You must complete discovery 30 days before your trial. This guide contains forms and instructions for responding to Requests for Production from your opponent in a California civil case.For a Request for Informal Discovery Conference, briefly describe the nature of the discovery dispute, including the facts and legal arguments at issue. Discovery is an important tool for parties in a lawsuit to get information to prepare for trial and to decide what issues to focus on in a case. This guide contains forms and instructions for propounding Requests for Production on your opponent in a California civil case. 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. Call Our 24 Hour Personal Injury Hotline 800-816-1529 X.1 What is Discovery? In early 2019, Governor Gavin Newsom signed into law three bills affecting discovery procedures in the California courts.