California Motion for Summary Judgment

Count every period under Code Civ. Proc. §§ 12 and 12c

Time is computed by excluding the first day and including the last, unless the last day is a holiday, and then it is also excluded (§ 12); a period measured before a hearing is counted backward from the hearing date, excluding the day of the hearing, and days added for a method of service are counted backward from that day (§ 12c).

Move after 60 days have elapsed since each opposing party's general appearance (Code Civ. Proc. § 437c(a)(1))

Or at any earlier time after the general appearance that the court, with or without notice and upon good cause shown, may direct.

Assemble the papers rule 3.1350(c) requires

Notice of motion; separate statement of undisputed material facts; memorandum; evidence; and a request for judicial notice, if appropriate (Cal. Rules of Court, rule 3.1350(c)).

Serve the notice and papers at least 81 days before the hearing (Code Civ. Proc. § 437c(a)(2))

Mail adds 5 days within California, 10 outside California but within the United States and 20 outside the United States; fax, express mail or overnight delivery adds two court days.

Have the motion heard no later than 30 days before trial (Code Civ. Proc. § 437c(a)(3))

Unless the court for good cause orders otherwise.

File proof of service of the moving papers no later than 5 court days before the hearing (Cal. Rules of Court, rule 3.1300(c))

Calendar the opposition: served and filed not less than 20 days before the hearing (Code Civ. Proc. § 437c(b)(2))

Unless the court for good cause orders otherwise.

Calendar the reply: served and filed not less than 11 days before the hearing (Code Civ. Proc. § 437c(b)(4))

Unless the court for good cause orders otherwise; the reply may not include new evidentiary matter, additional material facts, or a separate statement not presented in the moving or opposing papers.