Service of Complaint: 60 days after filing complaint. (CRC 3.110; See also  CCP § 583.210 which requires serving the Summons and Complaint within three years after the Complaint is filed.  Due to the conflict between the CCP and the CRC, the best practice is to use the shorter time limit.)

Serve Defendant Added via Amended Complaint: 30 days after adding party.(CRC 3.110(b).)

Filing Proof of Service of Summons and Complaint: 60 days after filing complaint. (CRC 3.110; See also CCP § 583.210 which requires filing the Proof of Service within 60 days after serving the complaint. Due to the conflict between the CCP and the CRC, the best practice is to use the shorter time limit.)

Response to Complaint (Answer/Demurrer/Motion to Strike): 30 days from date complaint was served. (CCP § 412.20.)

Meet and Confer re Demurrer: A meet and confer regarding demurrer must take place at least 5 days before the date the responsive pleading is due. (CCP § 430.41(a)(2).) Response is extended another 30 days from date responsive pleading was due with timely filing of declaration re inability to meet and confer re the demurrer. (CCP § 430.41(a)(2).)

Filing of Case Management Statements: 15 days days before the date set for the case management conference. (CRC § 3.725(a).)

Plaintiff may Serve Discovery Questions to Another Party: 10 days after service of complaint. (CCP § 2030.020 (Interrogatories), CCP § 2031.020 (Requests for Production), CCP § 2033.020 (Requests for Admission).)

Defendant may Serve Discovery: Anytime. (CCP § 2030.020 (Interrogatories), CCP § 2031.020 (Requests for Production), CCP § 2033.020 (Requests for Admission).)

Plaintiff May Serve Deposition Notice: 20 days after service of Complaint. (CCP § 2025.210.)

Defendant May Serve Deposition Notice: Anytime after service or appearance, whichever occurs first. (CCP § 2025.210.)

Depositions: Must be set at least 10 days in the future. (CCP § 2025.270.)

Depositions in Unlawful Detainer Actions: Only 5 days notice required. (CCP 2025.270(b).)

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:

• For parties to the lawsuit - no subpoena is necessary, and the party can be compelled to produce "personal records" with only 10 days notice.  (CCP § 2025.270.)
• For Non-Party Witnesses: A subpoena must be issued at least 20 days before the deposition.  (CCP § 2025.270.)

Deposition Objection: A party must "promptly" object at least 3 calendar days before the date of the deposition. (CCP § 2025.401(a).)

Respond to Written Discovery: 30 days. (CCP § 2030.260 (Interrogatories), CCP § 2031.260 (Requests for Production), CCP § 2033.250 (Requests for Admission).

Move to Compel Further Response: 45 days. (CCP § 2030.300 (Interrogatories), CCP § 2031.310 (Requests for Production), CCP § 2033.290 (Requests for Admission).)

Subpoena for Personal (medical) records: Must be served on consumer at least 15 (in actuality 20) days before date of production. (CCP § 1985.3(d) incorporating CCP § 2020.220(a).) The subpoena may not be served on records custodian until at least five days after service on consumer. (CCP § 1985.3(b)(3).)

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. (CCP § 1985.6(b)(2)&(3).) Must be served on records custodian 15 days before date of production.

Motion to Quash Subpoena Duces Tecum: Must be served at least 5 days before date for production of documents. (CCP § 1985.3(g), 1985.6(f)(2).) Note: Court may still grant a motion to quash after this time.(Slage v. Sup. Ct. (1989) 211 Cal. App.3d 1309, 1313.)

Discovery closes before trial: 30 days before the date initially set for the trial of the action. (CCP § 2024.020.)

Last Day to Hear Discovery Motions: 15 days before the date initially set for the trial of the action.(CCP § 2024.020.)

Practical Last Day to Serve Discovery: (and be able to make a motion on it) 90-100 days before trial.

Experts Must Be Demanded : 70 days before trial (or within 10 days of setting trial date, whichever is closer to trial date)(CCP § 2034.220.)

Experts Must Be Disclosed : 50 days before trial (or 20 days after service of demand, whichever is closer to trial date)(CCP § 2034.230.)

Supplemental Expert Disclosure: Must be disclosed within 20 days of the Exchange of Expert Witnesses. May only disclose witness to cover a subject covered by opponent’s witnesses. (CCP § 2034.280.)

Expert Depositions: May be set "On receipt of an expert witness list from a party." (CCP § 2034.410.)

Expert Discovery Cut Off: 15 days before original trial date. (CCP § 2024.030.)

Last Day for Motions Regarding Experts: 10 days before original trial date. (CCP § 2024.030.)

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. (CCP § 2034.415.)

Noticed motions: Must be served and filed 16 court days before the hearing date (+ 5 calendar days if served by mail) (+ 2 calendar days if served by fax, express mail, or overnight delivery). (CCP § 1005(b).) Note: CCP § 1013 does not apply.

Opposition to noticed motion: Must be filed and served 9 court days before hearing. (CCP § 1005.)

Reply to noticed motion : Must be filed and served 5 court days before hearing. (CCP § 1005.)

