Trial Preparation Calendar

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, Noon of Friday b/f trial. OCSC Local Rule 450.

motions in limine and oppositions thereto, joint list of controverted issues, jury

instructions) 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.

ATTORNEY WORK PRODUCT Page 1 of 7 Orange County Superior Court Amended June 30, 2009 LDT hold Issue Conference with opposing counsel, and: No later than 10 days b/f trial. OCSC Local Rule 450.

 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- 10 days b/f trial. Internal deadline. party witnesses 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 CCP §§ 2016.060 and

falls on Sat., Sun. or Holiday, 2024.030.

then next court day. 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 CCP §§ 2016.060 and

then next court day. LDTPS Notice of Trial No later than 15 days b/f trial. CCP § 594. LDTPS Trial Subpoenas for Personal Appearance and Production of 15 days b/f trial. Internal deadline.

Documents

ATTORNEY WORK PRODUCT Page 2 of 7 Orange County Superior Court Amended June 30, 2009 DISCOVERY MOTION CUT-OFF 15 days b/f trial. If falls on Sat., CCP §§ 2016.060 and

Sun. or Holiday, then next court 2024.020

day. ID: LDT hold Issue Conference and exchange trial documents and related 20 days b/f trial. Internal deadline. motions to comply with Local Rule 450 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 No later than 16 court days b/f CCP § 1005; OCSC Rule

Local Rule 450 trial. 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 No later than 16 court days + 5 CCP § 1005; OCSC

Local Rule 450 calendar days b/f trial. 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., CCP §§ 2016.060 and

Sun. or Holiday, then next court 2024.020.

day. GENERAL LAW AND MOTION CUT-OFF (except discovery motions, No later than 30 days b/f trial. Internal deadline. motions for summary judgment/adjudication and motions in limine) LD for hearing on motion to bifurcate/sever claims or issues at trial (Note: No later than 30 days b/f trial. CCP § 598. does not include common law motions or court’s powers to bifurcate/sever sua sponte) LDTPS Notice of Deposition—Expert Only No later than 10 days b/f expert CCP § 2034.460.

discovery cut-off. LDTMS Notice of Deposition—Expert Only No later than 15 days b/f expert CCP § 2034.460.

ATTORNEY WORK PRODUCT Page 3 of 7 Orange County Superior Court Amended June 30, 2009 discovery cut-off. 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 CCP §§ 1005, 2024.030.

expert discovery motion cut-off . LDTPS discovery motions No later than 16 court days b/f CCP §§ 1005, 2016.60

discovery motion cut-off. and 2024.020. LDTPS discovery motions in accordance with the last day the Court hears No later than 16 court days b/f CCP §§ 1005, 2016.60 noticed motions last day of week court hears and 2024.020.

motions. **Check court

website** [INSERT DATE] LDTPS Notice of Deposition (including documents) No later than 10 days b/f CCP §§ 2024.020 and

discovery cut-off 2025.270. LDTPS Deposition Subpoena for Personal Appearance and Production of No later than 10 days b/f Internal Deadline: CCP §

Documents or Personal Appearance Only (excludes duces tecum) discovery cut-off 2020.220(a)

—“reasonable time” LDTMS discovery motions No later than 16 court days + 5 CCP §§ 1005 and

calendar days b/f discovery 2024.020.

motion cut-off. LDTMS discovery motions in accordance with the last day the Court hears No later than 16 court days + 5 noticed motions 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 CCP §§ 1005, 2024.030.

ATTORNEY WORK PRODUCT Page 4 of 7 Orange County Superior Court Amended June 30, 2009 calendar days b/f expert

discovery motion cut-off. LDTMS Notice of Deposition (including documents) No later than 15 days b/f CCP § 2024.020 and

discovery cut-off. 2025.270. LDTPS Deposition Subpoena for Prod. of Business Records only No later than 15 days b/f CCP § 2020.410(c).

discovery Cut-off. LDTPS general motions to be heard b/f motion cut-off (excluding discovery No later than 16 court days b/f CCP § 1005. motions, motion for summary judgment/adjudication and motions in limine) general law and motion cut-off. LDTPS motion to bifurcate/sever claims or issues at trial (Note: does not No later than 16 court days b/f CCP §§ 598 and 1005. include same motion based on common law or court’s sua sponte powers) general law and motion cut-off. LDTMS general motions to be heard b/f motion cut-off (excluding discovery No later than 16 court days + 5 CCP § 1005. motions, motion for summary judgment/adjudication and motions in limine) calendar days b/f general law

and motion cut-off. LDTMS motion to bifurcate/sever claims or issues at trial (Note: does not No later than 16 court days + 5 CCP §§ 598 and 1005. include same motion based on common law or court’s sua sponte powers) calendar days b/f general law

and motion cut-off. 60 DAYS TO TRIAL Whatever date it falls on Internal deadline. LDTPS written and updating discovery No later than 30 days b/f CCP §§ 2024.020 and

discovery cut-off. 2025, et seq. LDTMS written and updating discovery No later than 35 days b/f CCP §§ 1013, 2016.050,

discovery cut-off. 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 No later than 25 days b/f CCP §§ 1985.3 and

ATTORNEY WORK PRODUCT Page 5 of 7 Orange County Superior Court Amended June 30, 2009 records only and consumer notice on party or non-party discovery Cut-off 1985.6 LDT send meet and confer letter re: discovery motions b/f trial 30 days b/f discovery motion cut- Internal deadline.

off. 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 CCP §§ 2016.060 and

of initial designation and 2034.280.

declaration. If falls on Sat., Sun.

or Holiday, then next court day. LDTMS expert designation and declaration No later than 50 days b/f trial. If CCP §§ 2016.060 and

then next court day. LDTMS demand for exchange of expert witness information No later than 70 days b/f trial or CCP §§ 2016.060 and

10 days after initial trial date set. 2034.220.

If falls on Sat., Sun. or Holiday,

then next court day. 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 OCSC, Local Rule 316,

of Plaintiff’s settlement demand subd. (F) Plaintiff’s LDTS Settlement Demand on all Defendants No later than 5 days b/f MSC. OCSC, Local Rule 316,

ATTORNEY WORK PRODUCT Page 6 of 7 Orange County Superior Court Amended June 30, 2009 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 No later than 30 days b/f CMC OCSC rule 450. consider the issues identified in Cal. R. Ct., rule 212, subds. (e) and (f). 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 Within 20 days of the responsive OCSC, Local Rule 315 support the allegations of the pleadings; (ii) to discuss possible settlement of pleading by the first responding the action including possible arbitration, and (iii) to exchange preliminary defendant. schedules of discovery. 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 Page 7 of 7 Orange County Superior Court Amended June 30, 2009