CivPro: Timing Rules Flashcards
service of process
within 90 days of filing complaint
response to waiver of service
defendant must have at least 30 days after receiving request for waiver of service
foreign defendant: 60 days
answer
within 21 days of service
answer with service waived
within 60 days of waiver request
if foreign: 90 days
pre-answer motion
within 21 days of service
answer after denial of pre-answer motion
within 14 days of court denial
reply to answer
within 21 days of answer
amended pleading as of right
within 21 days of service of original pleading
if responsive pleading required: within 21 days of service of responsive pleading or MTD, whichever is earlier
response to amended pleading
the longer of 14 days OR time left to respond to original pleading
impleader as of right
within 14 days of service of answer
jury demand
within 14 days of service of last pleading
removal
within 30 days of receiving complaint (original or amended) of removable case
discovery conference
as soon as practicable, at least 21 days before scheduling conference
mandatory initial disclosures
within 14 days of discovery conference
expert testimony disclosure
90 days before trial
if rebuttal expert: 30 days after other side’s disclosure
pretrial disclosures
30 days before trial
objections to admissibility of depo, docs, or exhibits
within 14 days of disclosure
production of documents
within 30 days of request or 30 days of discovery conference, whichever is later
answers and objections to interrogatories
within 30 days of service
answers and objections to admissions
within 30 days of service
pretrial
30 days before trial
objections to pretrial
within 14 days of pretrial disclosures
motion for summary judgment
after pleadings until 30 days after close of discovery
motion for JMOL
after party presents its case on the matter but BEFORE submitted to jury
