Sample motion to reopen discovery in California.

This sample motion to reopen discovery in California is filed pursuant to Code of Civil Procedure section 2024.050(a) on the grounds that,

• (1) The Court recently continued the trial date,
• (2)  an order reopening discovery is necessary due to the fact that the moving party has a need to conduct additional discovery to assist in trial preparation and to prosecute the cross-complaint, and
• (3) The moving party has just filed an amendment to their complaint or cross-complaint substituting the true name of a defendant in place of a Doe or Roe defendant.

The sample motion has been revised and updated in 2018, is 11 pages and includes,

• Brief instructions,
• Memorandum of points and authorities with citations to case law and statutory authority,
• Sample declaration, and
• Proof of service.

The author is an entrepreneur and retired litigation paralegal that worked in California and Federal litigation from January 1995 through September 2017. 

Note that the author is NOT an attorney and no guarantee or warranty is provided.