Procedural guides

These guides answer the questions people arrive with — how long do I have, what happens if I miss it, how do I undo it — and link down to the rule pages that supply the answers. Each one covers a single jurisdiction and a single task, and states what the rules say rather than what you should do.

Applies in every jurisdiction

• Computing a court deadline: the day you start counting, weekends, holidays, and what mail addsNearly every court deadline follows the same three-step shape — exclude the first day, count every day, extend if the last day is a weekend or holiday. The exceptions are where cases are lost.
• Getting more time to respond: the line between asking early and asking lateAlmost every system asks an easy question if you request an extension before the deadline and a hard one after it. Some deadlines can't be extended at all.
• Post-trial motions: the deadlines that cannot be extendedA motion for a new trial is due 10 days after judgment in North Carolina and Pennsylvania, 28 federally, 30 in Texas and Illinois — and almost nowhere can a court extend it.
• Demanding a jury: the deadline that waives a constitutional right by silenceIn most systems the right to a jury is lost automatically if nobody files a short written demand. The deadline ranges from 10 days to 30 days before trial — and Arizona requires no demand at all.
• Filing-certification sanctions: the 21-day safe harbor, and the states that don't have oneFederal Rule 11 and California's CCP 128.7 let you withdraw a challenged filing within 21 days and avoid sanctions entirely. Most states we cover have no such window.
• Asking for a continuance: good cause, an affidavit, and moving as soon as you knowCourts grant continuances on good cause, usually supported by an affidavit or declaration — and almost every rule punishes delay in asking far more than the reason for asking.
• The limitations defense in a debt case: it only works if you plead itA statute of limitations is an affirmative defense — the court will not raise it for you. If it is not stated in the answer it is generally waived, and the case proceeds as if the debt were timely.
• The motion to compel: confer first, say so in the motion, and expect fees to follow the resultAlmost every motion to compel discovery requires a certification that you conferred in good faith first — and in most systems the losing side pays the other's expenses unless the position was substantially justified.
• Claiming an exemption from garnishment: the deadline is short, and it is not the same in any two statesExempt money is not protected automatically in most states — you have to claim it, on a form, within a window that ranges from five business days to no deadline at all.
• Subpoenaing records: fourteen days to object, and the issuer owes a duty not to burdenA records subpoena rarely requires anyone to appear — and the recipient's objection deadline is the earlier of the compliance date or 14 days after service.
• Challenging defective service: raise it first, or you have agreed to be suedInsufficient service is one of the easiest defenses to win and the easiest to lose — nearly every system waives it unless it is raised in the first motion or the first responsive pleading.
• When the appeal clock starts: finality, entry, and the motions that stop itThe deadline to appeal almost never runs from the day you lost — it runs from entry of a final judgment, and a timely post-judgment motion usually restarts it.

Alabama — Alabama Rules of Civil Procedure

• Responding to an Alabama complaint: 30 days, unless you were served by publicationAlabama Rule 12(a) gives 30 days after service of the summons and complaint to serve an answer — except where service is by publication and a different time applies under the governing procedure.
• Setting aside an Alabama default judgment: 30 days in circuit court, 14 in district — and 7 for evictionsAlabama Rule 55(c) allows a default judgment to be set aside on motion filed within 30 days — but the District Court Rule cuts that to 14 days, and to 7 calendar days in eviction cases.
• The Alabama motion to dismiss: thirty days to answer, ten if the motion failsAlabama gives thirty days to answer a complaint, but only ten days after a Rule 12 motion is denied — and four of the seven enumerated defenses are waived if left out.
• Alabama summary judgment: a narrative summary, ten days out, and two days to opposeAlabama Rule 56 requires a narrative summary of the undisputed facts, serves the motion at least 10 days before the hearing, and gives the opposition only 2 days.
• The Alabama motion to compel: you choose the courtAlabama Rule 37 lets a motion be made in the circuit where the discovery is sought or where the action is pending, and shifts fees both ways.
• Alabama execution: the sheriff must hand you a Form 92 notice, and a claim of exemption stops the saleAlabama Rule 69 requires the clerk to issue a notice of exemption rights on Form 92, and a notarized claim of exemption stays the sale unless the creditor contests it.

Alaska — Alaska Rules of Civil Procedure

• Responding to an Alaska complaint: 20 days, seven days' warning before default, and the loser pays feesAlaska gives 20 days to answer, requires the party seeking default to serve the application on the defaulting party and wait seven days — and Rule 82 awards attorney's fees to the prevailing party as a matter of course.
• Alaska discovery: disclose the factual basis of your case, 30 interrogatories, and three experts per issueAlaska requires initial disclosures broader than the federal ones — including the factual basis of every claim and defense — caps interrogatories at 30, and limits each side to three independent experts per issue.
• Alaska summary judgment: 15 days to oppose, a statement of genuine issues, and a judgment somebody has to draftAlaska Rule 56 runs on the Rule 77 motion calendar — 15 days to oppose, five to reply — requires a memorandum with the motion and a "statement of genuine issues" in opposition, and does not produce a final judgment on its own.
• Amending an Alaska pleading: retype the whole thing, or it is not amendedAlaska Rule 15(e) says no pleading is deemed amended until it has been retyped complete in itself with all exhibits attached — a formatting rule with the force of a validity rule.
• Setting aside an Alaska judgment: one year from notice, not from entry — and bring a proposed judgmentAlaska Rule 60(b) gives six grounds for relief from a judgment, runs its one-year limit from the date of notice under Rule 58.1(c) rather than from entry, and requires a proposed amended judgment with the motion.
• Alaska TROs and injunctions: 10 days, a bond in almost every case, and a surety who has already consented to jurisdictionAlaska Rule 65 caps a TRO without notice at 10 days — shorter than the federal 14 — requires security except from the state, and makes a surety's liability enforceable on motion.
• Alaska costs and attorney's fees: a schedule for the winner, 10 days to claim, and an offer of judgment that can flip the caseAlaska Rule 82 awards the prevailing party attorney's fees by schedule in every civil case, Rule 79 lists the only recoverable costs, and both are waived if not claimed within 10 days.
• The Alaska motion to dismiss: twenty days to answer, ten after a denialAlaska Rule 12(b) carries the familiar seven defenses, gives 20 days to answer, and only 10 days after a motion is denied.

Arizona — Arizona Rules of Civil Procedure

• Responding to an Arizona complaint: 20 days — and a 10-day grace period built into the default ruleArizona gives 20 days to answer. Its default rule then gives something no other state we cover does: default isn't effective until 10 days after the application, and answering inside that window stops it.
• Setting aside an Arizona judgment: six months, not a yearArizona's relief-from-judgment rule is lettered Rule 60(c), and its outer limit for mistake, new evidence and fraud is six months — half the federal and most-state period.
• Arizona's Rule 26.1 disclosure: you have to hand over your case in 30 daysArizona requires each party to disclose its factual basis, legal theories, witnesses, damages computation and documents within 30 days of the responsive pleading — far more than federal initial disclosures.
• The Arizona motion to dismiss: twenty days, and you must phone the other side firstArizona gives only 20 days to answer, and Rule 12(j) requires a good faith consultation certificate on a motion to dismiss — a call or a meeting, not an email.
• Arizona summary judgment: thirty days to respond, and a separate statement of facts with a page limitArizona Rule 56 gives 30 days to respond and 15 to reply, and requires a separate numbered statement of facts capped at 11 pages for the movant and 17 for the opposition.
• The Arizona motion to compel: there is a faster route you are supposed to try firstArizona Rule 37 is expressly subject to Rule 26(d)'s expedited dispute procedure, and every motion must attach a good faith consultation certificate made by phone or in person.
• Arizona execution: fifteen days before anyone can collect, and no discovery during the stayArizona Rule 62(a) stays execution for 15 days after entry, and Rule 69(c) bars post-judgment discovery during that window unless the court orders otherwise.

Arkansas — Arkansas Rules of Civil Procedure

• Responding to an Arkansas complaint: 30 days, 60 if you are incarceratedArkansas Rule 12(a) gives 30 days after service of the summons and complaint to file an answer, 60 days for an incarcerated defendant — and only a court, never a clerk, enters a default judgment.
• Setting aside an Arkansas default judgment: no deadline, but you must show a meritorious defenseArkansas Rule 55(c) sets aside default judgments on four grounds with no stated time limit — but the rule requires a meritorious defense unless the judgment is void.
• The Arkansas motion to compel: failing to supplement is its own sanctionable failureArkansas Rule 37(e) allows sanctions where a party fails to supplement seasonably and another party suffers prejudice — a ground most states leave out.
• The Arkansas motion to dismiss: eight grounds, and the test is factsArkansas Rule 12(b)(6) asks whether the pleading states facts upon which relief can be granted, and adds a parallel-action ground the federal rule lacks.
• Arkansas summary judgment: forty-five days before trial, and the motion must specify the issuesArkansas Rule 56 requires any summary judgment motion to be filed no later than 45 days before trial and to specify the issues on which judgment is sought.

California — California Code of Civil Procedure

• Responding to a California complaint: when the 30 days really starts, and what a demurrer does to itCalifornia gives 30 days to respond — but the clock starts when service is complete, and substituted service isn't complete until the 10th day after mailing. Here's the arithmetic.
• Setting aside a California default: four different routes, four different deadlinesCalifornia doesn't have one motion to vacate. It has discretionary relief, mandatory attorney-fault relief, the lack-of-actual-notice route, and void judgments — each with its own clock.
• Responding to a California eviction: the 10-day clock that isn't 10 daysCCP 1167 gives an unlawful detainer defendant 10 days to respond, excluding weekends and judicial holidays — and 5 more court days if service was by mail. Older pages still say five days.
• Missing a California discovery deadline: the automatic waiver, and how to get it backA late discovery response in California waives every objection — including privilege and work product. The Discovery Act also supplies a specific way to undo that, on two conditions.
• California's 45-day motion-to-compel deadline: when it applies, and when it doesn'tCalifornia gives 45 days to move for further discovery responses, and blowing it waives the right entirely. But the 45 days only runs against a served, verified response.
• California summary judgment: the 81/20/11 schedule and the traps around itCCP 437c anchors every summary-judgment date to the hearing: 81 days' notice, opposition 20 days before, reply 11 days before — and the hearing itself no later than 30 days before trial.
• The California demurrer: the meet-and-confer you have to do first, and the 30 days it can buy youCCP 430.41 requires a meet and confer at least 5 days before the responsive pleading is due — and grants an automatic 30-day extension if it doesn't happen in time.
• California's five-year rule: the dismissal deadline that cannot be excusedCCP 583.310 requires an action to be brought to trial within five years. CCP 583.360 makes dismissal mandatory and says the requirement is not subject to extension, excuse, or exception.
• California's anti-SLAPP motion: 60 days to file, and discovery stops the moment you doCCP 425.16 gives a defendant 60 days from service of the complaint to file a special motion to strike. Filing it stays all discovery and, if it succeeds, shifts fees automatically.
• Amending a California complaint: the one free amendment, and the window most people missCCP 472 lets a party amend once without leave — and the window doesn't close when a demurrer is filed. It closes on the date the opposition to that demurrer is due.
• California TROs and preliminary injunctions: 15 days to the hearing, and a certification about noticeCCP 527 lets a TRO issue without notice only on a sworn certification about what notice was attempted — and the order to show cause must be heard within 15 days, or 22 for good cause.
• California requests for admission: 35 without a declaration, and the one discovery device that can end a caseCCP 2033 caps requests for admission at 35 without a supporting declaration, requires a motion before anything is deemed admitted, and makes a wrong denial payable in attorney's fees.
• California depositions: seven hours, six exceptions, and a 60-day clock most people missCCP 2025 caps most California depositions at seven hours — but not employment cases, expert depositions or PMK depositions. Objections to the notice are due three days out, and a motion to compel an answer is due 60 days after the record is complete.
• The California expert witness exchange: 70 days, 50 days, 20 days — and exclusion if you get it wrongCalifornia's expert exchange under CCP 2034 happens only if someone demands it, runs on deadlines counted backward from trial, and ends in mandatory exclusion for a party who fails to comply.
• Motion for reconsideration in California: 10 days, an affidavit, and something genuinely newCCP 1008 gives 10 days from notice of entry to ask a California judge to reconsider, requires new or different facts, circumstances or law, and says no court may consider a reconsideration motion made any other way.
• Dismissing a California case — and keeping the power to enforce the settlementCCP 581 lets a plaintiff dismiss any time before trial actually commences. CCP 664.6, rewritten operative January 1, 2025, is how a court keeps jurisdiction to enforce the settlement after the case is gone.
• California interrogatories: 35 special, unlimited form, no subparts, and a late answer that waives privilegeCCP 2030 caps specially prepared interrogatories at 35 without a declaration, bars subparts and compound questions outright, and makes a late response waive every objection including privilege.
• California inspection demands: three ways to respond, a diligent-search affirmation, and documents labeled by request numberCCP 2031 gives a responding party exactly three options per demand, requires an inability to comply to affirm a diligent search and say what happened to the documents, and requires production labeled to the request number.
• The California discovery cutoff: 30 days, 15 for motions, and a continuance that changes nothingCCP 2024.020 closes California discovery 30 days before the date initially set for trial and discovery motions 15 days before — and a continuance of the trial does not reopen either.
• Moving to quash service in California: file before you plead, and keep 10 days for the writCCP 418.10 lets a California defendant challenge jurisdiction on or before the last day to plead, extends the pleading deadline to 15 days after denial, and preserves a 10-day writ petition — but only before pleading.
• The California 998 offer: 10 days before trial, 30 days to accept, and expert fees on the tableCCP 998 lets either side make a written settlement offer up to 10 days before trial. Beat it and the other side pays your post-offer costs — and, in the court's discretion, your expert witness fees.
• Enforcing a California money judgment: the writ, the abstract, and the 180-day ruleA California money judgment is enforced by a writ of execution issued by the clerk, one per county, with a 180-day wait before a second writ — and a recorded abstract creates a 10-year lien on real property.
• California wage garnishment: 20 percent, or 40 percent of what clears 48 hours' minimum wageCalifornia's Wage Garnishment Law caps withholding at the lesser of 20% of disposable earnings or 40% of the amount above 48 times the minimum wage — and uses the local minimum wage where it is higher.
• Renewing a California judgment: 10 years, one shot for some debts, and interest that halved in 2023A California money judgment dies at 10 years unless renewed. Since 2023, medical and personal-debt judgments under set thresholds may be renewed only once, for five years, and accrue interest at 5 percent rather than 10.
• California exemptions: the homestead floor of $300,000, and the ones you lose by not claimingCalifornia's homestead exemption is the greater of the countywide median home price capped at $600,000 or $300,000, adjusted annually for inflation — and most other exemptions are waived unless claimed in time.
• The California 170.6 challenge: one per side, no reasons, and a deadline that depends on the assignmentCCP 170.6 lets a party disqualify a California judge once, without giving reasons — 15 days after an all-purpose civil assignment, 5 days before a known trial date, and never after trial begins.
• The California motion to strike: meet and confer five days out, or take the automatic 30 daysCCP 435 lets a party move to strike within the time to respond, CCP 435.5 requires a meet and confer five days before it is due, and failing to confer earns an automatic 30-day extension.
• California cross-complaints: the one you must file with your answer, and the one you can file laterA related cause of action against the plaintiff must be pleaded in a cross-complaint filed with the answer or it is lost — but CCP 426.50 lets a party who acted in good faith cure the omission at any time.
• California venue: move to transfer when you respond, or the case stays where it was filedCCP 396b lets a wrongly venued California case be tried where it was filed unless the defendant moves to transfer at the time of responding — and the fees for a bad venue fight fall on the attorney, not the client.
• California sanctions: bad faith under 128.5, the safe harbor under 128.7, and the discovery carve-outCCP 128.5 reaches bad-faith tactics that are frivolous or solely intended to delay; CCP 128.7 reaches papers that fail a certification test but gives a 21-day safe harbor. Neither applies to discovery.
• Staying a California judgment on appeal: the appeal stays most things, but not a money judgmentPerfecting a California appeal stays trial court proceedings under CCP 916 — but CCP 917.1 excludes money judgments unless an undertaking is given, and the trial court's own stay power runs only 10 days past the appeal deadline.
• The California vexatious litigant statute: five losses in seven years, security, and a prefiling orderCCP 391 defines a vexatious litigant by five self-represented losses in seven years, repeated relitigation, or repeated unmeritorious filings — and CCP 391.7 lets the court bar new filings without the presiding judge's leave.
• Compelling arbitration in California: 10 days to respond, four defenses, and a 30-day fee deadline that forfeits the whole clauseCCP 1281.2 requires a California court to order arbitration unless one of four things is shown — and CCP 1281.98 makes a drafting party who pays arbitration fees more than 30 days late waive its right to arbitrate at all.
• California attachment: contract claims over $500, a noticed hearing, and an undertaking before the writCCP 483.010 limits attachment to contract claims for a fixed or readily ascertainable amount of at least $500. A right to attach order requires a noticed hearing, probable validity, and an undertaking.
• Moving for summary judgment in California: 60 days in, 81 days' notice, heard 30 days before trialCCP 437c lets a party move for summary judgment 60 days after a general appearance, on 81 days' notice, heard no later than 30 days before trial — and a defective separate statement alone can sink the motion.
• Serving a California complaint: 60 days to serve, and four methods that complete on different daysCalifornia Rule of Court 3.110(b) requires service and proof of service within 60 days of filing — and the four methods under CCP 415.10 to 415.50 are each deemed complete on a different date.

