State CourtDay 1: Initial Case Management Conference. Written discovery begins.
Day 60: Written discovery should be complete. If not, it’s ok. The judge will give you more time.
Day 120: Written discovery is complete, right? If not, the judge will be miffed but give you more time.
Day 150: Written discovery is done. [Most likely] You have party deposition dates, right?
Day 210: Your party depositions aren’t done? Fine. Tell the judge you have scheduling problems and get more time.
Day 240: Party depositions are done. Let’s come back in 30 days with the dates for treating physicians to give their depositions
Day 270: The dates aren’t set? Fine. Come back in 30 days. Get the dates set.
Day 300: The treating physicians dates are set. For the day before the next Court appearance.
Day 345: Turns out the treating physicians had to go to Cabo unannounced. Need to reschedule.
Day 400: Treating physicians are done. Let’s get a pre-trial settlement conference!
Day 460: Pre-Trial settlement conference happens. No settlement.
Day 475: Judge wants the expert depositions to go. Final. No if ands or buts.
Day 500: Expert depositions go. Finally. [We think.]
Day 540: Discovery is done. Let’s go to trial.
Federal CourtDay 1: Initial Case Management Conference.
Day 90: Discovery is done. Let’s go to trial.