TRIAL PREPARATION CALENDAR
Matter No.:Court:
Case No.:
Dept.:
Judge:
Action Filed:
Date Prepared:
Day of week noticed motions heard:
Date / Deadline / Calendar / Authority
TRIAL / Start Time:9:00 a.m.
LDTF all trial documents (Exhibit list, witness list, joint statement of the case, motions in limine and oppositions thereto, joint list of controverted issues, jury instructions) / Noon of Friday b/f trial. / OCSC Local Rule 450.
LDTF Statement of Compliance / Noon of Friday b/f trial. / OCSC Local Rule 450.
LDTF Oppositions to Motions in Limine / Noon of Friday b/f trial. / OCSC Local Rule 450.
Pretrial Readiness Conference / Approx. 10 days b/f trial. / Set by Court. OCSC Local Rule 332.
LDT hold Issue Conference with opposing counsel, and:
- Exchange exhibits and motions in limine, and inspect photos and diagrams;
- Stipulate to facts for purposes of trial;
- Prepare joint statement of the case, joint list of controverted issues; and
- Prepare voir dire questions for the court to include in its voir dire; and
- Execute Statement of Compliance.
LDTPS Notice to Appear at Trial in Lieu of Subpoena / No later than 10 days b/f trial. / CCP § 1987(b).
LDTPS Trial Subpoenas for Personal Appearance (w/out documents) on non-party witnesses / 10 days b/f trial. / Internal deadline.
LDTPS CCP § 998 settlement demand / No later than 10 days b/f trial. / CCP § 998(b).
EXPERT DISCOVERY MOTION CUT-OFF / No later than 10 days b/f trial. If falls on Sat., Sun. or Holiday, then next court day. / CCP §§ 2016.060 and 2024.030.
LDTMS Notice to Appear at Trial in Lieu of Subpoena / No later than 15 days b/f trial. / CCP § 1987(b).
LDTMS CCP § 998 settlement demand / No later than 15 days b/f trial. / CCP § 998(b).
EXPERT DISCOVERY CUT-OFF / No later than 15 days b/f trial. If falls on Sat., Sun. or Holiday, then next court day. / CCP §§ 2016.060 and 2024.030.
LDTPS Notice of Trial / No later than 15 days b/f trial. / CCP § 594.
LDTPS Trial Subpoenas for Personal Appearance and Production of Documents / 15 days b/f trial. / Internal deadline.
DISCOVERY MOTION CUT-OFF / 15 days b/f trial. If falls on Sat., Sun. or Holiday, then next court day. / CCP §§ 2016.060 and 2024.020
ID: LDT hold Issue Conference and exchange trial documents and related motions to comply with Local Rule 450 / 20 days b/f trial. / Internal deadline.
ID: LDT Arrange Issue Conference w/ Opposing Counsel / 25 days b/f trial. / Internal deadline.
LDTMS Notice of Trial / No later than 20 days b/f trial. / CCP § 594.
LDTPS Notice to Appear and Produce Documents at Trial / No later than 20 days b/f trial. / CCP § 1987(c).
LDTPS motions in limine (to be heard on first day of trial) to comply with Local Rule 450 / No later than 16 court days b/f trial. / CCP § 1005; OCSC Rule 450.
OLDT post jury fees / No later than 25 days b/f trial. / CCP § 631(a)(5).
LDTMS Notice to Appear and Produce Documents at Trial / No later than 25 days b/f trial. / CCP § 1987(c).
LDTMS motions in limine (to be heard on first day of trial) to comply with Local Rule 450 / No later than 16 court days + 5 calendar days b/f trial. / CCP § 1005; OCSC Local Rule 450.
30 DAYS TO TRIAL / Whatever date it falls on / Internal deadline.
DISCOVERY CUT-OFF / 30 days b/f trial. If falls on Sat., Sun. or Holiday, then next court day. / CCP §§ 2016.060 and 2024.020.
GENERAL LAW AND MOTION CUT-OFF (except discovery motions, motions for summary judgment/adjudication and motions in limine) / No later than 30 days b/f trial. / Internal deadline.
LD for hearing on motion to bifurcate/sever claims or issues at trial (Note: does not include common law motions or court’s powers to bifurcate/sever sua sponte) / No later than 30 days b/f trial. / CCP § 598.
LDTPS Notice of Deposition—Expert Only / No later than 10 days b/f expert discovery cut-off. / CCP § 2034.460.
LDTMS Notice of Deposition—Expert Only / No later than 15 days b/f expert discovery cut-off. / CCP § 2034.460.
LD for hearing on motion for summary judgment/adjudication / No later than 30 days b/f trial. / CCP § 437c.
LDTPS motion re: expert discovery / No later than 16 court days b/f expert discovery motion cut-off . / CCP §§ 1005, 2024.030.
LDTPS discovery motions / No later than 16 court days b/f discovery motion cut-off. / CCP §§ 1005, 2016.60 and 2024.020.
LDTPS discovery motions in accordance with the last day the Court hears noticed motions / No later than 16 court days b/f last day of week court hears motions. **Check court website**[INSERT DATE] / CCP §§ 1005, 2016.60 and 2024.020.
LDTPS Notice of Deposition (including documents) / No later than 10 days b/f discovery cut-off / CCP §§ 2024.020 and 2025.270.