Colorado — Colorado Rules of Civil Procedure

• Responding to a Colorado complaint: 21 days, and 14 more if your motion is deniedColorado Rule 12(a) gives 21 days to file an answer or other response, and 14 days after notice of an order denying a pre-answer motion — with default entered by the clerk on an affidavit.
• Setting aside a Colorado default judgment: 182 days, and a different rule for each halfColorado sets aside an entry of default for good cause under C.R.C.P. 55(c), but a default judgment only under Rule 60(b) — where mistake and excusable neglect expire at 182 days.
• Colorado's mandatory disclosures: 28 days after the case is at issue, favorable or notC.R.C.P. 26(a)(1) requires four categories of disclosure within 28 days after the case is at issue — including material that hurts your own case — with no waiting for a discovery request.
• Starting a Colorado civil case: two ways to commence, and a 14-day trap in one of themColorado lets you commence a civil action either by filing the complaint or by serving it — but service-first commencement is void unless the complaint is filed within 14 days.
• Colorado wage garnishment: 21 days to object, on Form 28Colorado's writ of continuing garnishment runs 182 days and can be objected to on C.R.C.P. Form 28 — but if no objection is filed within 21 days of service on the employer, the money goes out.
• Responding to a Colorado eviction: the date on the summons is the whole deadlineA Colorado eviction summons sets an appearance date not less than seven nor more than fourteen days out — file a written answer or appear by then, or the court may enter default judgment for possession.
• The Colorado motion to dismiss: six grounds, and it must be filed by the answer dateC.R.C.P. 12(b) lists six defenses that may be raised by separate motion — but the motion must be filed on or before the date the answer is due, and three of them are waived if omitted.
• Responding to summary judgment in Colorado: 91 days before trial, and sworn copies attachedC.R.C.P. 56(c) requires a summary judgment motion to be filed at least 91 days before trial and a cross-motion at least 70 — and affidavits must attach sworn or certified copies of everything they cite.
• Compelling discovery in Colorado: certify the conferral, and note what happens if they comply lateC.R.C.P. 37(a) requires a certification of good-faith conferral with every motion to compel — and expenses can be awarded even where the discovery arrives after the motion is filed.

Connecticut — Connecticut Practice Book

• Responding to a Connecticut complaint: there is no 20-day answer deadlineConnecticut has no fixed answer deadline. An appearance is due by the second day after the return day, and Practice Book § 10-8 requires each pleading to advance one step every 30 days.
• The Connecticut motion to strike: file it out of order and you have waived itConnecticut tests the legal sufficiency of a pleading by motion to strike under Practice Book § 10-39 — and § 10-7 waives it automatically if you file anything that comes later in the order of pleading first.
• Setting aside a Connecticut default: file before judgment and it vanishes by operation of lawIn Connecticut a default for failure to appear or plead is set aside automatically once you file — but after judgment you have four months and a verified motion.
• The Connecticut motion for compliance: answering misleadingly is its own groundConnecticut Practice Book § 13-14 reaches answers given falsely or in a manner calculated to mislead, and requires any sanction to be proportional to the noncompliance.

Delaware — Delaware Superior Court Rules of Civil Procedure

• Responding to a Delaware complaint: 20 days, and watch for an affidavit demandDelaware Superior Court Rule 12(a) gives 20 days after service of process to serve an answer — and where the plaintiff has noted the complaint under Rule 3(b), an ordinary answer will not do.
• Setting aside a Delaware default judgment: Rule 60(b) sets no deadline of its ownDelaware Rule 55(c) sends a default judgment to Rule 60(b), and Rule 60(b) states no time limit on its face — unlike Rule 59, which fixes 10 days and 5.
• The Delaware motion to dismiss: seven defenses, ten days if you lose, and six deadlines that are not twenty daysDelaware Rule 12(b) lists seven defenses that may be raised by motion, gives 10 days to answer after a denial, and sets separate deadlines for certiorari, ditch returns, mechanics' liens, appeals, attachment and capias.
• Delaware summary judgment: cross motions are treated as a stipulation to decide the caseDelaware Rule 56(h) treats cross motions for summary judgment as the equivalent of a stipulation for decision on the merits unless a party argues a material fact is in issue.
• The Delaware motion to compel: the Prothonotary will not accept it without a certification of dates and time spentDelaware Rule 37(e) requires a certification detailing dates, time spent and method of communication before a discovery motion can be filed, and imposes a $100 minimum fee on an attorney who fails to appear.
• Delaware execution: a default judgment can be stayed six months, if the security is posted within twenty daysDelaware Rule 69(c) lets a defendant buy a six-month stay of execution on certain default judgments by posting Prothonotary-approved security within 20 days, superseding any writ already issued.
• Delaware judgment by confession: two chances to appear, and the creditor has to prove you waived your rightsDelaware Rule 58.1 requires certified-mail notice and a motion day before a confessed judgment is entered, and a second notice and motion day before the first writ of execution issues.
• Delaware discovery deadlines: thirty days, forty-five if you are the defendant, and an unstated objection is waivedDelaware gives 30 days to answer interrogatories, document requests and admissions — 45 days for a defendant measured from service of the complaint — and waives any objection ground not stated.
• Amending a Delaware pleading: one free amendment, and you must show plainly what changedDelaware Rule 15(a) allows one amendment as of course before a responsive pleading, and Rule 15(aa) requires the amended pleading to indicate plainly how it differs from the one it replaces.
• Delaware dismissal for want of prosecution: six quiet months, then thirty days' notice, then it is goneDelaware Rule 41(e) requires the Prothonotary to send a want-of-prosecution notice after six months of inactivity, and the action is dismissed as of course if nothing is done within 30 days.
• Delaware mandatory non-binding arbitration: twenty days to pick an arbitrator, or you lose the trackDelaware Rule 16.1 sends elected civil cases to non-binding arbitration capped at $50,000, requires an arbitrator within 20 days of the close of pleadings, and shifts costs against a party who demands a trial de novo and does no better.
• Delaware depositions: your lawyer cannot talk to you about your testimony during a breakDelaware Rule 30(d)(1) bars a deponent's attorney from conferring about the substance of testimony during the deposition, including recesses shorter than five calendar days.
• Delaware reargument: five days from the opinion, and the clock runs from a different event than every other motionDelaware Rule 59(e) gives five days to move for reargument, measured from the filing of the Court's opinion or decision rather than from entry of judgment.
• Delaware jury demand: you get six jurors unless you ask for twelveDelaware Rule 38(d) deems a party to have consented to a jury of 6 unless the demand specifies 12, and Rule 38(b) sets the demand deadline at 10 days after the last pleading on the issue.
• Quashing a Delaware subpoena: fourteen days to object in writing, and no motion needed to stop productionDelaware Rule 45(c)(2)(B) lets a subpoenaed non-party stop document production with a written objection within 14 days, shifting the burden to the issuing party to move to compel.
• Delaware Rule 11 sanctions: twenty-one days to withdraw before the motion can even be filedDelaware Rule 11(c)(1)(A) bars filing a sanctions motion unless the challenged paper is not withdrawn within 21 days of service, and holds a law firm jointly responsible for its lawyers.
• A Delaware Rule 35 examination: asking for the report waives your privilegeDelaware Rule 35(b)(2) provides that requesting the examiner's report, or deposing the examiner, waives privilege as to every other person who has examined you for the same condition.
• Delaware class actions: only one kind of class gets notice and an opt-outDelaware Rule 23(c)(2) requires individual notice and a right of exclusion only in (b)(3) classes; classes certified under (b)(1) or (b)(2) bind every member the Court identifies.
• Delaware briefs: 8,000 words, and consent will not buy you an extensionDelaware Rule 107 caps an opening or answering brief at 8,000 words and a reply at 5,500, and refuses extensions of a briefing schedule even where all parties consent, absent a good-cause order.
• Appealing a Delaware board decision to the Superior Court: fifteen days if no statute says otherwiseDelaware Rule 72(b) sets a 15-day default for a notice of appeal from a commission, board or lower court to the Superior Court where no statute prescribes a time.
• Delaware Summary Proceedings for Commercial Disputes: no jury, no punitive damages, and no summary judgmentDelaware Rules 124-131 create a consent-based expedited commercial track with no jury trial, no punitive damages, ten interrogatories, four depositions, and no summary judgment motions at all.
• The Delaware CCLD: a motion supported by a brief may not exceed 500 wordsDelaware's Complex Commercial Litigation Division takes cases of $1 million or more and imposes its own limits — 500-word motions where a brief is filed, a seven-day opposition, and a certification requiring Delaware counsel to speak.
• Delaware requests for admission: silence admits, and an admission is conclusiveDelaware Rule 36 admits a matter automatically if no answer or objection is served in 30 days, and Rule 36(b) makes an admission conclusively established unless the Court permits withdrawal.
• Delaware business mediation: a judge mediates, and the petition never reaches the public docketDelaware Rules 135 and 136 let business parties petition the Superior Court for confidential mediation before a judge, with the petition kept off the public docketing system.
• Delaware business arbitration: a sitting judge is the arbitrator, and the award becomes a judgmentDelaware Rules 137-139 let consenting business parties arbitrate before a Superior Court judge or commissioner, off the public docket, with the final award entered as an enforceable judgment.
• Delaware counterclaims and third-party claims: ten days to bring in a third party without leaveDelaware Rule 14(a) lets a defendant serve a third-party complaint without leave if filed within 10 days of the original answer, and Rule 13(a) makes a related claim compulsory.
• Delaware joinder and intervention: a joined party who objects to venue gets dismissedDelaware Rule 19(a) requires dismissal of a joined party whose presence would make venue improper if that party objects, and Rule 19(c) requires a pleading to name anyone who should have been joined.
• Substitution after a death in Delaware: ninety days from the suggestion of death, or the claim is dismissedDelaware Rule 25(a) dismisses an action as to a deceased party unless a motion for substitution is made within 90 days after the death is suggested upon the record.
• Delaware judgment as a matter of law: make the motion before the case goes to the jury, or lose the right to renew itDelaware Rule 50(a)(2) allows a motion for judgment as a matter of law at any time before submission to the jury, and Rule 50(b) permits renewal only within 10 days after entry of judgment.
• Delaware costs: ten days to apply, and a deposition transcript is only taxable if it went into evidenceDelaware Rule 54(d) requires a prevailing party to apply for costs within 10 days of final judgment, and Rules 54(f)-(h) make deposition transcript, witness and expert fees taxable only if the deposition was introduced into evidence.
• Delaware pleading: negligence must be pleaded with particularity, and you may not sue under a pseudonymDelaware Rule 9(b) requires the circumstances constituting negligence — not just fraud and mistake — to be stated with particularity, and Rule 10(e) bars filing under a pseudonym without Court approval.
• Delaware pro hac vice: an annual fee that renews itself, and Delaware counsel must attend everythingDelaware Rule 90.1 requires a motion by Delaware counsel for pro hac vice admission, an annual assessment renewed each January 1, and attendance by Delaware counsel at all proceedings.
• Delaware court records: missing the Prothonotary's notice of judgment does not extend your time to appealDelaware Rule 77(d) requires the Prothonotary to mail notice of every judgment, but provides that lack of that notice does not affect the time to appeal or authorize relief for missing it.

