Legal Question in Family Law in Maryland

Re: Discovery Complete and Pre-trail Statement

The "discovery completion" date is just what it says--by that date, you must have taken all deposition and served all written discovery. There should also have been an earlier date by which all written discovery had to be submitted, which date controls that requirement. Your scheduling order should also indicate whether and when the pre-trial conference will be held. If so, it should indicate whether you are required to file a joint or separate pre-trial statement and how long before the conference it's due.

Re: Discovery Complete and Pre-trail Statement

Your discovery request must be tendered by the date scheduled. Unless you can show that non-compliance with an otherwise lawful discovery request, the discovery complete date is set in stone. Whether a pre-trial statement is required is a matter that should have been addressed in the scheduling conference and, without extenuating circumstances, the date that it was due is the date due.

G. Joseph Holthaus

(410) 799-9002