Plaintiff 1
Time for a plaintiff to Serve a defendant with the summons and complaint after filing.
What is 120 days, but can be extended by the CT after notice or on motion.
Defendant's time to file pre-answer motions if service has been waived
60 days
Defendant's time to file an answer after their motion to dismiss has been denied
10 days.
Time to answer interrogatories. (both)
30 days. if served with complaint 45.
Notice required before scheduling pre trial conference
20 days
Time limit for demanding jury trial
10 days after service of last pleading directed to the issue on which the party seeks a jury.
Timing for a motion for attorney's fees
within 30 days after judgement or dismissal
Timing of a motion for remittitur
Within 15 days of rendition of verdict
Time to enter a case management order after completion of case management conference in a complex case
10 days
Plaintiff's time to reply to an asnwer
20 days after service of the answer.
Defendant's time to file an answer if service is not waived
20 days from date of service; FL Agencies/Employees 40 days.
Time for defendant to implead a party
20 days after service of defendant's answer. after this MUST seek leave of court
Time to answer request for production(both)
30 days if not served with complaint; 40 days if served with complaint
Time required for the initial case management conference after declaring an action to be complex litigation
within 60 days of the order declaring the case to be complex litigation
Time for a non-moving party's evidence to be submitted prior to summary judgement motion hearing
at least 20 days before the hearing
Timing for a motion to set aside a verdict
within 15 days after the verdict, but only if a motion for directed verdict was previously made
Timing for motion for additur
within 15 days of rendition of verdict
Time for the court to assign a case management track to a case
120 days after commencement of action
Plaintiff's time to file an answer to crossclaims or counterclaims?
20 days after service of the crossclaims or counter claims.
defendants time to file is service is waived
60 days from the date request was received
Defendant's timing for initial offer and demand for judgement
No sooner than 90 days after commencement of the action
Time to respond to request for examination.
30 days if not served with complaint; 45 if it is served with complaint
time for attorney's mandatory conference in complex litigation cases
at least 20 days prior to the initial case management conference
Latest time that either party may serve an offer and demand for judgement
no sooner than 45 days before trial date
Timing for a motion to disqualify the trial judge
within 20 days after a party learns of the need to disqualify
Timing for motion for relief from judgement
within a reasonable time
Time for a court to enter a case management order
120 days after commencement of the action or 30 days after service of complaint on last named defendant. whichever happens first.
Earliest Time plaintiff can take a deposition
30 days after service of process
defendant's time to file pre-answer motions if service is not waived
20 days, FL Agencies/Employees 40 days
When is a suit commenced
When plaintiff files the complaint.
time to respond to requests for admissions
within 30 days of service is not served with complaint, 45 days if served with complaint.
Time to file a notice of failure to prosecute
after at least 10 months of no record activity
Time for moving a party's evidence and motion to be submitted prior to a summary judgement motion.
motion and evidence must be served at least 40 days before the scheduled hearing
Timing for a motion for a new trial
within 20 days after the rendition of the verdict
Timing for motion for relief from judgment when there is fraud, new evidence, or mistake discovered
within 1 year of judgement being entered
Days within to serve initial mandatory disclosures
60 days after service of the complaint or joinder, unless a different time is set by court order
plaintiff's timing for initial offer and demand for judgement
no sooner than 90 days of the defendant being served with process
defendant's time to respond to a request for waiver of service. (domestic; outside of US)
20 days ; 30 days if outside of US
When is a case at issue
1. After any motions directed to the last pleading have been disposed of
2. if not such motions are served, 20 days after service of the last pleading
OR
3. The party entitled to have filed a motion directed at the last pleading can file a notice of trial after the service of the last pleading to accelerate the case being at issue.
Timing for issuance of subpoena duces tecum for production from a non-party
the requesting party must serve a notice of intent to issue the subpoena at least 10 days before issuance if service is by hand delivery or email, 15 days before subpoena before the subpoena is issued if service is by mail. if no objections, requesting party may issue SDT
Earliest time to file a motion for summary judgement
20 days after the commencement of the action OR after service of a motion for summary judgement by the adverse party.
Timing for a motion for directed verdict
after a party has rested their case and chief and can be made again at the close of all evidence
Computation of time
Don’t count the day of the triggering event.
Count the last day unless it’s a weekend/holiday → then go to next biz day.
If time period is ≤ 7 days, exclude weekends/holidays.
Add 5 days for service by mail.
Add 1 day for email/e-service, unless court order says no.
Time for filing notice of appeal
Within 30 days of the date of judgement or an order being entered
Time for scheduling the final case management conference in a complex case
No less than 90 days before set trial date.