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It depends on the volume of live yeast in the wort. At peak growth, 24-36 hours or so depending on yeast, temps and volume, you want to be at target temperature and stay there until pretty much done. I’ve seen yeast pinched at what most would consider very high temps and the beer is fine. Mostly because the temps are dropping to normal vs static or rising.
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Oh yeah, definitely I'm talking about getting to the intended ferment temp in way less than 24 hours after pitching.
I use a craigslist chest freezer, and it will drop a 5.5gal fermenter from ~85 to ~65 in something like four hours. For my current equipment and process this is very common for me to do. I will pitch at ~65 and let it come up to the target (yeast dependent) with heat generated by the fermentation. And/or room ambient temp in the summer time.
Of course I'm sure many other variations are just fine as well.
Just based on reading I've done, I would try not to have >10 degree temp difference between the wort and a liquid starter at the time of pitching. But push comes to shove, I've never tried it either.