Before filing a motion to compel discovery responses, the parties must engage in a “reasonable and good faith attempt at an informal resolution of each issue presented by the motion.” CCP §2016.040. What constitutes a good faith meet-and-confer effort depends on a variety of factors.
In the past, most California superior courts routinely held trial-setting, pretrial, arbitration status, and status conferences. Delay reduction rules put a stop to this practice, consolidating all of these into a comprehensive conference that occurs in the first 180 days after the complaint is filed. Cal Rules of Ct 3.721. And woe to any attorney who comes to the conference unprepared! Take some of the stress out of preparing for your next case management conference by using these four steps.
Right before the trial begins, trial judges routinely invite counsel into chambers to explore areas of agreement and disagreement, anticipated trial objections, and how certain matters will be handled at trial. These conversations may feel informal, but they are far from it—get any argument or decisions made in chambers on the record.