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DISCOVERY: The parties shall complete all written discovery and depose all fact witnesses on or before . Written discovery should proceed promptly (unless.After the Defendant files an Answer, the judge will set a hearing for the parties to appear in court. (3) The scheduling order must limit the time to join other parties, amend the pleadings, complete discovery, and file motions. At the initial case management conference the court and counsel will consider the specific matters which are enumerated in subparagraphs (a)(1) through (a)(10). (b) Conduct of Case Management Conference . CONNECTIONS will customize the FASP according to FASP type (Initial,. The date of filing the initial complaint. A proposed Order Accepting Agreed. Psychological readiness for adoption.