Civil Litigation Deadlines Quick Guide (California)

California Civil Litigation Deadlines Quick Reference

Last updated: September 2026

Statute of Limitations


Serving the Complaint

  • Service of Complaint: Within 60 days after filing the complaint (CRC 3.110(b))
  • Filing Proof of Service: Within 60 days after filing the complaint (CRC 3.110(b))

Responsive Pleadings

  • Defendant's Response (Answer, Demurrer, or Motion to Strike): 30 days from date of personal service (CCP § 412.20(a)(3))
  • Plaintiff's Opposition to Demurrer/Motion to Strike: 9 court days before hearing (CCP § 1005(b))
  • Defendant's Reply to Opposition: 5 court days before hearing (CCP § 1005(b))

Discovery Deadlines

  • Start of Discovery: Upon service of summons or defendant's appearance (CCP § 2030.020)
  • Responses to Interrogatories, Requests for Admission, Requests for Production: 30 days from service (extended if served by mail; CCP §§ 2030.260, 2031.260, 2033.250)
  • Motions to Compel Discovery Responses: 45 days after receiving inadequate or incomplete responses (CCP §§ 2030.300, 2031.310, 2033.290)

Depositions

  • Notice of Deposition: At least 10 days prior (extended if by mail; CCP § 2025.270)
  • Objections to Deposition Notice: At least 3 calendar days prior (CCP § 2025.410(a))

Expert Witness Discovery

  • Initial Exchange of Expert Witnesses: 50 days before trial date or 20 days after demand (CCP § 2034.230(b))
  • Supplemental Expert Disclosure: 20 days after initial exchange (CCP § 2034.280)
  • Completion of Expert Depositions: 15 days before initial trial date (CCP § 2024.030)

Arbitration

  • Request for Judicial Arbitration: According to local court rules, typically within 120 days after case management conference
  • Arbitrator's Award: Filed within 10 days after completion of arbitration hearing (CRC 3.825(b))

Motions

  • Motion for Summary Judgment (MSJ/MSA): 81 days before hearing (CCP § 437c(a))
  • Opposition to MSJ/MSA: 20 days before hearing (CCP § 437c(b)(2))
  • Reply in Support of MSJ/MSA: 11 days before hearing (CCP § 437c(b)(4))
  • Motion for New Trial or JNOV: Within 15 days after notice of entry of judgment (CCP §§ 659, 629)

Trial-Related Deadlines

  • Jury Fees Deposit: No later than date of initial Case Management Conference (CCP § 631(c))
  • Demand for Jury Trial: At the initial Case Management Conference or as set by local rules (CCP § 631(f))
  • Trial Brief: Typically due 5 court days before trial (per local court rules)
  • Exchange of Witness & Exhibit Lists: Typically due 20 days before trial (per local court rules)
  • Motions in Limine: Usually due 5 court days before trial or as ordered by the court (per local court rules)

Appeals

  • Notice of Appeal: Within 60 days after service of notice of entry of judgment or order, or 180 days if no notice given (CRC 8.104)



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Deadlines are only half the picture — what you file matters as much as when. See our guide to pleadings and motions in California civil litigation for how complaints, demurrers, and motions to strike fit the timeline above.

Settlement deadlines matter too: a Section 998 offer to compromise must be served at least 10 days before trial and expires after 30 days — timing that can shift costs dramatically.

Deadlines in this guide are general rules, and local rules or court orders can shorten them. If a deadline in your case is unclear or already missed, speak with an Irvine business litigation lawyer promptly — relief is often available, but only if you act quickly.

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Kolmogorov Law is committed to answering your questions about Business Litigation, Civil Litigation, Real Estate Litigation, Employment Litigation, Judgment Enforcement, Product Liability, Construction Litigation and Professional Liability issues in Irvine, California. We'll gladly discuss your case with you at your convenience. Contact us today to schedule an appointment.