Practical Last Day to Serve Discovery (and be able to make a motion on it) – 90-100 days before trial. Deposition Notice – Defendant may serve any time.Document all contacts with the County Counsel and all actions taken in the Contact Notebook. File all correspondences in the case file. For a Request for Informal Discovery Conference, briefly describe the nature of the discovery dispute, including the facts and legal arguments at issue. This guide contains forms and instructions for propounding Requests for Production on your opponent in a California civil case. Make changes to the template. Take advantage of the top and left-side panel tools to change Los angeles informal discovery conference. Discovery is ongoing and Defendants reserve the right to supplement this response at a later time as appropriate. Conference the Court will impose tight deadlines to complete discovery.