![]() (+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. Discovery Closes Before Arbitration – 15 days before arbitration.Respond to Written Discovery – 30 days (+5 days if questions were mailed).Move to Compel Additional Answers – 45 days. ![]()
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