Capabilities / Routine motions
Routine motion practice
There are no small motions.
Most of a federal case is not the big motion. It is leave to amend, the stay fight, the objection to the magistrate judge, the sur-reply. Your swarm drafts each one against the rules of the court it is filed in.
What the firm hands over
- The case your firm is litigating.
- The motion the other side filed, or the one your firm needs to make.
What comes back
- A draft back within the hour.
- The court’s page limits, local rules and standing orders, read before the first word.
- A motion, opposition or reply your lawyers review, change and sign.
Volume is a cost strategy.
Leave to amend. A stay. An objection to the magistrate judge. A sur-reply. Each one is small. A docket full of them is not, because every motion spends days the firm does not bill, and the days come out of another case. Your swarm drafts each one. What a routine motion costs your firm is a review and a decision.
A motion struck for form costs days.
Every court has its own page limits, its own local rules, its own standing orders, and judges hold the firm to them. Your swarm reads the rules of the court before it writes the first word, so the draft that reaches your lawyers is already in the form that court expects.
The heaviest motion
Summary judgment used to take weeks. Now an opposition takes about a day.
It is the heaviest motion in a case: every deposition, every exhibit, every disputed fact. Your swarm works through the whole record. Your lawyers sharpen the opposition. They do not assemble it. Summary judgment is the one motion here that opens by invitation.
- Every sentence of the opposition traces back to the testimony or the exhibit behind it.
- The other side’s statement of facts answered point by point, with your own statement of the facts in dispute.
- What to press, what to concede and how the story is told stay with your lawyers.
Summary judgment, by invitation Discovery: where the record is made
Take the small motions off the calendar.
Your firm’s real work. Security verified first.