Re: Discovery deadline

Do you mean written interrogatories? The answer depends on many different facts, including, among others, in which court your action is pending, court orders in your action, how you plan to serve the discovery, etc. If you are attempting to represent yourself, please understand there are an infinite amount of things you must consider. For instance, do you plan to use the interrogatory responses only at trial, or perhaps also in a motion for summary judgment or in preparation for a deposition or something else. You might have to serve additional interrogatories based on the responses to your first set or you might need additional time to compel answers. There is a tremendous amount of strategy and know-how required to prosecute or defend an action.

Re: Discovery deadline

Mr. Gorski is correct. It depends on a number of factors. You can conduct discovery until the 30th day before trial, but if you have not completed the discovery process before that time, you will not leave yourself any time to: (1) review the responses to the discovery before trial; (2) bring any motion to compel further responses which may be necessary (remember, parties do not always provide full, complete and meaningful responses simply because you ask them to or they are required to by the code); (3) conduct further written discovery; (4) take depositions (which must begin before the 30-day cut-off); or (5) arrange for any expert witnesses and conduct expert discovery.

If you haven't completed discovery substantially before the 30-day cut-off, you are likely not to complete discovery at all. In fact, you should generally plan on completing all discovery during the last 100 days before trial.