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The Proposed Scheduling Order should include: 1. Trial date: A proposed trial date. a.DISCOVERY Discovery shall be completed on or before the date set forth in the scheduling order. The scheduling order must limit the time to join other parties, amend the pleadings, complete discovery, and file motions. (B) Permitted Contents. The Court sets a discovery cutoff on the date stated in the caption of this Order. Scheduling orders and firm trial dates are an essential part of docket management. "Complete discovery" includes conclusion of all depositions and submission of full and final responses to written discovery. 6. A sample proposed scheduling order under Federal Rule of Civil Procedure (FRCP) 16(b) that counsel may use in a federal civil case. That counsel shall complete all discovery not later than . 2.