How many days notice IME California?

How many days notice IME California?

Motions for Summary Judgment – Notice is 75 days before hearing (+10 if outside CA, +20 if outside US) [CALIFORNIA CODE OF CIVIL PROCEDURE 437c(a)]. Opposition is 14 days before the hearing [CALIFORNIA CODE OF CIVIL PROCEDURE 437c(b)(2)]. Reply is 5 days before hearing. [CALIFORNIA CODE OF CIVIL PROCEDURE 437c(b)(3)].

What is a PMK notice?

An important purpose in any deposition of a person most knowledgeable (“PMK”) is to solicit testimony from the person who has the most knowledge about your specific topic, for the relevant period.

How much notice do I need to give for a deposition in California?

In most types of cases, for the deposition of a party to the case, you must provide at least 10 days’ notice if personally served, and 15 days’ notice if served by mail within California (California Code of Civil Procedure (CCP) § 2025.270(a), § 1013).

How many days before trial must a subpoena be served California?

For a Notice to Attend AND Bring Documents: You must have it served by mail at least 25 days before the court date. If it is delivered in person, it must be served at least 20 days before the court date.

What is a Pmq deposition?

Section 2025.230 requires the designated “Person Most Qualified” or “PMQ” to testify based upon information “known or reasonably available to” the deponent. Courts have construed this provision to require a PMQ designee to educate himself or herself as to information available to the entity on a given subject.

Can a witness be deposed more than once California?

P. 30(a)(2)(ii), which provides that a witness may not be deposed more than once absent a stipulation or leave of court.

How far in advance must a subpoena be served in California?

Serve the Notice. For a Notice to Attend AND Bring Documents: You must have it served by mail at least 25 days before the court date. If it is delivered in person, it must be served at least 20 days before the court date. A judge may order a shorter time for service, but you must ask for it.

How long can depositions be in California?

seven hours
(a) Except as provided in subdivision (b), or by any court order, including a case management order, a deposition examination of the witness by all counsel, other than the witness’ counsel of record, shall be limited to seven hours of total testimony.

How do you impeach a deposition testimony?

Best Practices

1. First, impeach with only one fact at a time.
2. Second, when impeaching with prior sworn testimony, you must read the questions and answers verbatim.
3. Third, be mindful of your tone.
4. Fourth, do not impeach with facts taken out of context.