(a)Deposition procedure. – Unless the court orders otherwise, the parties may agree that depositions may be taken before any person, at any time or place, upon any notice, and in any manner and when so taken may be used like other depositions. (b)Modification of scheduling order and discovery procedures or limitations. – Unless the Court orders otherwise, a scheduling order may be modified only as follows:
(1) Time limits set forth in a scheduling order for the joinder of other parties, amendment of pleadings, filing of motions, and completion of discovery, and any date or dates set forth therein for conferences before trial, a final pretrial conference, and for trial may be modified for cause by order of the court. (2) Subject to paragraph (3), stipulations to modify discovery procedures or limitations will be valid and will be enforced as if established by order of the court, provided the stipulations are in writing, signed by the parties making them or their counsel, timely filed with the clerk of the court, and do not affect the time limits specified in subparagraph (1). (3) A private agreement to extend discovery beyond the discovery completion date as set in a scheduling order will be respected by the court if the extension does not affect the other time limits specified in subparagraph (1). A discovery dispute which arises from such a private agreement to extend discovery beyond a discovery completion date need not, however, be resolved by the court.
