And once again, I am up late dealing with a meritless motion from the other side. Unfortunately, given the draw of a particular judicial officer, it seems a distinct possibility that the opposing counsel's motion will be granted.
It boggles the mind. It is clear from opposing counsel's brief that they have done nothing beyond look up the appropriate code section for the motion. Had they taken the next step, and looked in the annotated code, then this person would have realized that they did not have the good cause required for the motion.
What I want to do is start off the brief with "Everything opposing counsel said in their motion is bullpuckey" or words to that effect. Unfortunately, I doubt that that will assist in my client cause.
Though, if the judicial officer rules against my client in this matter, it looks like I'll be seeking a writ.
To date in this case, I have filled a 2 inch thick file with pleadings. Most of them dealing with every wild hair thats gone up opposing counsel's arse (such as "Oh, my client can respond to discovery whenever we damn well please" or "Your client has no rights" or "Your client is a liar and therefore has the burden of proof which we, as the plaintiffs, do not bear in the slightest")(Note, these are the translations of the opposing counsel's actual words)
And all of this over a very small, very well trained dog.
I'm thinking that to date, this considering how much paper is flying back and forth between us, adding in appearances and experts hired by the other side, as well as sanctions awarded to my client, they are probably nearing $5000 or $6000. I push this further, drag it trial, and the opposition will have lost any profit that they would hope to achieve by this suit.
Of course, since this is a pro bono case, I shall be receiving.... well... nothing. Unless you count good karma.