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Wednesday, January 25, 2006

17 hours at work.

Mr. Clients R. Losers, I am going to give you insights into what is going to happen to you at our motion call on Thursday.

1)      I’ll set forth Local Rule 37.2

           Pursuant to Local Rule 37.2, if a party files a motion relating to the production of discovery the movant must supply a statement indicating that: 1) "after consultation in person or by telephone and good faith attempts to resolve differences [the parties] are unable to reach an accord," or 2) the movant's counsel unsuccessfully attempted to meet with, or contact by phone, counsel for the non-movant.

2)      I’ll bring up Snooker v. Hooker

     A case where our judge dismiss a motion for failing to comply with Local Rule 37.2

3)      I’ll turn to you and ask where your statement complying with 37.2 is.

4)      You’ll give me a blank stare back.

5)      The Judge will DENY your Motion, and HOPEFULLY he’ll enter mine.

Additional Insights

I was upset that the court waived the electronic filing requirement and allowed your motion to be filed.  I was agitated that the court did this at 5:00pm yesterday.  I was angered when they didn’t docket your entire motion because you never gave us pages 2 and 3. But, I became happy when I found Snooker v. Hooker.  (ALWAYS CHECK THE LOCAL RULES, and the JUDGES’ RULES, ALWAYS)

I’ve now spent 17 hours writing a reply to your Motion for a Protective Order. Its 16 pages double-spaced.  I found 16 pages of errors in your motion and protective order.  16 Pages! Your Protective Order and Motion were only 17 pages. That’s nearly a ratio of one-to-one. 

Nevertheless, you should pay me for every minute of it. why? Here are the elements

The final element is that it is necessary to demonstrate that the plaintiff suffered an injury as a proximate result of the lawyer's negligence. Thanks to my Reply, your motion probably would not have been entered. Thus, your negligence in filing would not have resulted in a different outcome for your clients. 

I am placing 10-1 odds (10 against – 1 in favor) that the only reason why the judge waived electronic filing is so he make an example out of your during his motion call.

And that, ladies and gentlemen, makes my job a little easier.

Oh, for those asking why I spent 17 hours writing a reply, when it was going to be dismissed anyways on a technicality: (1) You don’t always know that it will be dismissed on that technicality and (2) See last line of prior po$t 

BOO YA

*Prophet

Comments

Go take his candy, boy!!!

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