A schedule may be modified only for good cause and with the judge's consent. Mere failure to complete discovery within the time allowed does not constitute good.If you feel confident that the opposing party is unlikely to cooperate with discovery, you could file a motion to compel now. All forms are available in PDF format unless otherwise noted. The Court recommends opening PDF forms with Adobe Acrobat Reader. Generally no, though there are many exceptions. (h) Discovery Not Filed Until Necessary. No discovery materials shall be filed until they are used in the proceeding or the court orders filing. Refuse to testify in her CR 30(b)(6) capacity on topics not specified adequately in the notice. Supervisory approval and notice to the defendant.