District of Columbia — District of Columbia Superior Court Rules of Civil Procedure

• Responding to a D.C. complaint: 21 days, and a 14-day grace on defaultsD.C. Superior Court Rule 12(a) gives 21 days after service to answer, 60 days for government defendants — and a default entered on the court's own initiative does not take effect for 14 days.
• Setting aside a DC default: fourteen days before it even takes effectA District of Columbia default entered on the court's own initiative does not take effect for 14 days, and the clerk cannot enter judgment at all in a consumer debt collection action.
• The DC motion to dismiss: six grounds, and sixty days if you are suing the governmentD.C. Superior Court Rule 12 lists six defenses — venue is not among them — and gives the District and its officers 60 days to answer instead of 21.

Federal — Federal Rules of Civil Procedure

• Answering a federal complaint: 21 days, the 60-day waiver track, and what a Rule 12 motion does to the clockThe federal answer deadline is 21 days — unless you waived service, in which case it's 60 or 90. Rule 12 also lets a motion reset the clock, and omitting some defenses waives them for good.
• Missing the Rule 36 deadline: what gets admitted, and whether it can be undoneUnder Rule 36, an unanswered request for admission is admitted automatically — no motion, no order. What follows is a two-part standard for withdrawing it.
• Federal summary-judgment timing: what Rule 56 actually sets, and what your district setsRule 56 supplies one national deadline — 30 days after the close of all discovery. Almost every other date in a federal summary-judgment schedule comes from local rules or the judge.
• You got a federal subpoena: the 14-day objection window, where you have to comply, and when to move to quashRule 45 gives a document subpoena an objection deadline most people miss — the earlier of the compliance date or 14 days after service — and it is not the same as moving to quash.
• Setting aside a federal default: two standards, and which one you get depends on timingRule 55(c) sets an easy standard for an entry of default and a hard one for a default judgment. The difference between them is worth more than almost anything else in Rule 60.
• Amending a federal pleading: the 21-day window, leave to amend, and the scheduling order that outranks bothRule 15 gives one amendment as of right within 21 days and says courts should freely give leave after that. Once a Rule 16 scheduling order sets a deadline, the standard changes to good cause.
• Federal motions to compel: the certification, who pays, and the sanctions ladderRule 37 requires a good-faith conferral certification before any motion to compel, and then makes fee-shifting the default outcome — against whichever side loses.
• Dismissing your own federal case: the notice, the cutoff, and the two-dismissal ruleRule 41(a) lets a plaintiff walk away without a court order — but only before an answer or a summary-judgment motion, and the second time you do it, it counts as a decision on the merits.
• Rule 68 offers of judgment: 14 days to accept, and what happens if you refuse and win lessRule 68 lets a defending party shift post-offer costs onto a plaintiff who turns down an offer and then does no better at trial. The mechanics are short, rigid, and easy to get wrong.
• Serving a federal complaint: the 90-day deadline, and the cheapest way to extend itRule 4(m) gives 90 days from filing to serve each defendant. Miss it and the court must dismiss or order service by a date — unless you show good cause, in which case it must extend.
• What happens after you answer a federal complaintFiling an answer starts a sequence most people don't expect: a mandatory conference, initial disclosures without anyone asking, and a scheduling order that becomes the hardest deadline in the case.
• Federal deposition limits: ten depositions, seven hours, one dayRule 30 caps depositions at ten per side and each one at a single day of seven hours. Both are defaults — but exceeding them needs a stipulation or leave, and leave has conditions.
• Protective orders in federal discovery: what Rule 26(c) can and cannot doRule 26(c) requires a conferral certification before you move, lists eight specific forms of protection, and — importantly — does not by itself seal anything filed with the court.
• Federal TROs and preliminary injunctions: 14 days, two days' notice, and a bondA federal TRO issued without notice expires in 14 days, the adverse party can move to dissolve it on two days' notice, and Rule 65(c) requires security before either order issues.
• Federal interrogatories: 25 including discrete subparts, and 30 days to answerRule 33 caps interrogatories at 25 per party "including all discrete subparts," requires answers under oath in 30 days, and waives any objection not stated with specificity.
• Federal document requests: 30 days, and the objection that has to say what you're holding backRule 34 requires a response in 30 days, and since 2015 every objection must state whether responsive materials are being withheld because of it. Boilerplate no longer works.
• Costs and attorney's fees after a federal judgment: 14 days, and the clock starts on entryRule 54(d)(2) requires a fee motion within 14 days of entry of judgment. Costs run on a separate track — the clerk taxes them on 14 days' notice, with 7 days to seek review.
• Federal class actions: the deadlines in Rule 23 that aren't about certificationRule 23 sets few fixed dates, but the ones it sets are unforgiving — 14 days to petition for permission to appeal a certification order, and court approval required before any settlement.
• Federal expert disclosures: 90 days before trial, and two very different kinds of expertRule 26(a)(2) requires expert disclosures 90 days before trial and rebuttal within 30 days — but whether a written report is required depends on how the expert came to the case.
• The federal Rule 12(b)(6) motion: one shot, 14 days after denial, and the trap in Rule 12(g)FRCP 12(b)(6) tests whether a complaint states a claim. File it before answering, join every available defense in the same motion, and expect 14 days to answer if it is denied.
• FRCP 16.1: the first federal rule written for multidistrict litigationRule 16.1, effective December 1, 2025, gives MDL transferee courts a framework for the initial management conference — a required party report on leadership counsel, factual substantiation, and coordination.
• The federal Rule 30(b)(6) deposition: reasonable particularity, a mandatory conferral, and testimony that binds the organizationFRCP 30(b)(6) requires the notice to describe the matters for examination with reasonable particularity and the parties to confer in good faith — and the designee must testify to what the organization knows, not what they personally know.
• Federal pleading under Rule 8: three requirements, eighteen affirmative defenses, and the denial that admitsFRCP 8 requires a short and plain statement of the claim, lists eighteen affirmative defenses that must be pleaded affirmatively, and makes any allegation you fail to deny an admission.
• Rule 37(e): what happens when electronically stored information is lostFRCP 37(e) sets four threshold conditions before any ESI sanction, allows curative measures on a finding of prejudice, and reserves adverse-inference instructions and dismissal for an intent to deprive.
• FRCP 60: six grounds, a one-year cap on three of them, and a motion that stays nothingRule 60(b) gives six grounds for relief from a final federal judgment, caps the first three at one year from entry, requires all six to be brought within a reasonable time — and does not suspend the judgment.
• Getting a federal default judgment: two routes, seven days' notice, and a ceiling on what you can recoverFRCP 55 splits default judgment between the clerk and the court. A sum certain goes to the clerk; everything else needs an application, and Rule 54(c) caps the judgment at what the complaint demanded.
• Adding parties in federal court: impleader in 14 days, required joinder, and intervention of rightFRCP 14 lets a defendant implead a third party without leave for 14 days after answering; Rule 19 makes some absentees required parties; Rule 24 gives others a right to intervene.
• Objecting to a magistrate judge's ruling: 14 days, and two very different standards of reviewFRCP 72 gives 14 days to object to a magistrate judge's order or recommendation — but a nondispositive order is reviewed for clear error, while a dispositive recommendation gets de novo review.
• Staying a federal judgment: 30 automatic days, then a bond — and three things that are never stayedFRCP 62 stays execution on a federal judgment automatically for 30 days after entry. After that a stay requires a bond or other security — and injunctions are not stayed at all.
• Federal counterclaims: the one you must plead, the one you may, and the crossclaim in betweenFRCP 13(a) makes a claim arising from the same transaction compulsory — plead it or lose it. Rule 13(b) permits anything else, and Rule 13(g) governs claims against a co-party.
• FRCP 41(b): dismissal for failure to prosecute, and why it usually ends the claim for goodRule 41(b) lets a defendant move to dismiss for failure to prosecute or to comply with the rules or a court order — and unless the order says otherwise, that dismissal operates as an adjudication on the merits.
• Collecting a federal judgment: Rule 69 sends you to state law, and opens discovery against the debtorFRCP 69 enforces a federal money judgment by writ of execution using the procedure of the state where the court sits — and lets the creditor take discovery from anyone, including the judgment debtor.
• FRCP 35 examinations: good cause, a court order, and the report exchange that waives privilegeRule 35 is the only federal discovery device that always requires a court order and good cause — and asking for the examiner's report waives privilege over every examination of the same condition.
• Privilege logs in federal court: the 2025 amendments put the method on the scheduling orderAmendments to FRCP 16 and 26 effective December 1, 2025 direct parties to settle the timing and method of Rule 26(b)(5)(A) compliance at the outset — rather than fighting about privilege logs a year later.
• Issuing a federal subpoena: the 100-mile rule, the notice requirement, and the duty to avoid undue burdenFRCP 45 requires every subpoena to issue from the court where the action is pending, sets a 100-mile limit on where compliance can be commanded, and imposes a sanctionable duty to avoid undue burden.
• Findings after a federal bench trial: Rule 52, the clearly-erroneous shield, and judgment on partial findingsFRCP 52 requires a court trying a case without a jury to find the facts specially and state its conclusions of law separately — and those findings survive appeal unless clearly erroneous.
• FRCP 27: taking a deposition before the lawsuit existsRule 27 lets a person who expects to be a party but cannot yet sue petition to depose a witness — on a verified petition, 21 days' notice, and a finding that perpetuation may prevent a failure of justice.
• Serving and filing federal papers: six methods, mandatory e-filing, and the four things you must redactFRCP 5 sets six ways to serve papers after the complaint, requires represented parties to file electronically, and Rule 5.2 requires redaction of Social Security numbers, birth dates, minors' names and account numbers.
• When a federal judgment is entered: the separate document, the 150-day backstop, and Rule 54(b)FRCP 58 requires every judgment to be set out in a separate document, and treats it as entered when docketed plus the earlier of the separate document or 150 days — the date every post-judgment clock runs from.

Georgia — Georgia Civil Practice Act

• Responding to a Georgia complaint: 30 days, automatic default, and the 15 days that followGeorgia puts a case into default automatically when no answer is filed in 30 days — and then gives 15 days to open it as a matter of right, on payment of costs.
• Amending a Georgia pleading: no leave needed until the pretrial orderGeorgia has the most permissive amendment rule in the country — a party may amend as a matter of course, with no limit on the number, until a pretrial order is entered.
• Georgia summary judgment: 30 days' notice, and no deadline to fileO.C.G.A. § 9-11-56 sets one timing rule — the motion must be served at least 30 days before the hearing. A defending party may move at any time; a claimant must wait 30 days after filing.
• Georgia discovery deadlines: 30 days, 45 for a defendant, and 50 interrogatoriesGeorgia gives 30 days to answer written discovery — 45 if you're a defendant served at the outset — and permits 50 interrogatories, double the federal limit.
• The Georgia expert affidavit: it goes with the complaint, not 60 days laterGeorgia O.C.G.A. § 9-11-9.1 requires an expert affidavit to be filed with the complaint in any professional malpractice action — with one narrow 45-day exception the court cannot extend.
• The Georgia offer of settlement: 75 percent, 125 percent, and 30 days openGeorgia O.C.G.A. § 9-11-68 lets either party in a tort case shift attorney's fees by offer of settlement — a defendant at 75 percent, a plaintiff at 125 percent — with the offer open 30 days.
• The Georgia motion to dismiss: 15 days after the ruling, and a discovery stay you have to ask forGeorgia O.C.G.A. § 9-11-12 lists seven defenses that may be raised by motion, gives 15 days to answer after the court rules, and stays discovery only if the motion is filed within the answer period.
• Opening a Georgia default: fifteen days as of right, then a four-part showingGeorgia lets a defendant open a default as a matter of right within 15 days by filing defenses and paying costs — after that, O.C.G.A. § 9-11-55(b) requires a sworn showing with four separate elements.
• Georgia requests for production: 30 days, 45 for a defendant, and non-parties tooO.C.G.A. § 9-11-34 gives 30 days to respond to a request for production — 45 for a defendant served with process — and the same section reaches non-parties.
• Stopping a Georgia garnishment: no deadline to claim, and a hearing within ten days as of rightGeorgia lets a garnishment defendant file a claim at any time before the money is disbursed — and once filed, the court must set a hearing within ten days and nothing may be paid out until it happens.
• The Georgia motion to compel: silence is not excused by an objection you never filedGeorgia O.C.G.A. § 9-11-37 shifts fees to the losing side either way, and says a total failure to respond cannot be excused by objections unless a protective order was sought.

