Does a party have to lodge a peremptory challenge to a judge assigned for all purposes in a direct calendar court?

"[S]ubdivision (2) of Code of Civil Procedure section 170.6 simply requires a party to exercise a peremptory challenge to a judge assigned for all purposes within 10 days of the assignment, unless that party has not yet appeared in the action. Under that circumstance the challenge must be lodged within 10 days after the party appears. In the typical case, therefore, parties lodge peremptory challenges before the assigned judge conducts any hearings or has had the opportunity to make any rulings." (Fight for the Rams v. Superior Court (1996) 41 Cal.App.4th 953, 957.)

Government Code section 68616, subdivision (i) unambiguously requires a party to exercise a peremptory challenge "within 15 days of the party's first appearance" in a direct calendar court. Clearly, when a direct calendar assignment is made more than 15 days after a complaint if filed, the 15-day time period begins when the party receives notice of the assignment of the new judge. (Fight for the Rams v. Superior Court, supra, 41 Cal.App.4th at pp. 957-958.)