So with East Bound and Down going on in my head, I am still up at just before 5 a.m. (or as some friends of mine would say "o'dark early").
And these are the thoughts I have...
1) I hate it when I do not have a complete file to work from. It would be nice to know what hell is going on in the case beyond the motion. (Note to people who may want contract work done, when the Angry Bell says send the file over, I do not mean a copy of the moving papers that are missing 1/6th of the pages and incomprehensible pro per brief that make sense only if you can read idiotese!)
2) I'm not my ex-boss from the days gone by. He could, and did on occasion, write his briefs blindly without evening bothering to wait for the other side serve him with their moving papers. I am a mere mortal who likes to know what the other player is throwing in the pot.
3) Writing a full blown opposition in less than a day is frakking nuts. Especially when its a motion I have never handled before. And I tell you that you I have never done this particular wrinkle of civil law.
4) I absolutely hate it when the person who contracts me the job says things like "it'll be easy" and "it's a slam dunk" or "all you have to do is....". If it was easy, why the frak did they not just bang it out on their weekend time instead of me doing it? If it was a slam dunk, then why are the casing running 3 to 1 against with the given fact pattern (that namely our client is in the wrong)? And if all I have to do is x, why is x the least important part of the entire frakking piece?
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