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Appellate Practice

Apr. 6, 2000

Resetting the Clock

Resetting the Clock Discovery Timeline Automatically Restarts at New Retrial Date

James C. Martin

Partner Reed Smith LLP

Phone: (213) 457-8002

Email: jcmartin@reedsmith.com

James is in the firm's Appellate Group, resident in the Los Angeles and Pittsburgh offices. He is certified as specialists in appellate law by the California State Bar Board of Legal Specialization.

Benjamin G. Shatz

Partner Manatt, Phelps & Phillips LLP

Appellate Law (Certified), Litigation

Email: bshatz@manatt.com

Benjamin is a certified specialist in appellate law who co-chairs the Appellate Practice Group at Manatt in the firm's Los Angeles office. Exceptionally Appealing appears the first Tuesday of the month.

When a case is reversed on appeal and remanded for a new trial, do the litigants get to renew discovery? Beginning in 1993, California law appeared to provide an unfettered opportunity to conduct additional discovery after remand, with a new discovery timeline automatically recalibrating based on the date set for retrial. Beverly Hospital v. Superior Court, 19 Cal.App.4th 1289 (1993).

However, a later court-of-appeal opinion - Fairmont Insurance Co. v. Superior Court,...

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