Back in June, I wrote this post about the nearly stalled status of litigation since the pandemic began. While some courts are still incredibly backlogged (and, will give priority to criminal cases once they bear any semblance of “back to normal”), other courts have been surprisingly quick to adopt new procedures and technology in the latter half of 2020. As trials, hearings, and even status conferences have resumed in most districts we practice in, we expect litigation in general to slowly but surely pick back up throughout 2021.

In California, “case management conferences” are scheduled in every case – these are fairly quick and simple procedures where the parties advise the court on status. Typically, once all defendants have been served and/or filed answers, the court will set a trial date about 1-2 years out. This trial date triggers a host of pre-trial deadlines, perhaps the most important of which, is the deadline to complete discovery (30 days before the trial date, although you want to make sure you serve your last round of requests well before then in case motion practice is necessary to obtain responses). Discovery is where the parties will spend the bulk of their time and

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