Discovery
Demands, responses, verifications, depositions, and the motions each of them produces.
The sequence
- Day 0Demand servedThe manner of service fixes every extension that follows.
- +30 daysResponse duePlus the service extension. Serving late waives every objection, privilege included.
- With itVerificationObjections need none, substantive answers do. This is the fault line.
- +45 daysMotion to compel furtherQuasi-jurisdictional, and only if a verified response started the clock.
- Any timeWritten extensionIt has to recite the original date, the new date, and the sets it covers.
This sequence is the shape of the stage, not a calculator. Dates come from calcourtdeadlines.com.
Guides in this stage5
- The 45-day deadline to compel furtherQuasi-jurisdictional. Unverified responses may never have started the clock.
- When opposing counsel stops respondingNo response and a bad response are two different motions on two different clocks. The cheap one has no 45-day limit and needs no meet and confer declaration, and almost nobody files it.
- Auditing a meet and confer letterThe dangerous ones are mostly right. The correct parts pressure you into conceding the parts that are wrong.
- When you cannot instruct your client not to answerIrrelevance is not a ground. The objection everyone makes is preserved anyway, and the one they skip is the only one that waives.
- What is actually privileged at a depositionThe tender defines the medical waiver, not the complaint. The lien-doctor referral is not privileged, and immigration status is the one clean instruction.