You’ve just returned from lunch. Sitting on the top of your desk is a thick envelope from opposing counsel. You take a deep breath, and lo and behold, it’s a state court motion for summary judgment. You quickly put it aside. Later in the afternoon, you take a deep breath and decide to look at the motion, but before you do, repeat the following mantra five times: "This is an opportunity, not a burden."
Summary judgment motions must be served at least 75 days before the hearing and you need to file your opposition 14 days before the hearing. Although you get more time to respond to a motion for summary judgment, don’t wait. It’s probably a good idea to look at Code of Civil Procedure §437(c), which governs such motions.
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