TRIAL PREPARATION CALENDAR
Flora Wilhelmi v. Health Net Life Ins. Co.Matter No.: / 229.01
Court: / LASC—Central
Case No.: / BC318591
Dept.: / C56
Judge: / Jane L. Johnson
Action Filed: / July 16, 2004
Date Prepared: / November 17, 2006
Date / Deadline / Calendar / Rule
TRIAL
Final Status Conference / Not more than 10 days b/f trial / Set by Court. LASC Local Rule 7.9(h)
LDT to file and exchange with opposing counsel:
- List of pre-marked exhibits;
- Jury instruction requests (If BAJI, list will suffice; If changes to BAJI, submit proposed changes);
- Trial witness lists;
- Proposed short statement of the case; and
- Other various trial docs.
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-party witnesses / No later than 10 days b/f trial / Internal deadline
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 / CCP § 2024.030.
LDT exchange trial docs / No later than 10 days b/f trial / Internal deadline
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 / CCP § 2034
LDTPS Notice of Trial / No later than 15 days b/f trial / CCP § 594
LDTPS Trial Subpoenas for Personal Appearance and Production of Documents / No later than 15 days b/f trial / Internal deadline
DISCOVERY MOTION CUT-OFF / 15 days b/f trial. If falls on Sat., Sun. or Holiday, then next court day. / CCP § 2024.
LDT exchange trial documents to comply with Local Rule 7.9(h) / 10 days b/f FSC / 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 at Final Status Conference) to comply with LASC Local Rule 7.9(h). / No later than 16 court days b/f FSC. / CCP § 1005; LASC rule 7.9(h).
LDT meet & confer for proposed MILs / No later than 25 days b/f FSC / Internal deadline; LASC rule 8.92(a)
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 at Final Status Conference) to comply with LASC Local Rule 7.9(h). / No later than 16 court days + 5 calendar days b/f FSC. / CCP § 1005; LASC rule 7.9(h).
30 DAYS TO TRIAL / Whatever day it falls on / Internal deadline.
DISCOVERY CUT-OFF / 30 days b/f trial. If falls on Sat., Sun. or Holiday, then next court day. / CCP §§ 2016.060 and 2024.020.
GENERAL LAW AND MOTION CUT-OFF (except discovery motions, motions for summary judgment/adjudication and motions in limine) / No later than 30 days b/f trial / Internal deadline
LD for hearing on motion to bifurcate/sever claims or issues at trial (Note: does not include common law motions or court’s sua sponte powers.) / No later than 30 days b/f trial / CCP § 598
LD for hearing on motion to bifurcate/sever claims or issues per local rules / Date of FSC / LASC rule 7.9(h)
LD for hearing on motion for summary judgment/adjudication / No later than 30 days b/f trial / CCP § 437c
LDTPS Notice of Deposition—Expert Only / No later than 10 days b/f expert discovery cut-off. / CCP § 2034.460.
LDTMS Notice of Deposition—Expert Only / No later than 15 days b/f expert discovery cut-off. / CCP § 2034.460.
LDTPS motion re: expert discovery / No later than 16 court days b/f expert motion cut-off . / CCP §§ 1005, 2024.030.
LDTPS discovery motions / No later than 16 court days b/f disc. motion cut-off . / CCP §§ 1005, 2016.60 and 2024.020.
LDTPS Notice of Deposition (including documents) / No later than 10 days b/f Disc. Cut-off / CCP §§ 2024.020 and 2025.270.
LDTPS Deposition Subpoena for Personal Appearance and Production of Documents or Personal Appearance Only (excludes duces tecum) / 10 days b/f disc. Cut-off / Internal Deadline: CCP § 2020.220(a)—“reasonable time”, e.g. 10 days
LDTMS discovery motions / No later than 16 court days + 5 calendar days b/f disc. motion cut-off. / CCP §§ 1005, 2016.60 and 2024.020.
LDTMS motion re: expert discovery / No later than 16 court days + 5 calendar days b/f expert motion cut-off. / CCP §§ 1005, 2024.030.
LDTMS Notice of Deposition (including documents) / No later than 15 days b/f Disc. Cut-off / CCP § 2024.020 and 2025.270.
