The discovery deadline, whether fact or otherwise, is the date by which all responses to
discovery shall be due according to the Federal Rules of Civil Procedure and by which all
depositions shall be concluded. Counsel shall initiate discovery requests and notice depositions
(including subpoenas/subpoenas duces tecum to non-parties) sufficiently in advance of the
deadline to comply with this Rule. Discovery requests that call for responses or scheduled
depositions after the discovery deadline will not be enforceable except by order of the Court for
good cause shown. Unless otherwise ordered by the Court, motions to compel discovery must
be filed within the discovery period.