c) within 75 days such parties will complete any discovery, subject to additional time being needed to conduct foreign depositions, if necessary

Assuming there has been no change of course since the DM response 7/28 that is, and if so, I'd assume a Pacer would be required? Then again, if the 2 parties are corresponding without the courts involvement, re: settlement talks, probably not.

Regardless, the date is near.