Manner of service for Opposition/Reply: “Notwithstanding any other provision of this section, all papers opposing a motion and all reply papers shall be served by personal delivery, facsimile transmission, express mail, or other means consistent with Sections 1010, 1011, 1012, and 1013, and reasonably calculated to ensure delivery to the other party or parties not later than the close of the next business day after the time the opposing papers or reply papers, as applicable, are filed.” (CCP § 1005(c).)

Ex Parte Motion: Opposing party must be notified no later than 10:00 A.M. the court day before the ex parte appearance, absent "exceptional circumstances." (CRC 3.1203.) Note: This is a minimum. Check local rules for more strict notice periods.

Table of Contents/Authorities: Required for motions over 10 pages. (CRC 3.1113(f).)

Motions for Summary Judgment: Notice is 81 days before hearing (+10 if outside CA, +20 if outside US). (CCP § 437c(a)(2).) Opposition is 20 days before the hearing. (CCP § 437c(b)(2).) Reply is 11 days before hearing. (CCP § 437c(b)(4).) Motion must be heard 30 days before trial date. (CCP § 437c(a)(3).) Note: This 30 day time limit can be modified by the court for "good cause." (CCP § 437c(a)(3).) (CCP 437c as amended by Stats. 2024, Ch. 99, Sec. 1. (AB 2049) Effective January 1, 2025.)

Manner of service for Opposition/Reply: "Notwithstanding any other provision of this section, all papers opposing a motion and all reply papers shall be served by personal delivery, facsimile transmission, express mail, or other means consistent with Sections 1010, 1011, 1012, and 1013, and reasonably calculated to ensure delivery to the other party or parties not later than the close of the next business day after the time the opposing papers or reply papers, as applicable, are filed." (CCP § 1005(c).)

Discovery Closes: (with the exclusion of expert lists, and expert depositions) 30 days before the date initially set for the trial, or after non-binding arbitration. (CCP § 2024.020, CCP § 1141.24.).

998 Offers to Compromise: Can be made up until 10 days prior to trial. (CCP § 998.).

Notice to Appear at Trial (to party) (No documents): 10 days before trial. (CCP § 1987(b).).

Notice to Appear at Trial (to party) (With documents): 20 days before trial. (CCP § 1987(c).).

Objection to Notice to Appear At Trial With Documents: 5 days after the notice to appear, "or any other time period as the court may allow"(CCP § 1987(c).).

Answers/Responses: Due 21 days after the operative complaint, counterclaim or crossclaim is served. (FRCP 12(a)(1).) After motion in connection with the pleadings (FRCP 12(b)-(e)) was denied or ruling was postponed until trial the answer/response is due after 14 days. (FRCP 12(a)(4).)

Rule 12(b) Motions (i.e. “demurrers”): Due before serving a responsive pleading and therefore are due 21 days after the operative complaint, counterclaim or crossclaim is served. (FRCP 12(b).)

Rule 12(c) Motions for Judgment on the Pleadings: Due after the close of pleadings but early enough not to delay trial. (FRCP 12(c)).

Rule 12(e) Motions for More Definite Statement: Due before serving a responsive pleading and therefore are due 21 days after the pleading to which they pertain is served. (In the case that no responsive pleading is due Rule 12(e) motions for more definite statement are not contemplated.) (FRCP 12(e).)

Rule 12(f) Motions to Strike: Due before serving a responsive pleading and therefore are due 21 days after the operative complaint, counterclaim or crossclaim is served. In the case that no responsive pleading is due, Rule 12(f) Motions to Strike are due 21 days after the pleading to which they relate. (FRCP 12(b), (e), (f).)

Rule 26(f) Conference: Must be held 21 days before the scheduling conference or the Rule 16(b) scheduling order is due. (FRCP 26(f)(1).)

Joint Discovery Plan: Due 14 days after the Rule 26(f) conference. (FRCP 26(f)(2).)

Rule 26(a)(1) Initial Disclosures: Due 14 days after the Rule 26(f) conference. (FRCP 26(a)(1)(C).) For parties joined after the Rule 26(f) conference, initial disclosures are due 30 days after joining. (FRCP 26(a)(1)(D).)

Scheduling Order: Due by the earlier of (a) 120 days after any defendant has been served or (b) 90 days after any defendant has appeared. (FRCP 16(b)(2).)

Responses to Discovery: Generally 30 days after the requests were served. (Interrogatories - FRCP 33(b)(2); Requests for Documents and Electronically Stored Information - FRCP 34(b)(2)(A); Requests for Admission – FRCP 36(a)(3).)

Depositions and Subpoenas: Only require, vaguely, “reasonable time” between notice and the deposition and, not incidentally, production of documents thereat. (Party depositions - FRCP 30(b)(1); Non-party subpoenas - FRCP 45(d)(3)(A)(i).)

Expert Witness Disclosures: Due 90 days before trial. (FRCP 26(a)(2)(D)(i).) Rebuttal expert witness disclosures are due 30 days after receiving the other parties’ expert witness disclosures. (FRCP 26(a)(2)(D)(ii).)

Pretrial Disclosures:Due 30 days before trial. (FRCP 26(a)(3)(B).) Objections to the use of designated deposition testimony and documents are due 14 days thereafter. (FRCP 26(a)(3)(B).)

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