LDTPS Deposition Subpoena for Personal Appearance and Production of Documents or Personal Appearance Only (excludes duces tecum) / No later than 10 days b/f discovery cut-off / Internal Deadline: CCP § 2020.220(a)—“reasonable time”
LDTMS discovery motions / No later than 16 court days + 5 calendar days b/f discovery motion cut-off. / CCP §§ 1005 and 2024.020.
LDTMS discovery motions in accordance with the last day the Court hears noticed motions / No later than 16 court days + 5 calendar days b/f discovery motion cut-off. **Check court website**[INSERT DATE]
LDTMS motion re: expert discovery / No later than 16 court days + 5 calendar days b/f expert discovery motion cut-off. / CCP §§ 1005, 2024.030.
LDTMS Notice of Deposition (including documents) / No later than 15 days b/f discovery cut-off. / CCP § 2024.020 and 2025.270.
LDTPS Deposition Subpoena for Prod. of Business Records only / No later than 15 days b/f discovery Cut-off. / CCP § 2020.410(c).
LDTPS general motions to be heard b/f motion cut-off (excluding discovery motions, motion for summary judgment/adjudication and motions in limine) / No later than 16 court days b/f general law and motion cut-off. / CCP § 1005.
LDTPS motion to bifurcate/sever claims or issues at trial (Note: does not include same motion based on common law or court’s sua sponte powers) / No later than 16 court days b/f general law and motion cut-off. / CCP §§ 598 and 1005.
LDTMS general motions to be heard b/f motion cut-off (excluding discovery motions, motion for summary judgment/adjudication and motions in limine) / No later than 16 court days + 5 calendar days b/f general law and motion cut-off. / CCP § 1005.
LDTMS motion to bifurcate/sever claims or issues at trial (Note: does not include same motion based on common law or court’s sua sponte powers) / No later than 16 court days + 5 calendar days b/f general law and motion cut-off. / CCP §§ 598 and 1005.
60 DAYS TO TRIAL / Whatever date it falls on / Internal deadline.
LDTPS writtenand updating discovery / No later than 30 days b/f discovery cut-off. / CCP §§ 2024.020 and 2025, et seq.
LDTMS written and updating discovery / No later than 35 days b/f discovery cut-off. / CCP §§ 1013, 2016.050, 2024.020 and 2025, et seq.
LDT order updated records obtained through subpoenas / 50 days b/f discovery cut-off. / Internal deadline.
LDTPS serve Deposition Subpoena for Production of consumer/employment records only and consumer notice on party or non-party / No later than 25 days b/f discovery Cut-off / CCP §§ 1985.3 and 1985.6
LDT send meet and confer letter re: discovery motions b/f trial / 30 days b/f discovery motion cut-off. / Internal deadline.
Post-mediation status conference / Set by court
LDT complete mediation / Set by court
LDTMS supplemental expert designation and declaration / No later than 20 days after service of initial designation and declaration. If falls on Sat., Sun. or Holiday, then next court day. / CCP §§ 2016.060 and 2034.280.
LDTMS expert designation and declaration / No later than 50 days b/f trial. If falls on Sat., Sun. or Holiday, then next court day. / CCP §§ 2016.060 and 2034.230.
LDTMS demand for exchange of expert witness information / No later than 70 days b/f trial or 10 days after initial trial date set. If falls on Sat., Sun. or Holiday, then next court day. / CCP §§ 2016.060 and 2034.220.
90 DAYS TO TRIAL / Whatever date it falls on / Internal deadline.
LDTMS serve written and updating discovery / 65 days b/f Discovery Cut-off. / Internal deadline.
LDTPS motion for summary judgment/adjudication / No later than 105 days b/f trial. / CCP § 437c.
LDTMS motion for summary judgment/adjudication / No later than 110 days b/f trial. / CCP § 437c.
Mandatory Settlement Conference (MSC) / Set by Court.
LDTF Confidential MSC statement / No later than 5 days b/f MSC. / OCSC, Local Rule 316, subd. (F)
Defendant’s LDTS Settlement Demand on Plaintiff / No later than 5 days after receipt of Plaintiff’s settlement demand / OCSC, Local Rule 316, subd. (F)
Plaintiff’s LDTS Settlement Demand on all Defendants / No later than 5 days b/f MSC. / OCSC, Local Rule 316, subd. (F)
120 DAYS TO TRIAL / Internal deadline.
Review file for possible motion for summary judgment/adjudication. / 140 days b/f trial. / Internal deadline.
Case Management Conference / Set by Court at outset of case.
LDTF&MS case management conference statement / No later than 15 days b/f CMC
LDT meet and confer with opposing counsel in person or by telephone to consider the issues identified in Cal. R. Ct., rule 212, subds. (e) and (f). / No later than 30 days b/f CMC / OCSC rule 450.
150 DAYS TO TRIAL / Whatever date it falls on / Internal deadline.
LDTMS Statement of Damages / No later than 180 days before trial / Internal deadline.
LDTMS Bill of Particulars / No later than 180 days before trial / Internal deadline.
LDT Meet & Confer: (i) to discuss facts which are presently available to support the allegations of the pleadings; (ii) to discuss possible settlement of the action including possible arbitration, and (iii) to exchange preliminary schedules of discovery. / Within 20 days of the responsive pleading by the first responding defendant. / OCSC, Local Rule 315
180 DAYS TO TRIAL / Whatever date it falls on / Internal deadline.
210 DAYS TO TRIAL / Whatever date it falls on / Internal deadline.
ATTORNEY WORK PRODUCT
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Orange County Superior Court
Amended June 30, 2009