Notice to Appear at Trial (to party) – 20 days before trial, send notice with time and place to attorney.Notice to Appear at Trial (to party) – 10 days before trial, send notice with time and place to attorney.998 Offers to Compromise – Can be made up until 10 days prior to trial.Experts Must Be Disclosed – 50 days before trial (or 20 days after service of demand, whichever is closer to trial date).Experts Must Be Demanded – 70 days before trial (or within 10 days of setting trial date, whichever is closer to trial date).Discovery Closes (with the exclusion of expert lists, and expert depositions) – 30 days before trial, or after non-binding arbitration.Discovery Closes Before Arbitration – 15 days before arbitration.
Arbitrator Must Issue Award – Within 10 days after conclusion of arbitration (or 20 on application from the Arbitrator for more time).Experts Must Provide Documents Before Their Depo – 3 business days before a deposition, experts must provide a copy of the documents that they are producing in response to the deposition notice.Last Day for Motions Regarding Experts – 10 days before original trial date.Expert Discovery Cut Off – 15 days before original trial date.Expert Depositions – May be set “On receipt of an expert witness list from a party.”.May only disclose witness to cover a subject covered by opponent’s witnesses. S upplemental Expert Disclosure – Must be disclosed within 20 days of the Exchange of Expert Witnesses.Experts Must Be Disclosed – 50 days before trial (or 20 days after service of demand, whichever is closer to trial date).Experts Must Be Demanded – 70 days before trial (or within 10 days of setting trial date, whichever is closer to trial date).Depositions in Unlawful Detainer Actions – Only 5 days notice required.(+5 days if the notice is mailed – ccp 1013) For non-party witnesses – A subpoena must be issued at least 20 days before the deposition.(+5 days if the notice is mailed – ccp 1013). For parties to the lawsuit – no subpoena is necessary, and the party can be compelled to produce “personal records” with only 10 days notice.Depositions With Records Requests – If seeking “personal records” of a “consumer” the procedure differs depending on whether one is taking the deposition of a party (plaintiff, defendant, cross-defendant, etc.) or a non-party witness:.Deposition Objection – A party must “promptly” object at least 3 calendar days (+5 for mail) before the date of the deposition.Depositions – Must be set at least 10 days in the future (+5 days if the notice is mailed – CCP 1013).Plaintiff must wait 20 days after service of Summons and Complaint to serve. Deposition Notice – Defendant may serve any time.Practical Last Day to Serve Discovery (and be able to make a motion on it) – 90-100 days before trial.Last Day to Hear Discovery Motions – 15 days before trial.Discovery closes before trial: 30 days before trial – or 15 days before arbitration.Note: Extending the trial date does not automatically extend the discovery cutoff date. Respond to Written Discovery – 30 days (+5 days if questions were mailed).Move to Compel Additional Answers – 45 days.Motion to Quash Subpoena Duces Tecum – must be served on defense counsel at least five days before date for production of documents Note: Court may still grant a motion to quash after this time.Must be served on records custodian 15 days before date of production. Subpoena for Employment Records – Must be served on the employee 10 days before date for production (in actuality 20 days before, see below), 5 days before service on the custodian of records.
The subpoena may not be served on records custodian until at least five days after service on consumer. Subpoena for Personal (medical) records – Must be served on consumer at least 15 (in actuality 20) days before date of production.Plaintiff May Serve Deposition Notice – 20 days after service of Complaint.Defendant may Serve Discovery – Anytime.Plaintiff may Serve Discovery Questions to Another Party – 10 days after service of complaint.Defendant Time Limit to File Answer or Demurrer – 30 days from date complaint was served.Proof of Service of Summons and Complaint (proving to Court that you served Defendant) – 60 days after filing complaint.Serve Defendant Added via Amended Complaint – 30 days after adding.Serve Defendant after Complaint Filed – 60 days after filing.
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