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  1. Early Discovery. Although Court-sanctioned discovery cannot begin before the initial attorney conference pursuant to Federal Rule of Civil Procedure 26(d), the Court encourages early discovery by agreement.
  2. Extensions. The Court will strictly enforce the discovery period set by the scheduling order. In rare circumstances, the Court will allow one extension upon a detailed showing of good cause by the parties. Extensions should be requested no later than one week before the close of discovery.
  3. Discovery Disputes. Counsel must work cooperatively to resolve any discovery disputes. To avoid unnecessary costs, Counsel should consider contacting the Court for informal resolution prior to filing discovery motions. Discovery motions will generally be referred to a discovery master or magistrate judge. Parties engaged in bad faith or vexatious conduct during discovery will bear the costs of a discovery master.