This guide contains forms and instructions for propounding Requests for Production on your opponent in a California civil case. This guide contains forms and instructions for scheduling a deposition of an opposing party or third party witness in a California civil case.If a discovery dispute arises, the Court strongly encourages parties to request an IDC with the Court before reserving a hearing date for any discovery motion. Lawyer guide on motions to compel in Sacramento, California. This guide covers motions to compel interrogatories, document requests, and admissions. Aspx for the latest e-filing FAQs from the Sacramento Superior Court. 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. (b) Using a discovery method in a manner that does not comply with its specified procedures. Discover all the great programs we offer.