In Erikson v. Weiner (1996) 48 Cal.App.4th 1663, the defendant, a medical doctor, moved for a new trial based in part on grounds of juror misconduct. (Erikson, supra, 48 Cal.App.4th at p. 1667.) The defendant thereafter obtained a 20-day extension of time in which to file his supporting affidavits. On the last day of the extension, he filed an affidavit of one juror, and 15 days later, he filed two additional affidavits, one from a juror named Gonzales, which the trial court ultimately accepted into evidence. (Id. at pp. 1667, 1669.) Nevertheless, the trial court denied the new trial motion. (Id. at p. 1669.) The Third District Court of Appeal affirmed the order, declining to consider the late-filed affidavits. (Erikson, supra, 48 Cal.App.4th at p. 1666.) On appeal, the plaintiff argued the time limits for filing affidavits was mandatory and that the Gonzales affidavit could not be considered. (Id. at p. 1670.) At the outset of its discussion of that issue, the Erikson court characterized the plaintiff's claim as arguing "the aggregate 30-day time period provided in section 659a for filing affidavits in support of a new trial motion is mandatory (also called jurisdictional)." (Id. at p. 1671.) Focusing on the statute's use of the word "shall," the court held the period was mandatory and jurisdictional, reasoning also that section 659a specified a "consequence" for exceeding the time limit, namely the ability to obtain an additional extension of time by the court. (48 Cal.App.4th at p. 1672.) It further reasoned that the time period was jurisdictional because any extension beyond the aggregate 30-day period of time would encroach upon the interests of the opposing party's allotted time to file counteraffidavits or the period for the court to deliberate on the motion. (Id. at pp. 1672-1673.) Erikson distinguished several cases stating that the time limits for filing affidavits are not jurisdictional. (Id. at p. 1673.)