Anyone ever miss a deadline of propounding discovery pursuant to a case management order? Is there anyway to fix this?

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File them ASAP then…

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OC is really who you have to worry about as far as seeking contempt…in our jurisdiction, OC is required to contact you in good faith requesting the discovery/asking for update/follow up prior to filing mot for contempt.

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Ask for an extension…

Even if the deadline was the 10th and it's 4 days later? My assistant didn't calendar the order so it wasn't on my radar

File response instead of extension. If you don’t have the documents yet, say that. Object for things you don’t know for now, and add section of “will continue to supplement.” Can’t provide something you don’t have; buys you time for OC to dispute the objections…

OP said “propounding discovery,” not serving responses to discovery.

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This is just a deadline to propound discovery requests, not responses

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