Hawaii — Hawaii Rules of Civil Procedure

• Responding to a Hawaii complaint: 20 days, 18 days' notice for every motion, and 60 interrogatories comingHawaii gives 20 days to answer, requires 18 days' notice for any motion under Rule 6(d), and allows 60 interrogatories — with 45 days for a defendant to answer them.
• Hawaii summary judgment: 50 days before trial, 18 before the hearing, 8 to oppose, 3 to replyHaw. R. Civ. P. 56 sets a hard 50-day-before-trial deadline for any summary judgment motion, then runs an 18/8/3 hearing schedule — and Rule 56(h) requires a partial order to name every claim and party it disposes of.
• Amending a Hawaii pleading: Ramseyer formatting, the whole pleading, and then a clean copyHawaii Rule 15(a)(2) requires a motion to amend to attach the proposed pleading in Ramseyer formatting — additions underscored, deletions bracketed and stricken — reproduced in full, then refiled clean once allowed.
• Setting aside a Hawaii judgment: six grounds, one year, and a deadline the court cannot extendHawaii Rule 60(b) gives six grounds for relief from a judgment with a one-year cap on the first three — and Rule 6(b) forbids the court from enlarging the time to bring the motion at all.
• Hawaii post-judgment motions: 10 days, six deadlines the court cannot move, and grounds drawn from historyHawaii Rule 59 gives 10 days to move for a new trial or to alter or amend a judgment, defines the grounds by reference to historic law and equity practice, and Rule 6(b) forbids extending any of it.
• Hawaii discovery: initial disclosures in 14 days, 45 days for a defendant, and 60 interrogatoriesHawaii requires initial disclosures within 14 days of the Rule 26(f) conference, gives a defendant 45 days to answer the first written discovery, and allows 60 interrogatories counting every subpart.
• The Hawaii motion to dismiss: twenty days to answer, ten after a denialHawaii Rule 12(b) carries the familiar seven defenses, gives 20 days to answer, and only 10 days after a motion is denied.
• Hawaii execution: ten days, and post-judgment discovery is limited to depositionsHawaii Rule 62(a) bars execution for 10 days after entry, and Rule 69 confines post-judgment discovery to the manner provided for taking depositions.

Idaho — Idaho Rules of Civil Procedure

• Responding to an Idaho complaint: 21 days, and notice before the default is even enteredIdaho Rule 12(a) gives 21 days after service of the summons and complaint to serve an answer — and if you have appeared, you get three days' written notice before a default can be entered at all.
• Setting aside an Idaho default judgment: six months, and the plaintiff had to certify your best addressIdaho Rule 60(b) allows six months, not a year — and Rule 55(b)(1) requires the original instrument and a certified address before a sum-certain default judgment can be entered.
• The Idaho motion to compel: a catch-all that reaches beyond the discovery rulesIdaho Rule 37(f) is a general sanctions catch-all allowing fees and costs against a party or the advising attorney in addition to the rule's specific remedies.
• The Idaho motion to dismiss: eight grounds, including a case already pending elsewhereIdaho Rule 12(b) lists eight defenses rather than the usual seven, adding a parallel action pending between the same parties.
• Idaho execution: no automatic stay, but a writ for more than the face amount needs a sworn computationIdaho Rule 62(a) allows execution immediately on entry, and Rule 69(a) bars a writ for anything beyond the face amount of the judgment without an affidavit verifying the computation.

Illinois — Illinois Code of Civil Procedure

• Illinois motions to dismiss: 2-615, 2-619, and the combined motion under 2-619.1Illinois splits the motion to dismiss in two. Section 2-615 attacks the pleading; Section 2-619 raises outside matter that defeats the claim. Combining them has its own rule and its own format.
• Setting aside an Illinois default: 30 days under 2-1301, two years under 2-1401Illinois gives 30 days to vacate a judgment on reasonable terms under 735 ILCS 5/2-1301. After that it takes a 2-1401 petition — a different filing, with affidavits and a two-year limit.
• Illinois summary judgment: 735 ILCS 5/2-1005 and the counteraffidavit you can file at the hearingIllinois sets no notice period for a summary-judgment motion in the statute and lets the opposing party file counteraffidavits at the hearing itself. Supreme Court Rules supply the rest.
• Responding to an Illinois complaint: 30 days, and why an unanswered allegation is admittedIllinois gives 30 days from service — counted from delivery, not mailing. And under 735 ILCS 5/2-610, any allegation you don't explicitly deny is admitted.
• Responding to an Illinois eviction: no written answer required, but you have to show upIllinois eviction summonses set an appearance date rather than a 30-day answer period, and the summons itself says no written answer is required unless the court orders one.
• Illinois discovery deadlines: 28 days across the board, and a sworn denial or it's admittedIllinois sets a uniform 28 days for interrogatories, document requests and requests to admit — and a request to admit is deemed admitted without a sworn denial.
• Illinois wage deduction: the cap, and the hearing you must ask for by the return dateIllinois caps a wage deduction at the lesser of 15% of gross weekly pay or the amount disposable earnings exceed 45 times the minimum wage — and a debtor who wants an exemption hearing must ask on or before the return date.
• The Illinois citation to discover assets: appear, or risk arrestA citation to discover assets under 735 ILCS 5/2-1402 compels a judgment debtor to appear and be examined — and the citation itself must warn that failing to appear can lead to arrest.
• Illinois requests to admit: 28 days, a sworn denial, and a warning that must be on the first pageIllinois Supreme Court Rule 216 deems facts admitted after 28 days — and requires the request to be a separate document carrying a boldface warning in 12-point type.
• Quashing an Illinois subpoena: the protective order is the tool, and witnesses have standingIllinois handles subpoena disputes through Rule 201(c) protective orders — available on the motion of any party or witness, and broad enough to deny, limit, condition or regulate the discovery.
• Illinois dismissal for want of prosecution: one year to refile, or the rest of the limitation period735 ILCS 5/13-217 gives a plaintiff whose case was dismissed for want of prosecution one year to refile — or the remaining limitation period, whichever is greater.
• The Illinois motion to compel: fees turn on a finding, not an exceptionIllinois Rule 219(a) awards fees only where the court finds the refusal was without substantial justification — and the same test applies against a movant whose motion fails.

Indiana — Indiana Rules of Trial Procedure

• Responding to an Indiana complaint: 20 days, and 10 more if your motion is deniedIndiana Trial Rule 6(D) gives 20 days to respond to a pleading, and Trial Rule 12(A) gives only 10 days after an order denying a pre-answer motion — one of the shortest such periods anywhere.
• Indiana discovery deadlines: read the request, because it sets your deadlineIndiana does not fix a discovery response deadline. Trial Rules 33, 34 and 36 let the requesting party designate the period, subject to a floor of not less than thirty days.
• Indiana's motion to correct error: optional for most appeals, mandatory for twoIndiana Trial Rule 59 makes a motion to correct error unnecessary before most appeals — but required for newly discovered evidence and for a claim that a verdict is excessive or inadequate, within 30 days.
• The Indiana motion to dismiss: eight grounds, and one free amendment if you loseIndiana Trial Rule 12(B) lists eight defenses rather than the usual seven, and gives a plaintiff whose claim is dismissed ten days to amend once as of right.
• Indiana summary judgment: if you did not designate it, it does not existIndiana Trial Rule 56 gives 30 days to respond and considers only evidence specifically designated to the court — a judgment cannot be reversed on undesignated facts.
• The Indiana motion to compel: fees run both ways, and no certification is requiredIndiana Trial Rule 37 imposes no conference certification requirement but makes an expense award mandatory whether the motion is granted or denied.
• Indiana proceedings supplemental: an ex parte order, twenty days' notice, and six months before your house can be soldIndiana Trial Rule 69(E) lets a creditor open proceedings supplemental on a verified motion granted ex parte, with the hearing no less than 20 days after service, and 69(A) bars a real estate sale for six months.

Iowa — Iowa Rules of Civil Procedure

• Responding to an Iowa petition: 20 days, and ten days' warning before defaultIowa R. Civ. P. 1.303 gives 20 days after service of the original notice and petition to serve a motion or answer — and no default may be entered without ten days' written notice of intent to seek it.
• Setting aside an Iowa default judgment: sixty days, and check whether you got the ten-day noticeIowa Rule 1.977 gives only 60 days to set aside a default judgment — but Rule 1.972 requires ten days' written notice of intent before a default can even be applied for.
• The Iowa motion to compel: if nobody resists it, the court can grant it unheardIowa Rule 1.517 lets the court grant an unresisted motion to compel without a hearing, and requires every such order to warn that non-compliance may bring sanctions.
• The Iowa pre-answer motion: you get one, and it must say how the pleading failsIowa Rule 1.421 permits only one pre-answer motion attacking a pleading, requires every available ground to be in it, and waives anything left out.

Kansas — Kansas Rules of Civil Procedure

• Responding to a Kansas petition: 21 days, and no clerk's default at allKansas K.S.A. 60-212 gives 21 days after service of the summons and petition to serve an answer, or at least 41 days from first publication — and every default judgment is rendered by a judge.
• Setting aside a Kansas default judgment: one year, and the statute points to two routesKansas K.S.A. 60-255(b) sends a defaulted defendant to two separate statutes — 60-260(b) with its one-year limit, and 60-309.
• The Kansas motion to compel: the fee award tilts toward whoever is rightKansas K.S.A. 60-237 makes fees mandatory when a motion to compel is granted but discretionary when denied, and requires a certification of good faith conference.
• The Kansas motion to dismiss: a statute, six grounds, and twenty-one daysKansas K.S.A. 60-212(b) lists six defenses that may be raised by motion, gives 21 days to answer and 14 days after a denial.
• Kansas summary judgment: twenty-one days to respond, fourteen to replyKansas K.S.A. 60-256(c) sets a full briefing schedule — motion until 30 days after discovery closes, response in 21 days, reply in 14.

Kentucky — Kentucky Rules of Civil Procedure

• Responding to a Kentucky complaint: 20 days, and no clerk's default judgmentKentucky CR 12.01 gives 20 days after service of the summons to serve an answer, and 10 days after entry of an order denying a pre-answer motion — and every default judgment goes to a judge.
• Vacating a Kentucky judgment: six grounds, three of which expire in a yearKentucky CR 60.02 lists six grounds for relief from a final judgment — mistake, newly discovered evidence and perjury are capped at one year, and filing does not suspend the judgment.
• Kentucky's ten days: the motion to alter, amend or vacate a judgmentKentucky CR 59.05 gives just 10 days from entry of judgment to serve a motion to alter, amend or vacate — one of the shortest post-judgment windows in the country.
• The Kentucky motion to dismiss: twenty days to respond, ten if the motion failsKentucky CR 12.02 lists seven defenses that may be raised by motion, and CR 12.01 gives only ten days to answer once the motion is denied — measured from entry, not notice.
• Kentucky summary judgment: ten days' notice, and opposing affidavits up to the day beforeKentucky CR 56.03 requires the motion to be served at least 10 days before the hearing and lets the adverse party serve opposing affidavits any time before the day of hearing.
• The Kentucky motion to compel: five separate rules, and one of them protects the CommonwealthKentucky CR 37.01 is the motion to compel, with fees mandatory both ways — and CR 37.05 bars an expense award against the Commonwealth.
• Kentucky garnishment: your wages sit in escrow for fifteen days, and an objection keeps them thereKentucky CR 69.02 requires garnished wages to be held in escrow for 15 days from the employer's check, and an objection filed in that window keeps them held until the court rules.

Louisiana — Louisiana Code of Civil Procedure

• Responding to a Louisiana petition: 21 days, 30 if discovery came with itLouisiana C.C.P. art. 1001 gives 21 days after service of citation to file an answer — 30 days if the plaintiff served a discovery request with the petition — and art. 1002 lets you answer at any time before a default judgment is signed.
• Louisiana default judgments after the 2022 overhaul: one step, and seven days' noticeLouisiana abolished the preliminary default. Article 1702 now requires a prima facie case by competent evidence plus seven days' written notice before a default judgment can be rendered.
• Answering a Louisiana petition: 21 days, or 30 if discovery came with itLa. C.C.P. art. 1001 gives a defendant 21 days after service of citation to answer — 30 days if the plaintiff served a discovery request with the petition, and 15 after an exception is overruled.
• Louisiana exceptions: three kinds, two deadlines, and two that waive themselvesLouisiana raises threshold objections by exception — declinatory, dilatory and peremptory. The first two are waived unless pleaded before or in the answer; the peremptory can come at almost any time.
• Louisiana summary judgment: sixty-five days before trial, and a closed list of what you may fileLouisiana C.C.P. art. 966 sets every deadline by statute — 65 days before trial to move, 15 before the hearing to oppose — and lists exhaustively what documents may be filed.
• The Louisiana motion to compel: one court for everyone, including non-partiesLouisiana C.C.P. art. 1469 sends every motion to compel — including one against a non-party deponent — to the court where the action is pending, and shifts fees both ways.
• Louisiana garnishment: a bank seizure catches only what is there that day, and a wage garnishment dies at 180 daysLouisiana C.C.P. art. 2411 makes non-wage garnishment a one-time snapshot, and ends a wage seizure automatically if no garnishment judgment is obtained within 180 days.

