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F. Completion of Discovery

The Court ordinarily sets a discovery completion date through its Case Management and Scheduling Order (although a Judge may have another method of setting and extending that deadline). The Court follows the rule that the completion date means that all discovery must be completed by that date. For example, interrogatories must be served more than thirty days prior to the completion date to permit the opposing party to respond before the discovery deadline. Untimely discovery requests are subject to objection on that basis. Counsel, by agreement, may conduct discovery after the formal completion date but should not expect the Court to resolve discovery disputes arising after the discovery completion date.