LDTPS Deposition Subpoena for Prod. of Business Records only / No later than 15 days b/f disc. Cut-off. / CCP § 2020.410(c).
LDTPS general motions to be heard b/f motion cut-off (excluding discovery motions, motions in limine and motion for summary judgment/adjudication) / No later than 16 court days b/f general motion cut-off. / CCP § 1005.
LDTPS motion to sever or bifurcate (Note: does not include same motion based on common law or court’s sua sponte powers) / No later than 16 court days b/f general motion cut-off. / CCP §§ 598, 1005.
LDTPS motion to sever or bifurcate per local rules / No later than 16 court days b/f FSC / LASC rule 7.9(h)
LDTMS general motions to be heard b/f motion cut-off (excluding discovery motions, motions in limine and motion for summary judgment/adjudication) / No later than 16 court days + 5 calendar days b/f general motion cut-off. / CCP § 1005.
LDTMS motion to sever or bifurcate / No later than 16 court days + 5 calendar days b/f general motion cut-off. / CCP §§ 598, 1005
LDTMS motion to sever or bifurcate per local rules / No later than 16 court days + 5 calendar days b/f FSC / LASC rule 7.9(h)
60 DAYS TO TRIAL / Whatever day it falls on / Internal deadline.
LDTPS written discovery / No later than 30 days b/f Disc. Cut-off / CCP §§ 2024.020 and 2025, et seq.
LDTPS updating discovery / No later than 30 days b/f Disc. Cut-off / CCP §§ 2024.020 and 2025, et seq.
LDTMS written discovery / No later than 35 days b/f Disc. Cut-off / CCP §§ 1013, 2016.050, 2024.020 and 2025, et seq.
LDTMS updating discovery / No later than 35 days b/f Disc. Cut-off / CCP §§ 1013, 2016.050, 2024.020 and 2025, et seq.
LDT order updated medical or other subpoenaed records / 50 days b/f Disc. Cut-off / Internal deadline
LDTPS Deposition Subpoena for Production of consumer/employment records only and consumer notice on party or non-party / No later than 55 days b/f disc. Cut-off / CCP §§ 1985.3 and 1985.6
LDT send meet and confer letter re: discovery motions b/f trial / 30 days b/f Disc. Motion Cut-off / Internal deadline
None / Post-Mediation Status Conference (to be vacated by Court if statement of compliance filed beforehand) / Set by Court
N/A / LDT Complete Mediation. / Set by Court.
LDTMS supplemental expert designation and declaration / 20 days after mail service of initial designation and declaration. / CCP § 2034.280.
LDTMS expert designation and declaration / No later than 50 days b/f trial / CCP § 2034.230.
LDTMS demand for exchange of expert witness information / No later than 70 days b/f trial / CCP § 2034.230.
90 DAYS TO TRIAL / Whatever day it falls on / Internal deadline.
LDTMS serve written discovery / 65 days b/f Disc. Cut-off / Internal deadline
LDTMS serve updating discovery / 65 days b/f Disc. 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
None / Mandatory Settlement Conference / Set by Court.
N/A / LDTF Confidential MSC statement / No later than 5 days b/f MSC / LASC Local Rule 7.9(e)
120 DAYS TO TRIAL / Whatever day it falls on / Internal deadline
Review file for possible motion for summary judgment/adjudication. / 140 days b/f trial / Internal deadline
150 DAYS TO TRIAL / Whatever day 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.
180 DAYS TO TRIAL / Whatever day it falls on / Internal deadline
210 DAYS TO TRIAL / Whatever day it falls on / Internal deadline
Case Management Conference / No later than 180 days after filing of complaint / LASC Local Rule 7.9(a)(1)
LDTF&S case management conference statement / No later than 15 days b/f CMC / LASC Local Rule 7.9(b)(2)
LDT meet and confer with opposing counsel in person or by telephone to consider the issues identified in Cal. R. Ct., rule 212, subds. (e) and (f). / No later than 30 days b/f CMC / LASC Local Rule 7.9(b)(1).
ATTORNEY WORK PRODUCT
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Los Angeles Superior Court
Amended July 2006