The California discovery cutoff: 30 days, 15 for motions, and a continuance that changes nothing
California procedure · Last verified August 17, 2026
Three sentences in CCP 2024 govern the end of every California case's discovery, and two of them regularly surprise people: the deadline runs from the date initially set for trial, and continuing the trial does not move it.
The two deadlines
CCP 2024.020(a):
Except as otherwise provided in this chapter, any party shall be entitled as a matter of right to complete discovery proceedings on or before the 30th day, and to have motions concerning discovery heard on or before the 15th day, before the date initially set for the trial of the action.
Two separate numbers. Discovery closes at 30 days; the window for hearing discovery motions runs 15 days further.
That gap is not spare time — it is the only room you have to bring a motion about discovery you completed at the cutoff. A response served on day 30 leaves 15 days to meet and confer, file, and be heard. Given CCP 1005(b)'s 16 court days of notice, a motion filed on day 30 cannot be heard by day 15 at all.
Work backwards from the hearing, not the cutoff.
"Completed" has a definition
CCP 2024.010:
As used in this chapter, discovery is considered completed on the day a response is due or on the day a deposition begins.
Both halves are useful.
Written discovery is complete when the response is due — not when it is served, and not when you are satisfied with it. So the last day to serve interrogatories is 30 days before the cutoff plus whatever response period applies. For an ordinary 30-day response, that means serving roughly 60 days before the initial trial date, and longer if service is by mail.
A deposition is complete when it begins. A deposition that starts on the cutoff day and continues afterwards is timely.
The date initially set — and continuances
CCP 2024.020(b):
Except as provided in Section 2024.050, a continuance or postponement of the trial date does not operate to reopen discovery proceedings.
This is the provision that catches people. The trial goes out six months; discovery does not come back. Everything still runs from the date initially set, and reopening requires a motion under CCP 2024.050 or an agreement under CCP 2024.060.
Note the interaction with a new trial date rather than a continuance: CCP 2024.050(a) refers separately to leave "to reopen discovery after a new trial date has been set," and CCP 2024.060 permits an agreement to the same effect. Both routes exist precisely because subdivision (b) shuts the door by default.
Expert discovery closes later
CCP 2024.030 gives expert discovery its own, later pair of deadlines:
Any party shall be entitled as a matter of right to complete discovery proceedings pertaining to a witness identified under Chapter 18 (commencing with Section 2034.010) on or before the 15th day, and to have motions concerning that discovery heard on or before the 10th day, before the date initially set for the trial of the action.
So the calendar has four points on it:
| Deadline | Days before the date initially set for trial |
|---|---|
| Complete ordinary discovery | 30 |
| Complete expert discovery | 15 |
| Have ordinary discovery motions heard | 15 |
| Have expert discovery motions heard | 10 |
The expert track exists because the expert exchange itself happens late — CCP 2034.230(b) sets the exchange at 50 days before the initial trial date, and expert depositions follow it.
And there is one crossing point worth remembering. A supplemental expert designation under CCP 2034.280 requires the designating party to make the new experts "available immediately for a deposition … which deposition may be taken even though the time limit for discovery under Chapter 8 has expired." That is an express exception to the cutoff, and the only one of its kind.
Cases the chapter does not govern
CCP 2024.040(b)(1) — unlawful detainer. The chapter does not apply to summary proceedings for possession of real property. Instead, "except as provided in Sections 2024.050 and 2024.060, discovery in these proceedings shall be completed on or before the fifth day before the date set for trial."
Five days, in a case where responses are themselves due in five days under CCP 2030.260(b), 2031.260(b) and 2033.250(b). The whole unlawful detainer discovery schedule is compressed to match the summary nature of the proceeding.
CCP 2024.040(b)(2) — eminent domain, governed by Title 7 commencing with CCP 1230.010.
CCP 2024.040(a) — judicial arbitration. The time limit in an action to be arbitrated under CCP 1141.10 and following "is subject to Judicial Council Rule," and after an award in a case ordered to judicial arbitration, completion of discovery is limited by CCP 1141.24.
Reopening by motion
CCP 2024.050(a): on motion of any party, the court may grant leave
- to complete discovery closer to the initial trial date;
- to have a discovery motion heard closer to it; or
- to reopen discovery after a new trial date has been set.
A meet and confer declaration under CCP 2016.040 is required.
