§ 2024.010.Completion date

The deadlines in this chapter turn on when discovery is "completed," so the chapter needs a fixed, workable answer to what that word means. This section supplies it in two parts: for written discovery, completion happens on the day the response is due, and for a deposition, completion happens on the day it begins.

Notice what the definition does not require: it does not demand that every document change hands or that a deposition finish before the cutoff date arrives. A party can serve a set of interrogatories, or notice a deposition, timed so that the response is due, or the deposition begins, on or before the applicable cutoff, and the discovery counts as completed on schedule even if the response arrives, or the deposition wraps up, a few days later. That fixed reference point is what lets litigants and courts calculate compliance with the completion deadlines set out in the rest of this chapter without arguing over how far along the underlying discovery got.