BILL ANALYSIS                                                                                                                                                                                                    






                             SENATE JUDICIARY COMMITTEE
                           Senator Ellen M. Corbett, Chair
                              2009-2010 Regular Session


          AB 2119 (Tran)
          As Introduced
          Hearing Date: June 10, 2010
          Fiscal: No
          Urgency: No
          TW:jd
                    

                                        SUBJECT
                                           
                      Civil Procedure:  Deadlines:  Computation

                                      DESCRIPTION  

          This bill, sponsored by the State Bar of California Committee on  
          Administration of Justice, would add to the Code of Civil  
          Procedure a definitive method of calculating specified action  
          deadlines, including the service and court filing of specified  
          motions, oppositions, and replies, as they pertain to court  
          hearings.

                                      BACKGROUND  

          California law provides deadlines for notice to be given of  
          hearings on certain motions and deadlines for service and filing  
          of motions, oppositions, and replies thereon.  Prior to 2004,  
          the Code of Civil Procedure calculated by calendar days the  
          service of specified moving, supporting, and opposing papers  
          regarding motions and other hearings, the deadline for the  
          completion of discovery proceedings prior to trial, and the  
          deadline for a demand for the exchange of information concerning  
          expert witnesses prior to trial.  AB 3078 (Assembly Judiciary  
          Committee, Chapter 171, Statutes of 2004) and AB 3081 (Committee  
          on Judiciary, Chapter 182, Statutes of 2004), among other  
          things, revised those deadlines by referring to court days  
          rather than calendar days. 

          This bill would further clarify the method for calculating these  
          deadlines by providing that they would be calculated by counting  
          backward from the date of the scheduled hearing and would  
          exclude the hearing date.
                                                                (more)



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                                CHANGES TO EXISTING LAW
           
           Existing law  provides that the time in which any act provided by  
          law is to be done is computed by excluding the first day, and  
          including the last, unless the last day is a holiday, and then  
          it is also excluded.  (Code Civ. Proc. Sec. 12.)

           Existing law  provides that the time for service and filing of  
          moving and supporting papers is at least 16 court days before  
          the hearing.  (Code Civ. Proc. Sec. 1005(b).)

           Existing law  provides that notice of a motion for summary  
          judgment and supporting papers shall be served at least 75 days  
          before the hearing.  (Code Civ. Proc. Sec. 437c.)

           This bill  would provide that, when calculating service and  
          filing deadlines of motions, oppositions, and replies, the  
          deadline will be counted backward from the hearing date,  
          excluding the day of the hearing.

           This bill  would provide that additional days added to the  
          deadline because of a particular method of service shall be  
          computed by counting backward from the deadline date.

                                        COMMENT
           
          1.  Stated need for the bill  
          
          The author writes:
          
            This bill clarifies the method of counting days in situations  
            where a statute requires that a certain act (such as service  
            of a brief) be done a specified number of days before a  
            hearing date.

            This bill provides that where the law requires that an act be  
            performed no later than a specified number of days before a  
            hearing date, the last day to perform that act will be  
            determined by counting backward from the hearing date,  
            excluding the day of the hearing.  The bill further provides  
            that any additional days that need to be added because of a  
            particular method of service will be computed by continuing to  
            count backward.
          
          2.  Existing statutes do not specify the method of counting  
                                                                      



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            deadlines relating to hearing dates  

          Existing law does not specify how a litigant should count -  
          backward from or forward to a hearing date - in order to  
          determine the last day to file and serve court papers.  The  
          court in Dahms v. Downtown Pomona Property & Business  
          Improvement (2009) 174 Cal.App.4th 708, 715 counted days  
          backward from a hearing to determine the proper deadline for  
          serving notice of the hearing.  On the other hand, the court in  
          Barefield v. Washington Mutual Bank (2006) 136 Cal.App.4th 299,  
          303 suggested that days should be counted forward to the hearing  
          date.   Barefield dealt with deadlines pertaining to a hearing  
          on a motion for summary judgment.  Typically with a motion for  
          summary judgment, moving parties request a hearing date from the  
          court that is at least 75 days from the date on which the moving  
          party will file and personally serve the motion.  To determine  
          the hearing date, the moving party counts forward 75 days.  The  
          method of counting becomes even more difficult when counting  
          "court days" (see Code of Civ. Proc. Sec. 437c) as well as  
          "calendar days" (see Code of Civ. Proc. Sec. 1005).  

          The sponsor of this bill, the State Bar of California Committee  
          on Administration of Justice, reports "at least one situation  
          where a party lost substantive rights because the party counted  
          backward from the hearing date, but the court counted forward  
          from the service date, which made service untimely."  As the  
          Judicial Council of California, a supporter of this bill, points  
          out, "AB 2119 rectifies this problem by providing a bright line  
          rule for counting time for service, providing clarity for both  
          litigants and the courts." 

          In order to definitively resolve the issue of counting deadlines  
          pertaining to court hearings, this bill would specify that these  
          deadlines will be determined by counting backward from the  
          hearing date.  This means that when the hearing date is unknown  
          (i.e., a motion for summary judgment), the hearing date will  
          first need to be determined by counting forward 75 days from the  
          projected filing and service date.  The filing and service  
          deadline then will need to be verified by counting backward from  
          the potential hearing date, excluding from the count the date of  
          the hearing, to make certain the filing and service deadlines do  
          not fall on a holiday and conforms to Code of Civil Procedure  
          Section 12.


           Support  :  California Judges Association; CompuLaw, LLC; Consumer  
                                                                      



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          Attorneys of California; Judicial Council of California;  
          Judicial Council of California; San Francisco Association for  
          Docket Calendar & Court Services

           Opposition  :  None Known

                                        HISTORY
           
           Source  :  State Bar of California Committee on Administration of  
          Justice

           Related Pending Legislation  :  None Known

           Prior Legislation  :  See Background.

           Prior Vote  :

          Assembly Judiciary Committee (Ayes 10, Noes 0)
          Assembly Floor (Ayes 76, Noes 0)

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