Maine — Maine Rules of Civil Procedure

• Responding to a Maine complaint: 20 days, and no clerk's default in a debt caseMaine Rule 12(a) gives 20 days after service to answer, or 50 days if served outside the continental United States or Canada — and the clerk cannot enter default in foreclosure or consumer debt collection actions.
• Setting aside a Maine default judgment: debt collectors must show strict compliance firstMaine bars the clerk from entering default in debt buyer, credit card, student loan and foreclosure actions, and requires court review for strict compliance before judgment.
• The Maine motion to dismiss: twenty days to answer, ten after a denialMaine Rule 12(b) carries the familiar seven defenses, gives 20 days to answer, and 10 days after a motion is denied.
• Maine execution: an appeal stays it without a bond, and a default against an absent defendant waits a yearMaine Rule 62(e) stays execution for the whole appeal with no bond required, and Rule 62(b) bars execution for one year on a default against an absent defendant with no actual notice.

Maryland — Maryland Rules of Civil Procedure

• Responding to a Maryland complaint: 30 days, 60 if you were served in another stateMaryland Rule 2-321 gives 30 days to answer, 60 days if you were served outside Maryland but within the United States — and a default order carries a notice with its own deadline.
• Maryland discovery deadlines: 30 days, or 15 after your pleading was due — whichever is laterMaryland gives 30 days to respond to interrogatories, document requests and requests for admission — or 15 days after the responding party's initial pleading was due, whichever is later.
• Maryland summary judgment: identify the dispute with particularity, and attach the proofMaryland Rule 2-501 requires a response to summary judgment to identify each disputed material fact with particularity and attach the record evidence — a stricter opposition standard than most states impose.
• Revising a Maryland judgment: thirty days of broad power, then only three groundsMaryland Rule 2-535(a) gives the court broad revisory power over a judgment for 30 days after entry — after that, only fraud, mistake or irregularity will reopen it.
• Maryland preliminary motions: four defenses are waived the moment you file an answerMaryland Rule 2-322 splits its defenses into mandatory and permissive — four must be raised by motion before the answer, or they are gone.
• The Maryland motion to compel: the rule tells you what the motion must containMaryland Rule 2-432 requires the motion to set out the request, the answer or objection, and the reasons — and allows immediate sanctions without any order for a total non-response.
• Maryland garnishment: you can object at any time, and $500 in the bank is exempt automaticallyMaryland Rule 2-646 lets a judgment debtor file a motion asserting a defense at any time, and Rule 2-645 exempts $500 in deposit accounts without any election.

Massachusetts — Massachusetts Rules of Civil Procedure

• Responding to a Massachusetts complaint: 20 days, and 10 after a motion is decidedMass. R. Civ. P. 12(a) gives 20 days to answer and only 10 days after a Rule 12 motion is denied — one of the shortest post-motion periods in the country.
• Setting aside a Massachusetts judgment: Rule 60(b), one year, and the earlier exitsMass. R. Civ. P. 60(b) tracks the federal six grounds with a one-year cap on the first three. The more useful question is usually whether you can get there before judgment.
• Massachusetts discovery deadlines: 45 days for interrogatories, and a final request that can end your caseMassachusetts gives 45 days to answer interrogatories — but ignoring them leads to a "final request for answers" and then an application for entry of final judgment or dismissal.
• Massachusetts summary judgment: 20 days to move, 10 days' notice, and no deadline at the other endMassachusetts Rule 56 lets a claimant move 20 days after the action is commenced and a defending party move at any time — with the motion served at least 10 days before the hearing.
• The Massachusetts motion to dismiss: ten grounds, and three you will not find in the federal ruleMassachusetts Rule 12(b) lists ten defenses that may be raised by motion — including misnomer, a prior pending action, and improper amount of damages — with seven of them waived if omitted.
• The Massachusetts motion to compel: fees are discretionary, but a wrongful denial is notMassachusetts Rule 37 makes fee awards on a motion to compel discretionary and requires a willful failure before non-response sanctions — but expenses for a wrongful refusal to admit are mandatory.
• Massachusetts execution: an appeal stays it automatically, and no bond is required to do itMassachusetts Rule 62(a) bars execution until the appeal period expires, and Rule 62(d) stays execution for the whole appeal on the taking of the appeal alone.

Michigan — Michigan Court Rules, Chapter 2

• Responding to a Michigan complaint: 21 days, or 28 if you were served outside the stateMichigan gives 21 days to answer a complaint served in-state, 28 days if service was made outside Michigan or by registered mail — and the clerk enters default without a hearing.
• Michigan discovery deadlines: 28 days, 42 if you are the defendantMichigan gives 28 days to answer interrogatories, respond to document requests, and answer requests for admission — with 42 days for a defendant counted from service of the summons and complaint.
• Michigan summary disposition: ten grounds, three timing rules, and one that waives itselfMichigan doesn't have summary judgment — it has summary disposition under MCR 2.116, with ten separate grounds, and three of them are waived unless raised in your first motion or responsive pleading.
• Michigan interrogatories: twenty each, subparts counted, and 28 days to answerMCR 2.309 limits each separately represented party to twenty interrogatories per party, counts discrete subparts separately, and requires answers within 28 days — 42 for a defendant.
• Michigan reconsideration: 21 days, palpable error, and nobody respondsMCR 2.119(F) gives 21 days to move for reconsideration of a decision on a motion — the standard is palpable error, no response is filed, and there is no oral argument.
• Objecting to a Michigan garnishment: 14 days, form MC 49, and five groundsMichigan gives 14 days from service of a writ of garnishment to file objections on form MC 49 — and an installment payment order signed by a judge is one of the recognized grounds.
• Relief from a Michigan judgment: six grounds, and a separate year for a defendant who never knewMCR 2.612(C) caps mistake, newly discovered evidence and fraud at one year — and MCR 2.612(B) gives a defendant who never knew of the case a full year to appear after final judgment.
• The Michigan motion to compel: a separate route for non-party subpoenasMCR 2.313(A)(2)(c) gives non-party subpoenas their own motion, requiring a copy of the subpoena, proof of service, and service on the non-party under MCR 2.105.

Minnesota — Minnesota Rules of Civil Procedure

• Responding to a Minnesota complaint: 21 days from the summons, in a case that may not be filed yetMinnesota Rule 12.01 gives 21 days after service of the summons to serve an answer — and because Minnesota actions are commenced by service, there may be no court file to look at.
• Commencing a Minnesota action: you sue before you file, and you have one year to fileMinnesota commences a civil action by serving the summons, not by filing it — and Rule 5.04(a) deems the action dismissed with prejudice if it is not filed within one year of commencement.
• Minnesota garnishment: you get ten days' warning before your wages are touchedMinnesota requires an earnings exemption notice to be served ten or more days before the first garnishment summons — and returning the exemption claim inside those ten days stops the garnishment.
• Appealing a Minnesota conciliation court judgment: it's a removal, and it starts the case overMinnesota does not review conciliation court judgments on appeal — a party removes the case to district court within 21 days of notice, and gets an entirely new trial.
• The Minnesota motion to dismiss: six grounds, made before pleadingMinn. R. Civ. P. 12.02 lets six defenses be raised by motion, but the motion must be made before pleading — and the answer clock runs from service, which in Minnesota is what starts the case.
• Responding to summary judgment in Minnesota: 14 days minimum, and cite the recordMinnesota's Rule 56 requires a summary judgment motion to be served at least 14 days before the hearing and no more than 30 days after discovery closes — and every factual assertion must cite particular parts of the record.
• Setting aside a Minnesota default judgment: one year, and a separate route if you were never notifiedMinn. R. Civ. P. 60.02 caps mistake, newly discovered evidence and fraud at one year — but preserves a distinct power to relieve a defendant who was never actually personally notified.
• The Minnesota motion to compel: failing to disclose and failing to admit are separate provisionsMinnesota Rule 37 separates failure to disclose or supplement from failure to admit, and makes fees mandatory when the motion is granted but discretionary when denied.

Mississippi — Mississippi Rules of Civil Procedure

• Responding to a Mississippi complaint: 30 days, and one extension you can grant yourselvesMississippi Rule 12(a) gives 30 days after service of the summons and complaint to serve an answer — and lets counsel extend the time once, by up to ten days, by written stipulation without asking a judge.
• Setting aside a Mississippi default judgment: six months, and the grounds are not numbered the way you expectMississippi Rule 60(b) allows only six months for its first three grounds, reorders them so fraud is (1), and never uses the words "excusable neglect."
• The Mississippi motion to compel: refusing to agree a discovery plan is sanctionableMississippi Rule 37(e) allows sanctions against a party or counsel who fails without good cause to cooperate in framing a discovery plan, or who otherwise abuses the process.
• The Mississippi motion to dismiss: thirty days to answer, ten after a denialMississippi Rule 12(b) carries the familiar seven defenses, gives 30 days to answer, and only 10 days after a motion is denied.
• Mississippi summary judgment: ten days out, and affidavits up to the day beforeMississippi Rule 56 requires the motion to be served at least 10 days before the hearing and lets the opposing party serve affidavits any time before the day of hearing.
• Mississippi execution: thirty days, unless the court shortens them for good causeMississippi Rule 62(a) stays execution for 30 days after entry but lets the court cut that short for good cause, and Rule 69(b) opens asset examination only above $100.

Missouri — Missouri Rules of Civil Procedure

• Responding to a Missouri petition: 30 days, or 45 after the first publicationMissouri Rule 55.25 gives 30 days to answer a petition — measured from the filing of the return receipt where service was by mail, and 45 days from first publication where neither personal nor mail service was had.
• Missouri discovery deadlines: 30 days, and a 45-day floor that appearing can start earlyMissouri gives 30 days to respond to interrogatories, document requests and requests for admission — with a 45-day floor for defendants running from the earlier of appearance or service of process.
• The Missouri motion to dismiss: eleven grounds, and you may answer at the same timeMissouri Rule 55.27 lists eleven defenses — more than any other state — and says a motion and a pleading may be filed simultaneously without waiving either.
• Setting aside a Missouri default judgment: the rule defines "good cause" in your favorMissouri Rule 74.05(d) gives one year to set aside a default judgment and defines good cause as conduct not intentionally or recklessly designed to impede the judicial process.
• Missouri summary judgment: a non-compliant response admits the factMissouri Rule 74.04(c)(2) treats any numbered paragraph you fail to answer properly as admitted — the strictest summary judgment response rule in the country.
• Missouri discovery sanctions: there is no motion to compel stepMissouri Rule 61.01 lets a court strike pleadings, dismiss or enter default for unanswered interrogatories without any prior order compelling discovery.
• Missouri garnishment: a direct-deposit benefits account is not garnishable property at allMissouri Rule 90.01 writes exempt direct-deposit accounts out of the definition of garnishable property, and Rule 90.02 fixes the return date at 30, 60, 90, 120, 150 or 180 days.

Montana — Montana Rules of Civil Procedure

• Responding to a Montana complaint: 21 days, 42 for the stateMontana Rule 12(a) gives 21 days after service of the summons and complaint to serve an answer, and 42 days where the State, a state agency, or a state officer or employee is the defendant.
• Setting aside a Montana default judgment: your motion is deemed denied if nobody rules on itMontana Rule 60(c) runs a Rule 60(b) motion on the Rule 59 clock — deemed denied at 60 days without a written order, and the motion must carry that date in its heading.
• The Montana motion to dismiss: twenty-one days, and the answer clock can be reset by the courtMontana Rule 12(b) carries the familiar seven defenses and gives 21 days to answer, unless the court orders otherwise under Rule 4(c)(2)(C).
• Montana execution: the fourteen-day stay comes with an automatic injunction against moving your assetsMontana Rule 62(a) stays execution for 14 days after entry and, during those days, automatically enjoins the judgment debtor from transferring or encumbering any property.

Nebraska — Nebraska Supreme Court Rules, Chapter 6

• Responding to a Nebraska complaint: 30 days, and the plaintiff has to prove its claimNebraska § 6-1112 gives 30 days after service of the summons and complaint to serve an answer — and a default judgment requires a verified petition, affidavits, or sworn testimony establishing the claim.
• Vacating a Nebraska default judgment: six months, seven grounds, and no excusable neglectNebraska Rev. Stat. § 25-2001 gives six months to vacate a judgment after the term, on seven enumerated grounds — a list that does not include excusable neglect.
• The Nebraska motion to compel: the bill can reach the law firm, not just the lawyerNebraska § 6-337 makes fees mandatory both ways and allows the award against the attorney's law firm or employer — a reach no neighboring state's rule has.
• The Nebraska motion to dismiss: venue is not a ground, but a parallel lawsuit isNebraska § 6-1112(b) lists seven defenses, replacing improper venue with the pendency of another action involving the same subject matter and parties.
• Nebraska garnishment: the employer must pay you your exempt wages, not hold themNebraska § 25-1056 requires a garnishee holding wages to pay the employee all exempt disposable earnings and retain only the remainder.

