Civil Litigation Litigation Strategy Pretrial Matters

What to Do a Month Before Trial

You’re 30 days from your trial date. Maybe it’s been a while since you’ve gotten this close, or maybe it’s your first time. Don’t worry—here’s a handy chart setting out what you need to do.

40 to 20 Days Before Trial to Trial Date (TD)
Make sure discovery is complete or obtain extension (CCP §§2024.020(a), 2024.040(b)) TD minus 30
Supplement expert disclosure (CCP §2034.280) TD minus 30, or exchange date plus 20
Move to compel discovery (CCP §2024.020(a)) TD minus 36 if personally served
Prepare for mandatory settlement conference
Prepare trial brief
Prepare motions in limine
Meet with witnesses and prepare for witness testimony
Prepare jury instructions
Prepare questions for jury voir dire
Prepare opening statement
Prepare closing argument
Deposit jury fees (CCP §631) TD minus 25, 365 days after filing, or on/before mandatory settlement conference
Serve notice by mail on parties to attend trial with documents (CCP §§1013, 1987(b)-(c)) TD minus 25 by mail
Serve subpoena on witnesses for trial with consumer records (CCP §1985.3) TD minus 25 if by mail
Move to compel discovery re expert witnesses (CCP §2024.030) TD minus 30 if by mail
Serve notice of trial date (CCP §594) TD minus 20 if by mail
Serve notice on parties to attend trial (CCP §1987) TD minus 15 if by mail

You may want to add a couple of columns to this chart to write in the exact due date for each item and the date on which it was done. This will help keep you organized.

For details on each of these steps, check out CEB’s Preparing for Trial (Action Guide) and California Trial Practice: Civil Procedure During Trial. These titles are part of CEB’s OnLAW Litigation Library.

Other CEBblog™ posts you may find useful:

© The Regents of the University of California, 2018. Unauthorized use and/or duplication of this material without express and written permission from this blog’s author and/or owner is strictly prohibited.

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