Joint Report Proposed Scheduling Discovery Order (Class Action - Judge Dugan) {ILSD JRPSDOCA_DWD}

JOINT REPORT OF THE PARTIES AND PROPOSED SCHEDULING AND DISCOVERY ORDER (CLASS ACTION). This is a Southern District of Illinois form used to outline the parties’ Rule 26(f) plan in putative class actions not subject to mandatory mediation. The form focuses on pre-certification discovery and requires the parties to identify deadlines for initial written discovery, depositions of plaintiffs and defendants, commencement of third-party actions, and expert disclosures related to class certification. It also exempts the parties from the standard deposition and interrogatory limits of Rules 30(a)(2)(A) and 33(a), allowing them to propose case-specific limitations. Parties must address proportionality and electronically stored information (ESI), and submit an ESI protocol if needed. The order sets required deadlines for the motion for class certification, opposition, and reply briefs, and outlines the court’s process for resolving discovery disputes. www.FormsWorkflow.com