Nevada — Nevada Rules of Civil Procedure

• Responding to a Nevada complaint: 21 days, or 45 for a public entityNRCP 12(a) gives 21 days after service to serve an answer, 60 or 90 days if you waived service, and 45 days for the State, its public entities and political subdivisions.
• Setting aside a Nevada default judgment: six months, and a separate route if you were never servedNRCP 60(b) gives six months for mistake, excusable neglect, newly discovered evidence and fraud — and NRCP 60(d)(2) adds a distinct six-month route for a defendant who was never personally served.
• Nevada initial disclosures: 14 days after the case conference, five categoriesNRCP 16.1(a)(1) requires five categories of initial disclosure within 14 days of the Rule 16.1(b) case conference — including records about the incident whether or not you intend to use them.
• Responding to a Nevada summary eviction: file the affidavit by the fifth judicial dayNevada's summary eviction puts the burden on the tenant — file an affidavit with the court by the close of business on the fifth judicial day after service, or the landlord can get an order without further notice.
• Vacating a Nevada justice court or small claims judgmentJustice court and small claims judgments in Nevada are set aside under JCRCP 60, which tracks NRCP 60(b) — mistake, excusable neglect, fraud, satisfaction, or never having been personally served.
• The Nevada motion to dismiss: six grounds, and venue is not one of themNevada's restyled Rule 12(b) lists six defenses — improper venue is not among them — and gives the State and its political subdivisions 45 days to answer instead of 21.
• Nevada summary judgment: thirty days after discovery closes, and silence makes a fact undisputedNevada Rule 56 allows a motion until 30 days after the close of all discovery, and lets the court treat any fact you fail to address as undisputed.
• The Nevada motion to compel: destroying electronic evidence needs intent before the worst sanctionsNevada Rule 37(e) allows an adverse-inference instruction for lost electronically stored information only on a finding that the party intended to deprive the other side of it.
• Nevada execution: the thirty days do not start until notice of entry is servedNevada NRCP 62(a) runs its 30-day stay from service of written notice of entry, and NRCP 69(b) bars execution until that notice has been served.

New Hampshire — New Hampshire Superior Court Civil Rules

• Responding to a New Hampshire complaint: 30 days, and your jury demand goes on page oneNew Hampshire Superior Court Rule 9 gives 30 days to file an Answer or a Motion to Dismiss — and a defendant who does not request a jury on the first page of the Answer waives the right.
• Striking off a New Hampshire default: a motion is not enough without an affidavit of defenseNew Hampshire Superior Court Rule 42 lets a default be stricken only on motion and affidavit of defense, specifically setting out the defense and the facts behind it.
• New Hampshire summary judgment: page, paragraph and line references, and a 25-page capNew Hampshire Superior Court Rule 12(g) caps a summary judgment motion and memorandum at 25 pages and requires specific page, paragraph and line references to the record.

New Jersey — New Jersey Rules of Civil Procedure

• Responding to a New Jersey complaint: 35 days, the longest answer period in the countryNew Jersey gives a defendant 35 days after service of the summons and complaint to serve an answer, including any counterclaim — longer than any other state, and longer than the federal 21 days.
• New Jersey discovery deadlines: 60 days for interrogatories, and you cannot agree to moreNew Jersey gives 60 days to answer interrogatories, 35 days to respond to a document request, and 30 days for requests for admission — and consent orders enlarging the interrogatory time are prohibited.
• The New Jersey affidavit of merit: 60 days per defendant, and a conference that does not save youNew Jersey's affidavit of merit runs 60 days from each defendant's answer, extendable once by 60 days — and Rule 4:5B-4's case management conference does not toll it.
• The New Jersey discovery track: 150, 300 or 450 days, and a clock that starts without youNew Jersey assigns every civil case to a track at filing, and Rule 4:24-1 runs the discovery period from the first answer filed or 90 days after the first defendant is served — whichever comes first.
• New Jersey summary judgment: 28/10/4, and a statement of material facts that decides the motionNew Jersey Rule 4:46 runs summary judgment on a 28/10/4-day cycle and requires a separate numbered statement of material facts — anything not specifically disputed is deemed admitted.
• New Jersey reconsideration: 20 days for a final judgment, no deadline for an interlocutory orderNew Jersey R. 4:49-2 gives 20 days from service to move for reconsideration of a judgment or final order — but interlocutory orders run on R. 4:42-2(b), which has no deadline at all.
• Compelling discovery in New Jersey: the two-stage dismissal that ends casesNew Jersey R. 4:23-5 dismisses a delinquent party's pleading without prejudice first, then with prejudice after 60 days — and restoration costs $100, $300, or more depending on when you move.
• Setting aside a New Jersey default: bring the answer and the filing fee with the motionNew Jersey R. 4:43-3 requires a motion to vacate an entry of default to arrive with an answer or dispositive motion and the filing fee — and a default judgment goes to R. 4:50 instead.
• The New Jersey motion to dismiss: thirty-five days to answer, ninety to moveNew Jersey R. 4:6-2 lists six defenses, and R. 4:6-3 requires three of them to be raised by motion within 90 days after service of the answer.
• New Jersey execution: ten days' notice before your property is turned over, and exempt deposits are excluded automaticallyNew Jersey R. 4:59-1 requires the creditor to serve an endorsed writ at least 10 days before turnover, and excludes electronically deposited exempt funds from any levy.

New Mexico — New Mexico Rules of Civil Procedure

• Responding to a New Mexico complaint: 30 days, and ten from the court's actionNew Mexico Rule 1-012 NMRA gives 30 days after service of the summons and complaint to serve an answer, and ten days after the court's action on a pre-answer motion — counted from the ruling, not from notice.
• Setting aside a New Mexico default judgment: a consumer debt pleading failure is written into the ruleNew Mexico Rule 1-060(B)(6) names a debt collector's failure to comply with the consumer debt pleading rules as a ground for relief from judgment.
• The New Mexico motion to compel: the motion itself must state that you triedNew Mexico Rule 1-037 requires the motion to state that counsel made a good faith effort to resolve the issue before filing, and shifts fees both ways.
• The New Mexico motion to dismiss: thirty days to answer, ten after a denialNew Mexico Rule 1-012(B) carries the familiar seven defenses, gives 30 days to answer, and 10 days after a motion is denied.
• New Mexico execution: there is no automatic stay, and collection can begin the day judgment is enteredNew Mexico Rule 1-062 gives a judgment debtor no automatic stay — execution may issue on entry — and a supersedeas stay starts only when the district court approves the bond.

New York — New York Civil Practice Law and Rules

• Served in New York: is it 20 days or 30? It depends on how they served youCPLR 320 sets 20 days for in-hand service and 30 days for most other methods — including deliver-and-mail, the method most often used. Here's how to tell which applies.
• Vacating a New York default judgment: CPLR 5015, CPLR 317, and which one fitsCPLR 5015(a)(1) gives one year from service of notice of entry. CPLR 317 gives a different route — up to five years — to a defendant who wasn't personally handed the summons.
• New York summary judgment: the note of issue starts the clock, and 120 days ends itCPLR 3212(a) ties the summary-judgment deadline to the note of issue — 120 days unless the court sets an earlier date. Late motions need leave on good cause shown.
• The New York 90-day demand: what CPLR 3216 requires before a case can be dismissed for delayCPLR 3216 lets a court dismiss for failure to prosecute — but only after three conditions precedent, including a written demand giving 90 days to file a note of issue.
• New York discovery sanctions: CPLR 3126's threshold, and why "wilfully" does the workCPLR 3124 lets you move to compel. CPLR 3126 supplies the sanctions — but only against a party who refuses to obey an order or wilfully fails to disclose.
• The New York motion to dismiss: eleven grounds, one motion, and three different waiver rulesCPLR 3211 allows one pre-answer motion on any of eleven grounds. Which ground you pick decides whether it survives being left out — and one of them has a separate 60-day trap.
• Amending a New York pleading: three windows under CPLR 3025(a), and what leave requiresCPLR 3025(a) gives one amendment without leave through any of three separate windows. After that, leave is "freely given" — but the motion must attach the proposed pleading marked up.
• New York TROs and preliminary injunctions: no expiry date, a mandatory undertaking, and vacatur without noticeCPLR article 63 puts no fixed expiry on a temporary restraining order, requires an undertaking before a preliminary injunction issues, and lets a restrained defendant move to vacate without notice.
• New York discovery deadlines: twenty days, almost everywhereThe CPLR runs on 20 days — to answer interrogatories, to object to a document notice, and as the minimum notice period for production. It is the shortest set in the country.
• Serving a New York summons: deliver-and-mail, nail-and-mail, and the ten days that followCPLR 308 sets five methods of serving a natural person in New York — and for two of them, service is not complete until ten days after proof of service is filed.
• New York statutes of limitations: six, three, two and a half, and oneNew York's CPLR limitations periods run six years for contract, three for personal injury and property damage, two and a half for medical malpractice, and one for the intentional torts.
• Reargue or renew in New York: two different motions, one of which has a deadlineCPLR 2221 splits post-order relief into reargument — 30 days, no new facts — and renewal, which requires new facts and a reasonable justification for not offering them the first time.
• The New York bill of particulars: thirty days, and objecting to one item doesn't buy time on the restCPLR 3042 gives thirty days to respond to a demand for a bill of particulars — and objecting to some items does not excuse responding in full to the ones you don't object to.
• The New York notice to admit: twenty days, a sworn response, and silence admitsCPLR 3123 deems every matter admitted unless the responding party serves a sworn denial within twenty days — and an unreasonable refusal to admit can carry the cost of proving the point.
• Quashing a New York subpoena: ask the issuer first, and move promptlyCPLR 2304 requires a motion to quash a subpoena to be made promptly — and where the subpoena is not returnable in a court, you must first ask the person who issued it to withdraw or modify it.
• Enforcing a New York money judgment: 10% of gross, and two bank restraints a yearNew York caps an income execution at 10% of gross income and limits a creditor to two restraining notices per year on a natural person's bank account.

North Carolina — North Carolina Rules of Civil Procedure

• Responding to a North Carolina complaint: 30 days, and the 30 more you can get by agreementNorth Carolina gives 30 days to answer. Rule 6(b) also lets the parties stipulate to as much as 30 additional days without asking the court — a right most states don't grant.
• North Carolina discovery deadlines: 30 days — but 45 if you're the defendantNorth Carolina gives a defendant 45 days from service of the summons and complaint to answer written discovery, not the usual 30. Requests can also arrive with the summons itself.
• North Carolina summary judgment: 10 days to the hearing, and a 2-day affidavit rule that means actual receiptN.C. Rule 56(c) requires the motion 10 days before the hearing and opposing affidavits 2 days before — and for that 2-day rule, service means the other side actually receives it.
• North Carolina Rule 9(j): the certification goes in the complaint, or the case is dismissedNorth Carolina Rule 9(j) requires a medical malpractice complaint to assert that an expert has reviewed the care and will testify it fell below the standard — with a 120-day extension available only before the limitations period runs.
• North Carolina default judgment: the clerk enters it, and three days' notice if you appearedNorth Carolina Rule 55 lets the clerk enter both the default and, on a sum certain, the judgment — with three days' written notice to a party who has appeared, and Rule 60(b)'s one-year outer limit to undo it.
• Serving a North Carolina summons: 60 days, then endorsement or an alias and pluriesNorth Carolina Rule 4 gives 60 days to serve a summons and keeps the action alive by endorsement or an alias and pluries summons — each available within 90 days of the last one.
• The North Carolina motion to dismiss: an extension of time waives nothingNorth Carolina Rule 12(b) lists seven defenses that may be raised by motion, and says expressly that getting an extension of time to answer waives none of them.
• The North Carolina motion to compel: a total non-response needs no order firstNorth Carolina Rule 37(d) allows sanctions for a complete failure to respond without any prior order — and fees are mandatory whichever way the motion goes.
• North Carolina execution: a discretionary stay hands back the appeal time it consumedNorth Carolina Rule 62(a) bars execution until the notice-of-appeal period expires, and Rule 62(b) restarts that period when a discretionary stay ends.

North Dakota — North Dakota Rules of Civil Procedure

• Responding to a North Dakota complaint: 21 days, and the plaintiff must produce the paperNorth Dakota Rule 12(a) gives 21 days after service of the summons and complaint to serve an answer — and a default judgment on a written instrument requires the plaintiff to produce it.
• Setting aside a North Dakota default judgment: your year runs from entry, not from noticeNorth Dakota Rule 60(c) gives a party who appeared one year from notice of entry — but a defaulted defendant only one year from entry of the judgment itself.
• The North Dakota motion to dismiss: twenty-one days, then fourteenNorth Dakota Rule 12(b) carries the familiar seven defenses, gives 21 days to answer and 14 after a denied motion.

Ohio — Ohio Rules of Civil Procedure

• Responding to an Ohio complaint: 28 days, and the notice you get before a default judgmentOhio gives 28 days to answer — not 20, not 30. And if you have appeared in the case, Civ.R. 55(A) requires seven days' written notice before a default judgment can be taken.
• Ohio summary judgment: leave is required once the case is set for trialOhio Civ.R. 56 has no fixed briefing schedule, but it does have a gate no other rule we cover imposes — once a case is set for pretrial or trial, a motion requires leave of court.
• Ohio discovery deadlines: the requesting party sets the date, subject to a 28-day floorOhio is the rare system where the party serving discovery designates the response date. It cannot be less than 28 days — and interrogatories are capped at 40, not 25.
• Setting aside an Ohio judgment: Civ.R. 60(B), one year, and the notice you should have received firstOhio Civ.R. 60(B) gives five grounds with a one-year cap on the first three. Before you get there, check whether Civ.R. 55(A)'s seven-day notice was ever sent.
• Ohio requests for admission: 28 days, quote each request, and silence admits conclusivelyOhio Civ.R. 36 admits a matter automatically if no answer is served within 28 days — and an admission is conclusively established unless the court permits withdrawal.
• Stopping an Ohio wage garnishment: five business days to ask for a hearingOhio requires a creditor to make a 15-day demand before garnishing wages, and gives the debtor five business days from receiving the notice to request a hearing with the clerk of court.
• Garnishing wages in Ohio: the fifteen-day demand comes firstAn Ohio judgment creditor cannot apply for a wage garnishment until it has made a written demand giving the debtor fifteen days to pay — and the application then runs on a prescribed affidavit and notice.
• The Ohio motion to dismiss: twenty-eight days to answer, and one motion to raise everythingOhio Civ.R. 12(B) lists seven defenses that may be raised by motion — and Civ.R. 12(G) requires them all in one motion, or the omitted ones are gone.
• The Ohio motion to compel: certify the conference, or the fee award goes the other wayOhio Civ.R. 37 requires a good faith conference certification on every motion to compel, and shifts fees to whichever side loses the motion.

