California Civil Litigation Deadlines – Comprehensive Reference Guide
Service of Process
- Plaintiffs are expected to serve all defendants within 60 days of filing the complaint under CRC 3.110(b).
- Although CCP § 583.210(a) allows service within 3 years, courts enforce the 60-day CRC rule as the practical deadline.
- When adding a defendant by amendment, service should be completed within 30 days of the amended filing (CRC 3.110(b)).
- Proof of service of the summons and complaint must be filed within 60 days from filing the complaint (CRC 3.110(c)).
- CCP § 583.210(b) also requires filing proof within 60 days of service.
- A defendant must file an answer, demurrer, or motion within 30 days after service of the summons and complaint (CCP § 412.20(a)(3)).
- A demurrer to an answer must be filed within 10 days after service of the answer (CCP § 430.40(b)), unless extended by stipulation or court order.
Discovery Deadlines
- Available 10 days after service of the complaint (CCP § 2030.020).
- Defendants may serve discovery immediately (CCP § 2030.020).
- Depositions may begin 20 days after service of the summons and complaint (CCP § 2025.210).
- Must be served at least 15 days on the consumer (20 actual days before production) and 5 days on the records custodian (CCP §§ 1985.3, 2020.220(a)).
- Must be served 10 days on the employee and 5 days on the custodian before production (CCP § 1985.6).
- Must be served at least 5 days before production (CCP § 1985.3(g)).
- Must be filed within 45 days of receiving responses (CCP § 2030.300).
- Responses due 30 days (+5 days if mailed) (CCP §§ 2030.260, 2031.260).
- Discovery closes 30 days before trial, excluding expert discovery (CCP § 2024.020).
- 15 days before trial (CCP § 2024.020).
- 15 days before arbitration hearing (CRC 3.822).
- Must be set at least 10 days after service of notice (+5 if notice served by mail) (CCP §§ 1013, 2025.270).
- Must be served at least 3 calendar days before deposition (+5 if mailed) (CCP § 2025.410).
- Subpoena must be served at least 20 days before deposition (CCP § 2025.270).
- Only 5 days’ notice is required (CCP § 2025.270(b)).
Expert Discovery
- Must be made 70 days before trial, or within 10 days of trial setting, whichever is closer (CCP § 2034.220).
- Must be exchanged 50 days before trial, or 20 days after demand, whichever is closer (CCP § 2034.230).
- Due within 20 days after the initial exchange (CCP § 2034.280).
- May proceed upon receipt of expert witness list (CCP § 2034.410).
- Available 10 days after service of the complaint (CCP § 2030.020).
- Defendants may serve discovery immediately (CCP § 2030.020).
Arbitration Deadlines
- Must issue an award within 10 days after arbitration conclusion (or 20 days if the arbitrator formally requests additional time) (CRC 3.825).
- A request for trial after arbitration must be filed within 60 days of service of arbitration award (CRC 3.826).
- 15 days before arbitration hearing (CRC 3.822).
Trial Deadlines
- Non-expert discovery closes 30 days before trial (CCP § 2024.020).
- 70 days before trial (CCP § 2034.220).
- 50 days before trial (CCP § 2034.230).
- May be made up to 10 days before trial (CCP § 998).
- Must be served 10 days before trial (CCP § 1987(b)).
- Must be served 20 days before trial (CCP § 1987(c)).
- Must be served 5 days before trial (CCP § 1987(c)).
Motions
- Must be served and filed 16 court days before the hearing (CCP § 1005(b)).
- Extra time applies when served by mail or electronic means.
- Due 9 court days before the hearing (CCP § 1005(b)).
- Due 5 court days before the hearing (CCP § 1005(b)).
- Notice must be provided by 10:00 a.m. the court day before the hearing (CRC 3.1203).
- Required for briefs exceeding 10 pages (CRC 3.1113(f)).
