Pretrial Preparation and Deadlines
Pretrial preparation should begin when you receive your trial date. That's when the deadline clock starts ticking. The first deadline occurs 75 days before trial. Check your calendar and determine that date. Seventy-five days represents the 30 days you have to respond to any formal discovery request plus the 45 day deadline for filing discovery motions. Discovery motions are generally motions to compel your uncooperative opponent to answer your requests, but they may include other types of motions as well. The rules say you may not submit discovery motions less than 45 days before the trial. If you want time to react to possible stone-walling by your opponent (and you do), your last opportunity to serve discovery on them is 75 days before trial because they have 30 days to reply. As a practical matter, it’s not a good idea to wait that long. You should have at least 120 days between the trial date announcement and trial. If you haven’t completed informal discovery ...
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