs			
	• by defendants			

2.	Except for good cause shown—
(a)	relief from the above schedule shall not be granted and all discovery shall be completed by 
          [date]           ;3
(b)	discovery shall be limited to matters occurring after          [date]         [and before       [date]      ];
(c)	no more than 	   interrogatories (including subparts) may be propounded to any party (exclusive of interrogatories seeking the identity and location of witnesses and documents);
[(d)	no more than          depositions may be taken by either plaintiffs or defendants, and no single deposition (other than of                                   ) may take more than           hours/days;4] and
(e)	no amendment of pleadings may be made after          [date]       , and no additional parties may be joined as plaintiff, defendant, or third-party defendant after 	    [date]            .
3.	The parties are expected to be prepared for trial on all issues [except 		] by        [date]          .

Dated: 												
									United States District Judge

Notes:
	1.	Where initial disclosure is appropriate, provision should be made in the order. See also supra section 40.21, ¶ 6(b). Note that the 2000 amendments to Rule 26(a)(1) contemplate that a party in a complex case may object during the Rule 26(f) conference that initial disclosures are “not appropriate in the circumstances of the action” and by such objection call for a judicial ruling on the question.
	2.	The time for undertaking or completing some aspect of discovery may be stated either by using specific dates or by reference to completion of discovery that should precede it. The listing in this sample order of certain forms of discovery is not intended to suggest that they should be undertaken in this sequence or that each item should be completed before other discovery is undertaken. For example, in many cases, depositions should be conducted by both sides during the same period of time, during which the parties may also be involved in preparing answers to interrogatories and responses to requests for admission.
	3.	The extent to which a schedule for all discovery can be established at the initial conference will depend on the circumstances of the litigation. In some complex cases it may be feasible to establish a timetable only for certain portions of discovery, leaving for subsequent conferences the setting of a schedule for other discovery and a ﬁnal cutoff date for all discovery. In other cases, a comprehensive discovery schedule—which may even include dates for preparation and submission of a joint statement of contested and uncontested facts, and for identification of trial witnesses and documents—can be established at the initial conference.
	4.	Other restrictions on discovery may be added.