§ 2024.060.Written agreements to extend time or reopen discovery

Not every extension of a discovery deadline needs a motion. This section gives parties a private alternative to the noticed-motion process in Section 2024.050: with the consent of anyone the agreement would affect, the parties can agree among themselves to extend the time to complete discovery, extend the time to have a discovery motion heard, or reopen discovery once a new trial date is in place. The negotiation behind that agreement can be informal, but the agreement itself has to be confirmed in writing that specifies the extended date, so there is no dispute later about exactly what the parties agreed to.

The one hard limit on this flexibility protects the court's own calendar. Whatever the parties agree to about their discovery timeline, that agreement cannot itself require the court to continue or postpone the trial. If an extended discovery schedule would bump up against the existing trial date, the parties still need the court's separate approval to move that date; a stipulation under this section reaches only the discovery deadlines, not the trial itself.