Motions for Summary Judgment / Adjudication
- Must be served 81 days before hearing (adjusted by AB 2049; modifies CCP § 437c(a))
- 20 days before hearing (CCP § 437c(b)(2)).
- 11 days before hearing (CCP § 437c(b)(3)).
- Must be heard 30+ days before trial (CCP § 437c(a)).
Motion for Reconsideration (NEW)
- Must be filed within 10 days after service of notice of entry of the order being challenged (CCP § 1008(a)).
- Must show new or different facts, circumstances, or law that existed but were not presented earlier for justifiable reasons.
- Repetitive motions without permission are prohibited (CCP § 1008(e))
Statute of Limitation (Select)
Appeals — California State Court
Deadlines are jurisdictional—missing a deadline eliminates appellate rights.
Final Judgment Appeals
- 60 days after service of Notice of Entry of Judgment (CRC 8.104(a)(1)(A)).
- If no notice served: 180 days after entry (CRC 8.104(a)(1)(C)).
Appeals from Orders Granting Summary Judgment
- Treated the same as judgments: 60 days after notice or 180 days after entry.
Appeals from Post-Judgement Orders
- Deadline: 60 days after service of Notice of Entry (CRC 8.104).
Appeals from Sanctions Orders
- Sanctions over $5,000 → directly appealable (CCP § 904.1(b)).
- Sanctions under $5,000 → not separately appealable; reviewable after final judgment.
Discovery Orders
- Not appealable.
- Must be challenged by writ petition, ideally within 60 days, but earlier is recommended.
Preliminary Injunction Orders
- Immediately appealable (CCP § 904.1(a)(6))
- Deadline: 60 days after notice of entry.
Anti - SLAPP Orders
- Appeal permitted for both grants and denials (CCP § 425.16(i))
- Deadline: 60 days after notice
Class Certification Orders
- Not appealable; only by writ.
Late-Served Notice of Entry
- If the clerk or party never serves notice, appellate deadline defaults to 180 days from entry.
Publications
Use of This Website & No Attorney–Client Relationship
Use of this website does not create an attorney–client relationship between you and BAKH LAW GROUP, PC, JONATHAN BAKHSHESHIAN, ESQ., or any of its attorneys. Communication through this site—including email or contact forms—does not constitute confidential or privileged communications. Confidential information should not be submitted until after a proper, written engagement agreement is executed.
No Legal Advice Intended
The content on this website is provided for general informational purposes only and should not be construed as legal advice tailored to your specific situation. You should not act or refrain from acting based solely on any information contained here. Consult a qualified attorney for advice specific to your circumstances.
Attorney Advertising & Compliance
This website may constitute attorney advertising under California Rules of Professional Conduct. Nothing on this site guarantees a particular outcome. References to past results or case examples do not predict future results. No warranties or promises, express or implied, are made about the outcome of legal matters. Such advertisements are provided by Jonathan Bakhsheshian, Esq. SBN: 304282.
Disclaimers Regarding Testimonials & Endorsements
Any testimonials or client endorsements displayed on this site do not guarantee success in similar cases, and may not reflect the experience of all clients. They are not intended to create unjustified expectations. The total advertised amount recovered and the representative verdicts and settlement are derived from the total recoveries achieved by Jonathan Bakhsheshian and the attorneys of BAKH LAW GROUP, PC, while affiliated with various law firms. These include recoveries achieved through efforts with other lawyers at such firms and through affiliation with co-counsel from outside law firms.
Privacy & External Links
While we endeavor to display accurate and up-to-date information, BAKH LAW GROUP, PC disclaims all liability in connection with third-party websites that may be linked from our site. We are not responsible for their accuracy or content.
Jurisdiction & Office Location
BAKH LAW GROUP, PC is licensed to practice law in California only. Information on this site may not reflect the most current legal developments or be applicable in other jurisdictions.
Contact Us for Representation
Your use of this website does not obligate us to provide legal services. We will only enter into an attorney–client relationship upon mutual agreement, including receipt of a signed engagement letter and required disclosures.