The four factors — subdivision (b). The court shall consider any relevant matter, "including, but not limited to":
(1) The necessity and the reasons for the discovery. (2) The diligence or lack of diligence of the party seeking the discovery or the hearing of a discovery motion, and the reasons that the discovery was not completed or that the discovery motion was not heard earlier. (3) Any likelihood that permitting the discovery … will prevent the case from going to trial on the date set, or otherwise interfere with the trial calendar, or result in prejudice to any other party. (4) The length of time that has elapsed between any date previously set, and the date presently set, for the trial of the action.
Factor (2) is where most of these motions are decided, and it asks two things: were you diligent, and why didn't you finish. Have an answer to the second before you file.
Sanctions — subdivision (c): mandatory against whoever unsuccessfully makes or opposes a motion to extend or reopen discovery, absent substantial justification.
Reopening by agreement
CCP 2024.060 is the cheaper route, and its requirements are precise:
Parties to an action may, with the consent of any party affected by it, enter into an agreement to extend the time for the completion of discovery proceedings or for the hearing of motions concerning discovery, or to reopen discovery after a new date for trial of the action has been set. This agreement may be informal, but it shall be confirmed in a writing that specifies the extended date. In no event shall this agreement require a court to grant a continuance or postponement of the trial of the action.
Three points. It needs the consent of any party affected, not just the two negotiating. It must be confirmed in writing with a date — the same formula the response-extension statutes use. And it binds only the parties: the court is not obliged to move the trial to accommodate it.
Working the calendar backwards
For a case with a trial date initially set on day 0, counting backwards:
| Days before trial | What happens |
|---|---|
| 81 | earliest date a summary judgment motion may be heard on 75 days' notice plus service time — see CCP 437c |
| 70 | last day to demand the expert exchange — CCP 2034.220 |
| ~60 | last practical day to serve 30-day written discovery so responses are due by the cutoff |
| 50 | expert information exchanged — CCP 2034.230(b) |
| 30 | ordinary discovery closes — CCP 2024.020(a) |
| 30 | supplemental expert designations due, 20 days after the exchange — CCP 2034.280 |
| 15 | expert discovery closes, and ordinary discovery motions must be heard — CCP 2024.030, 2024.020(a) |
| 10 | expert discovery motions must be heard — CCP 2024.030 |
Every one of those runs from the date initially set.
How California compares
| California | Washington | Oregon | Federal | |
|---|---|---|---|---|
| Discovery cutoff set by rule | yes — 30 days before trial | by case schedule order | by case schedule | by scheduling order |
| Separate expert cutoff | yes — 15 days | by case schedule | n/a | by scheduling order |
| Deadline to have motions heard | 15 days / 10 days | none | none | none |
| "Completed" defined | yes — CCP 2024.010 | no | no | no |
| Continuance reopens discovery | no | usually yes, via a new schedule | usually yes | usually yes |
| Reopening | motion with four factors, or written agreement | amended case schedule | amended schedule | good cause — Rule 16(b)(4) |
| Unlawful detainer | 5 days before trial | per RCW | per ORS | n/a |
A short checklist
- Write down the date initially set for trial. That is the anchor for everything, and it does not move when the trial does.
- Count 30 days back for ordinary discovery, 15 for expert.
- Serve written discovery about 60 days out so responses are due by the cutoff — more if you serve by mail.
- Book motion hearings early. Sixteen court days' notice plus a 15-day hearing deadline means a motion filed at the cutoff is already too late.
- A deposition is complete when it begins — so a cutoff-day start is timely even if it runs over.
- If the trial is continued, assume discovery stays closed until you have a CCP 2024.050 order or a CCP 2024.060 agreement.
- Get any agreement in writing with a specific date, and include every affected party.
- If you need a motion, be ready on diligence — factor (2) asks why you did not finish in time.
- In an unlawful detainer, the cutoff is five days, and responses are due in five.
- Remember the one express exception: a supplemental expert designated under CCP 2034.280 must be made available immediately, even after the cutoff.
Where these sections live
- CCP 2016.040 — Meet and confer declaration
- CCP 2024.010 — When discovery is considered completed
- CCP 2024.020 — The 30-day and 15-day deadlines
- CCP 2024.030 — Expert discovery deadlines
- CCP 2024.040 — Proceedings excluded from the chapter
- CCP 2024.050 — Motion to extend or reopen
- CCP 2024.060 — Extension by agreement
- CCP 2034.220 — Time to demand the expert exchange
- CCP 2034.230 — Date of the expert exchange
- CCP 2034.280 — Supplemental expert list
This page explains what the Code says. It isn't legal advice, and individual courts set trial-setting and case-management practices on top of these statutes.