Joint Report Proposed Scheduling Discovery (Not Referred-Judge Dugan) {ILSD JRPSDNR_DWD}

JOINT REPORT OF PARTIES AND PROPOSED SCHEDULING AND DISCOVERY ORDER. This is a Southern District of Illinois form used when cases assigned to Judge Dugan are not referred to mandatory mediation. Following the Rule 26(f) conference, the parties use this form to outline agreed deadlines for initial written discovery, the depositions of plaintiff and defendant, and motions to amend pleadings or add third-party claims. It also sets a timetable for disclosing expert witnesses and written reports under Rule 26(a)(2), followed by expert depositions. The form requires parties to confirm that they discussed proportionality, cost considerations, and ESI needs, and submit an ESI protocol if necessary. It further establishes deadlines for completing discovery and filing dispositive motions, and advises parties to follow Judge Dugan’s procedures for handling discovery disputes. www.FormsWorkflow.com