How to Create a Comprehensive Litigation Calendar from Complaint to Trial

When a trial date is assigned, experienced trial attorneys immediately work backward to establish a Master Litigation Schedule.

Key Milestones in the Trial Calendar Countdown

1. Initial Disclosures & Case Management Conference (CMC): Typically 60 to 90 days following initial appearance.
2. Non-Expert Discovery Cutoff: Typically 30 calendar days before the initial trial date (e.g., California CCP § 2024.020).
3. Expert Witness Disclosure & Exchange: Typically 50 days before the initial trial date (e.g., California CCP § 2034.230).
4. Dispositive Motions (Summary Judgment / Adjudication): Hearing must be scheduled at least 30 days before trial, with moving papers served 75 days before hearing (CCP § 437c)—meaning the motion must often be filed 105+ days prior to trial!
5. Pretrial Conference & Motions in Limine: Usually 14 to 21 days before trial date.
6. Jury Instructions & Exhibit Lists: Due at the final trial readiness conference.