Legal Question in Real Estate Law in California

If a motion for judgment on the pleadings has been filed, presumably the defendant has already answered. You must file a motion to amend once an answer is on file. The time limit for filing an opposition is nine court days before the hearing and service must be by hand delivery, fax, or overnight delivery service (e.g. FedEx).

Amending a Complaint may be done (a) without "leave of court" at any time before an answer or other responsive pleading is filed, or (b) any time thereafter, with leave of court. Courts routinely grant leave to amend when the purpose is to identify a Doe defendant or add an erroneously omitted cause of action (CCP section 426.50) and where justice requires and the prejudice to the other parties is minimal.