Oklahoma — Oklahoma Code of Civil Procedure

• Responding to an Oklahoma petition: 20 days, and the extension that costs you defensesOklahoma § 2012 gives 20 days after service of the summons and petition to answer — and offers a 20-day reservation of time that waives six of the defenses listed in the same section.
• The Oklahoma motion for new trial: ten days, nine grounds, and a fallback if nobody mailed you the judgmentOklahoma gives ten days from the filing of a conforming judgment to move for a new trial — with a separate ten-day clock if the court records don't show the judgment was mailed to you.
• The Oklahoma motion to compel: a statute, and fees run both waysOklahoma's discovery sanctions provision is 12 O.S. § 3237, which requires a good faith certification and makes an expense award mandatory whichever way the motion goes.
• The Oklahoma motion to dismiss: ten grounds, and capacity counts twiceOklahoma's 12 O.S. § 2012(B) lists ten defenses — more than any state but Missouri — including separate grounds for lack of capacity to sue and to be sued.
• Oklahoma summary judgment: twenty days, and the court narrows what it cannot decideOklahoma's 12 O.S. § 2056 lets a claimant move 20 days after commencement and directs the court to determine which material facts are not genuinely at issue when the motion fails.

Oregon — Oregon Rules of Civil Procedure

• Responding to an Oregon complaint: 30 days, and nine defenses you can raise by motionOregon gives 30 days from service to appear and defend. ORCP 21 A lists nine defenses that may be raised by motion instead of in the answer — a longer list than the federal rule's seven.
• Oregon discovery: there are no interrogatoriesORCP 36 A lists Oregon's discovery methods, and written interrogatories are not one of them. Oregon is the outlier among American civil systems, and it changes how a case is built.
• Oregon summary judgment: 60 days before trial, and a standard written into the ruleORCP 47 C requires the motion 60 days before trial, gives 20 days to oppose and 5 to reply — and it is one of the few rules that defines "no genuine issue" in its own text.
• Setting aside an Oregon judgment: ORCP 71, one year, and a pleading you must attachORCP 71 B gives five grounds for relief from an Oregon judgment. For the first three, the motion must be accompanied by a pleading asserting a claim or defense — and filed within one year.
• Amending an Oregon pleading: one free amendment, and what it means for a party already in defaultORCP 23 A gives one amendment as of right before a responsive pleading is served — and contains an unusual provision about serving amended pleadings on parties already in default.
• The Oregon ORCP 21 motion to dismiss: nine defenses, evidence without conversion, and one free jurisdiction motionORCP 21 A lists nine defenses that may be raised by motion — two more than the federal rule — lets the court decide most of them on evidence without converting to summary judgment, and exempts jurisdiction motions from the consolidation trap.
• Oregon depositions: no hour limit, a three-day designation rule, and a separate track for trial testimonyORCP 39 sets no cap on the length or number of depositions, requires an organization to designate its witnesses at least three days out, and runs perpetuation depositions on their own 14-day track.
• Oregon requests for admission: a warning in capital letters, 30 requests, and 45 days for a defendantORCP 45 requires every set of requests for admission to open with a capitalised warning that silence admits, caps the total at 30, and gives a defendant 45 days from service of the summons.
• Oregon post-trial motions: 10 days to file, 55 days to be decided, and one motion you must join or loseORCP 64 and 63 both give 10 days to move and 55 days for the court to rule, after which the motion is conclusively deemed denied — and a new trial motion not joined with a JNOV motion is waived.
• The Oregon motion to compel: list what you want at the top of the motionOregon ORCP 46 A(2) requires the motion to identify, at its beginning, the items sought — and includes insurance agreements and expert reports among the things you can compel.

Pennsylvania — Pennsylvania Rules of Civil Procedure

• Responding to a Pennsylvania complaint: 20 days, preliminary objections, and why a general denial admitsPennsylvania gives 20 days to plead to a complaint. It also makes a general denial operate as an admission — a rule with no equivalent in most states.
• The Pennsylvania ten-day notice: what it means and the ten days that come after judgmentPa.R.C.P. 237.1 stops the prothonotary entering a default judgment without ten days' written notice. Rule 237.3 then gives ten days after entry when opening the judgment is mandatory.
• Pennsylvania summary judgment: two grounds, thirty days to respond, and no resting on the pleadingsPa.R.C.P. 1035.2 splits summary judgment into two distinct grounds, and Rule 1035.3 gives the adverse party 30 days to file a response identifying record evidence.
• Pennsylvania discovery deadlines: 30 days, and answers go in the spaces providedPennsylvania uses 30 days for interrogatories, document requests and admissions — and Rule 4006 requires verified answers inserted into the interrogatories themselves.
• The Pennsylvania certificate of merit: 60 days, and a clerk can end your casePennsylvania Rule 1042.3 requires a certificate of merit in any professional liability action, with the complaint or within 60 days — and a defendant can take judgment of non pros by praecipe, without a hearing.
• Serving Pennsylvania original process: 30 days, and the reinstatement that keeps a case alivePennsylvania Rule 401 gives 30 days to serve original process inside the Commonwealth — and lets a complaint be reinstated or a writ reissued at any time and any number of times.
• Joining a Pennsylvania additional defendant: 60 days, and no third-party practicePennsylvania Rule 2253 gives a defendant 60 days after service of the plaintiff's initial pleading to join an additional defendant — a practice broader than federal third-party joinder and easy to miss.
• Opening a Pennsylvania default judgment: ten days changes everythingPennsylvania gives a defendant who petitions within ten days of a default judgment a rule that says the court "shall open" it — a far easier standard than the one that applies on day eleven.
• Pennsylvania preliminary objections: eight grounds, all at once, and a twenty-day clock at both endsPennsylvania replaces most Rule 12 motions with preliminary objections under Pa.R.C.P. 1028 — eight enumerated grounds, all of which must be raised in a single filing, with twenty-day windows on both sides.
• The Pennsylvania motion to compel: winning earns you nothing, losing costs youPennsylvania Rule 4019 makes fees discretionary when a sanctions motion is granted but mandatory against the movant when it is denied — and no fees at all on the first motion.
• Pennsylvania garnishment: a stalled garnishment can be terminated after a yearPennsylvania Rule 3111 attaches property that arrives after service, and lets the garnishee or the defendant petition to terminate a garnishment untouched for a year.

Rhode Island — Rhode Island Superior Court Rules of Civil Procedure

• Responding to a Rhode Island complaint: 20 days, and ten days' notice before judgmentRhode Island Rule 12(a) gives 20 days after service to serve an answer, or 60 days if you waived service — and an appearing defendant gets ten days' notice before a default judgment, the longest in the country.
• Setting aside a Rhode Island default judgment: ten days' notice, and no judgment without a military affidavitRhode Island requires ten days' written notice before a default judgment hearing — the longest in the country — and bars any default judgment until a military service affidavit is filed.
• The Rhode Island motion to dismiss: twenty days to answer, ten after a denialRhode Island Rule 12(b) carries the familiar seven defenses, gives 20 days to answer, and 10 days after a motion is denied.
• Rhode Island wage attachment: a hearing before your employer is ever served, and not objecting waives nothingRhode Island Rule 69(f) requires a motion, notice and a hearing before any post-judgment wage attachment, and says a debtor's failure to object waives no statutory exemption.

South Carolina — South Carolina Rules of Civil Procedure

• Responding to a South Carolina complaint: 30 days, and a default entered on the calendarSouth Carolina Rule 12(a) gives 30 days to serve an answer, with 60 or 90 days for the State in post-conviction matters — and the clerk enters default on the calendar, or file book.
• Answering a South Carolina summons: thirty days, and five defenses you lose by not raisingSCRCP 12(a) gives a defendant 30 days to answer a complaint in South Carolina — and Rule 12(h)(1) waives five defenses outright if they are left out of the first motion or the answer.
• Setting aside a South Carolina default judgment: good cause before judgment, five grounds afterSouth Carolina Rule 55(c) sets aside an entry of default for good cause, but a default judgment runs on Rule 60(b) — which lists only five grounds, with no catch-all.
• South Carolina summary judgment: ten days out, and two days to opposeSouth Carolina Rule 56 runs on the hearing date — the motion is served 10 days before it, and opposing affidavits are due only 2 days before.
• South Carolina execution: ten days, and a supersedeas stay does not start until the bond is approvedSouth Carolina Rule 62 bars execution for 10 days after entry, and a stay on appeal takes effect only when the court approves the supersedeas bond — not when it is filed.
• The South Carolina motion to dismiss: eight grounds, and the test is facts, not a claimSouth Carolina Rule 12(b)(6) asks whether the pleading states facts sufficient to constitute a cause of action, and adds a parallel-action ground the federal rule lacks.

South Dakota — South Dakota Rules of Procedure in Circuit Courts

• Responding to a South Dakota complaint: 30 days to answer, but 20 for a cross-claimSouth Dakota SDCL § 15-6-12 gives 30 days after service of the complaint to serve an answer but only 20 days for cross-claim answers and replies — and 20 days after a dismissal is reversed on appeal.
• Setting aside a South Dakota default judgment: relief survives for a defendant never actually notifiedSouth Dakota § 15-6-60(b) preserves the court's power to grant relief to a defendant not actually personally notified — a route that sits outside the one-year limit.
• The South Dakota motion to dismiss: six grounds, and venue is not among themSDCL § 15-6-12 lists six defenses that may be raised by motion, omitting improper venue, and gives twenty days to answer and ten after a denial.

Tennessee — Tennessee Rules of Civil Procedure

• Responding to a Tennessee complaint: 30 days, and five days' notice before any defaultTennessee gives 30 days to answer a complaint, and Rule 55.01 requires five days' written notice of a default application to every defendant — whether or not they ever appeared.
• Tennessee discovery deadlines: 30 days, 45 if you are the defendantTennessee gives 30 days to answer interrogatories, respond to document requests, and answer requests for admission — with 45 days for a defendant counted from service of the summons and complaint.
• The Tennessee motion to dismiss: four defenses you cannot rescue by amendingTennessee Rule 12.02 lists eight defenses, and Rule 12.08 says four of them cannot be raised by amendment — a harder waiver rule than the federal one.
• Setting aside a Tennessee default judgment: five days' notice, and only five groundsTennessee Rule 55.01 requires five days' written notice before a default judgment even if you never appeared — and Rule 60.02 offers five grounds, not six.
• Tennessee summary judgment: thirty days out, five days back, and three ways to answer each factTennessee Rule 56.03 requires a numbered statement of facts and lets the opponent agree a fact is undisputed for purposes of the motion only — a middle option most states lack.
• The Tennessee motion to compel: no certification required, but fees run both waysTennessee Rule 37 imposes no conference certification requirement, but makes an expense award mandatory whether the motion is granted or denied.
• Tennessee garnishment: the bank balance on the night of service, and ten years to collectTennessee Rule 69.05 catches a bank balance as it stood the night of service, gives the garnishee ten days to answer, and makes a silent garnishee liable for the whole judgment.

