California Civil Litigation Deadlines Quick Reference

Statute of Limitations

• Personal Injury: 2 years (CCP § 335.1)
• Property Damage: 3 years (CCP § 338)
• Breach of Written Contract: 4 years (CCP § 337)
• Breach of Oral Contract: 2 years (CCP § 339(1))
• Fraud: 3 years (CCP § 338(d))
• Medical Malpractice: 1 year from discovery, 3 years maximum (CCP § 340.5)
• Legal Malpractice: 1 year from discovery, 4 years maximum (CCP § 340.6)

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)