Texas — Texas Rules of Civil Procedure

• Answering a lawsuit in Texas: the Monday deadline and what an answer has to sayTexas doesn't give you 20 days to answer a lawsuit. It gives you until 10:00 a.m. on a Monday. Here's how that deadline works and what the rules require an answer to contain.
• Default judgments in Texas: what the plaintiff has to prove and when the court can sign oneA missed answer deadline in Texas doesn't produce a judgment the next morning. Rule 239 and Rule 107 set conditions the plaintiff has to meet first. Here's what they are.
• Setting aside a default judgment in Texas: the thirty-day window, and what happens after it shutsTexas gives a trial court thirty days of plenary power over its own judgment. Rules 320, 329b and 306a decide how long that window really lasts — and what's left when it closes.
• How you get served in Texas — and what each method does to your deadlineTexas allows personal delivery, certified mail, substituted service, out-of-state service, publication and waiver. The method changes the proof required — and sometimes the clock.
• Responding to an eviction in Texas: the trial date, the four-day rule, and why an answer isn't the pointA Texas eviction runs on a schedule set by Rule 510, not by Rule 99. Trial is 10 to 21 days after filing, an answer is optional, and appearing at trial is what actually matters.
• Appealing a Texas eviction: five days, and the rent you have to keep payingRule 510.19 gives five days to appeal a justice court eviction — and a second five-day deadline to pay rent into the court registry. Missing either can produce a writ of possession without a hearing.
• Texas discovery levels: what Level 1, 2 and 3 actually limitEvery Texas case is governed by a discovery control plan, and the plaintiff has to name the level in the first paragraph of the petition. Here's what each level allows.
• Responding to written discovery in Texas: thirty days, and the deadlines that bite hardestTexas gives 30 days to respond to interrogatories, requests for production and requests for admission. Miss the last one and the requests are admitted with no court order required.
• Amending pleadings in Texas: the seven-day line and the substitute-pleading ruleTexas lets parties amend freely until seven days before trial. After that, leave is required — but Rule 63 says the judge must grant it unless the other side shows surprise.
• Dismissal for want of prosecution in Texas: the notice, the thirty days, and the seventy-five-day cliffRule 165a lets a Texas court dismiss a case for failing to appear or for missing time standards — and gives 30 days to move for reinstatement, on a standard the rule spells out.
• The Texas special appearance: why Rule 120a has to be filed before anything elseRule 120a lets a defendant contest personal jurisdiction in Texas — but it must be sworn and filed before any other plea, and every non-complying appearance is a general appearance.
• Texas TROs and temporary injunctions: fourteen days, a bond with two sureties, and a trial settingA Texas TRO expires in 14 days, requires a bond with two or more sureties before it issues, and every temporary injunction order must set the case for trial on the merits.
• Texas summary judgment under the rewritten Rule 166a: every deadline now runs forward from filingThe amended Rule 166a replaced Texas's old 21-days-before-hearing rule. The response is due 21 days after the motion is filed, the reply 7 days after that, and the title of the motion is now mandatory.
• The Texas nonsuit: an absolute right, with four things it does not get you out ofTexas Rule 162 lets a plaintiff take a nonsuit any time before introducing all its evidence, without a court order — but it does not defeat a counterclaim, pending sanctions, fees, or costs.
• The Texas motion for new trial: 30 days to file, 75 days to be overruled by silenceTexas Rule 329b gives 30 days from the signing of the judgment to file a motion for new trial — and overrules it automatically at 75 days if the court never signs an order.
• The Texas motion to transfer venue: file it first, or you have waived itTexas Rule 86 waives an objection to improper venue unless it is filed before or with the defendant's first pleading — and Rule 87 requires 45 days' notice of the hearing.
• Collecting a Texas judgment: thirty days, then execution — and wages are mostly off the tableTexas execution cannot issue until thirty days after a final judgment is signed, and the debtor gets to designate which property is levied on first.
• The Texas motion to dismiss: Rule 91a runs on a 60-day clock and the loser can pay the feesTexas Rule 91a lets a party dismiss a cause of action with no basis in law or fact — but the motion must be filed within 60 days, ruled on within 45, and the court may award fees to the winner.
• The Texas motion to compel: you can skip straight to sanctions, but not the certificateTexas Rule 215.1 lets a party seek sanctions without first obtaining an order compelling discovery — but Rule 191.2 requires a certificate of conference on every discovery motion.

Utah — Utah Rules of Civil Procedure

• Responding to a Utah complaint: 21 days in state, 30 days out of stateUtah Rule 12(a) gives 21 days to file and serve an answer if you were served inside Utah and 30 days if you were served outside it — and a motion aimed at some claims does not delay the rest.
• Utah initial disclosures: 14 days for a plaintiff, 42 for a defendantUtah Rule 26(a)(2) gives a plaintiff 14 days after the first answer to serve initial disclosures and a defendant 42 days after filing its own answer — with no meet-and-confer trigger.
• Utah's statement of discovery issues: four pages, seven days, and one attachmentUtah does not use a conventional motion to compel — Rule 37 requires a four-page statement of discovery issues in a prescribed order, with a seven-day objection window.
• Setting aside a Utah default judgment: ninety days, not one yearUtah Rule 60(c) caps mistake, newly discovered evidence and fraud at 90 days after entry — where nearly every other state allows a full year.
• Utah summary judgment: restate each disputed fact verbatim, or it is admittedUtah Rule 56(a)(2) requires the opposing memorandum to restate each disputed fact verbatim with record citations — and any fact not disputed is deemed admitted for the motion.
• The Utah motion to dismiss: a partial motion leaves you on two clocks at onceUtah Rule 12(a) says a motion directed to fewer than all the claims does not extend the time to answer the rest — so a partial motion leaves the answer deadline running.
• The Utah writ of garnishment: fourteen days to reply, and silence makes the answers trueUtah Rule 64D gives 14 days to reply to a garnishee's answers — and a person who fails to reply is treated as having no exemption and no dispute.

Vermont — Vermont Rules of Civil Procedure

• Responding to a Vermont complaint: 21 days, and there is no entry of defaultVermont Rule 12(a) gives 21 days after service to serve an answer, or 49 days if served outside the continental United States or Canada — and Vermont has abolished the entry of default entirely.
• Setting aside a Vermont default judgment: the plaintiff had to swear to liability, not just damagesVermont has no entry of default — only a motion for default judgment, which requires an affidavit on personal knowledge setting out facts as to both liability and damages.
• The Vermont motion to dismiss: twenty-one days to answer, fourteen after a denialVermont Rule 12(b) carries the familiar seven defenses, gives 21 days to answer and 14 days after a motion is denied.

Virginia — Rules of the Supreme Court of Virginia

• Responding to a Virginia complaint: 21 days, no general denial, and default that waives your juryVirginia gives 21 days to respond. Missing it puts you in default automatically — and a defendant in default is deemed to have waived the right to a jury trial.
• Virginia discovery deadlines: 21 days — the shortest in the countryVirginia gives 21 days to answer interrogatories, document requests and requests for admission, with 28 days for a defendant served at the outset. No other system we cover is shorter.
• Virginia's 21-day rule: the day the trial court loses your caseVirginia Rule 1:1 gives a trial court just 21 days after entry to modify, vacate or suspend a final judgment — after which its jurisdiction ends, whatever the merits.
• The Virginia nonsuit: one as of right, and the moment it expiresVirginia Code § 8.01-380 gives a plaintiff one nonsuit as a matter of right — but only before the evidence is struck, the jury retires, or the case is submitted to the court.
• The Virginia demurrer: state every ground, because unstated ones are not consideredVirginia Code § 8.01-273 requires a demurrer to state specifically the grounds relied on — and provides that no other grounds shall be considered by the court.
• Virginia garnishment: the exemption form must be attached, or no summons may issueVirginia bars a garnishment summons from being issued or served unless a notice of exemptions and claim for exemption form is attached — and a non-compliant summons is void.
• The Virginia motion to quash service: file it before or with your first pleadingVa. Code § 8.01-277 lets a defendant attack a defect in the issuance, service or return of process — but only by a motion filed before or simultaneously with any pleading to the merits.
• Setting aside a Virginia default judgment: three windows, and the last one has no excusable neglectVirginia gives good cause before judgment and a flexible standard for 21 days after — but once Rule 1:1 expires, § 8.01-428 allows only four narrow grounds.
• Virginia summary judgment: you usually cannot use the deposition you just tookVirginia Rule 3:20 bars a summary judgment motion based on discovery depositions unless all parties agree — with narrow exceptions for punitive damages and business-to-business cases.
• The Virginia motion to compel: get the discovery, then remember you may not be able to use itVirginia Rule 4:12 requires a good faith certification and makes fees mandatory both ways — but Rule 3:20 bars most of what you obtain from supporting summary judgment.

Washington — Washington Superior Court Civil Rules

• Served in Washington before anything was filed? That's allowed — and you still have 20 daysWashington lets a civil action be commenced by service alone, with no court file and no clerk-issued summons. CR 12(a) gives 20 days — or 60 in four specific situations.
• Washington summary judgment: 28 / 11 / 5 days, all counted backward from the hearingWashington CR 56(c) is one of the few state rules that fixes the whole briefing schedule — 28 days to move, 11 to oppose, 5 to reply — and the hearing must be more than 14 days before trial.
• Setting aside a Washington judgment: eleven grounds, and only three carry the one-year limitWashington CR 60(b) lists eleven grounds for relief from a judgment — nearly twice the federal six — and the one-year cap applies to only the first three.
• Washington discovery deadlines: 30 days, 40 for a defendant, and admissions must stand aloneWashington gives 30 days to respond to written discovery and 40 to a defendant served at the outset — and CR 36 forbids combining requests for admission with any other discovery.
• Amending a Washington pleading: attach a copy marked "proposed," and leave it unsignedWashington CR 15(a) gives one amendment as of course, then requires a proposed, unsigned copy attached to any motion to amend — and forbids amending by writing on the original.
• Washington TROs and preliminary injunctions: 14 days, a bond, and two days to move to dissolveWashington CR 65 lets a TRO issue without notice for up to 14 days, requires security in almost every case, and gives the restrained party a two-day route to move for dissolution.
• A Washington CR 12 motion to dismiss: seven defenses, 20 days or 60, and the nonparty-at-fault trapWashington CR 12 lists seven defenses that may be raised by motion, sets four different answer deadlines depending on how you were served, and turns nonparty fault into an affirmative defense that must be pleaded.
• Washington CR 59: 10 days to move, 30 days to be heard, and nine grounds ending in "substantial justice"Washington CR 59 covers new trial, reconsideration and amendment of judgments in one rule. The motion is due 10 days after entry and must be noted when filed, to be heard within 30 days.
• Washington depositions: 5 days' notice, 20 for video, 120 days before any camera — and a conduct code for remote testimonyWashington CR 30, amended effective October 1, 2024, sets a 5-day notice floor, bars video depositions in the first 120 days, gives three days to object to a remote notice, and writes rules for what may be on screen.
• Washington execution: ten days before anything can issue, and an appeal buys you four moreWashington CR 62(a) bars execution for 10 days after entry and stays enforcement on appeal only until 14 days after entry, so a late notice of appeal buys almost nothing.
• How a Washington lawsuit starts: service or filing, a 14-day demand, and service that can go voidWashington CR 3(a) lets a civil action be commenced by service alone, with nothing filed — but a defendant can demand filing within 14 days, and if the plaintiff misses it the service is void.
• Washington default judgments: five days' notice, a venue statement, and what happens after a yearWashington CR 55 requires a venue statement in every default motion, bars default judgment without proof of service on file, and demands 10 days' notice once a year has passed since service.
• Washington sanctions: no safe harbor under CR 11, and no discovery motion without a conferenceWashington CR 11 has no 21-day safe harbor, CR 26(g) bans general objections, and CR 26(i) bars the court from entertaining any discovery motion until counsel have conferred and certified it.

West Virginia — West Virginia Rules of Civil Procedure

• Responding to a West Virginia complaint: 30 days, and your answer needs a cover sheetWest Virginia Rule 12(a) gives 30 days after service of the summons and complaint to serve an answer — and every answer must be accompanied by a completed civil case information statement.
• Setting aside a West Virginia default judgment: your year starts at the docket notationWest Virginia Rule 55(d) applies Rule 58 to default judgments, so the one-year clock runs from the notation in the civil docket — not from the judge's signature.
• The West Virginia motion to dismiss: thirty days, then fourteenWest Virginia Rule 12(b) carries the familiar seven defenses, gives 30 days to answer, and 14 days after a denied motion.
• West Virginia execution: a suggestee execution runs a full year, and the creditor picks the return dateWest Virginia Rule 69 gives a writ of execution a return date of 30 to 90 days chosen by the creditor, and a writ of suggestee execution a return only after one year.

Wisconsin — Wisconsin Rules of Civil Procedure (Chs. 801-847)

• Responding to a Wisconsin summons: 20 days, or 45 in a tort caseWisconsin § 802.06(1) gives a defendant 20 days after service of the complaint to serve an answer — but 45 days where the defendant is an insurer or any cause of action is founded in tort.
• Wisconsin earnings garnishment: 80% is exempt, and answering stops itWisconsin exempts 80% of a debtor's disposable earnings from garnishment, and totally exempts them below the poverty line — and the garnishee must treat a debtor's answered exemption as true.
• Commencing a Wisconsin lawsuit: file first, then serve within 90 daysWisconsin commences a civil action by filing the summons and complaint together — but commencement holds only if an authenticated copy is served within 90 days of filing.
• Wisconsin small claims: the return date is the deadline, and the limit rises in 2027Wisconsin small claims actions run on a return date rather than a paper deadline — and the money limit for ordinary civil actions rises from $10,000 to $15,000 on 1 January 2027.
• Setting aside a Wisconsin judgment: eight grounds, and only two carry the one-year capWis. Stat. § 806.07 lists eight grounds for relief from a judgment — mistake and fraud expire at one year, but a void judgment and the catch-all do not.
• The Wisconsin motion to dismiss: ten defenses, and a 180-day discovery stayWis. Stat. § 802.06(2) lists ten defenses that may be raised by motion — and filing one to dismiss for failure to state a claim stays all discovery for up to 180 days.
• Opposing summary judgment in Wisconsin: five days, and you cannot rest on the pleadingsWisconsin gives an opposing party just five days before the hearing to serve affidavits under Wis. Stat. § 802.08(2) — and an adverse party who does not respond faces judgment.
• Compelling discovery in Wisconsin: fees follow the result — and can land on the attorneyWis. Stat. § 804.12 shifts the costs of a motion to compel to whoever loses it, and unusually allows the award to be made against the attorney who advised the conduct or the motion.

Wyoming — Wyoming Rules of Civil Procedure

• Responding to a Wyoming complaint: 20 days, 30 if you were served out of stateWyoming Rule 12(a) gives 20 days after service of the summons and complaint to serve an answer, 30 days if service was made outside Wyoming or by publication, and 60 days if you waived service.
• Setting aside a Wyoming default judgment: one year, and four things to check in the file firstWyoming Rule 60(c) allows one year on the first three grounds — but the strongest arguments usually come from what Rule 55 required before judgment could be entered.
• The Wyoming motion to dismiss: twenty days to answer, fourteen after a denialWyoming Rule 12(b) carries the familiar seven defenses but gives only 20 days to answer — a day short of the federal period.