The most prestigious law school admissions discussion board in the world.
|
 |
 
|
Board lawyers: Does ZZZ's emergency mot to continue meet Judge Garcia's standard
Poast new message in this thread
Date: September 27th, 2022 4:26 PM Author: flirting candlestick maker Standing Order Sec. 5.h.
EMERGENCY MOTIONS: An emergency motion is based on an immediate threat to life, limb or property. The Court will set aside all other pending matters to address bona fide emergencies. Scheduling conflicts between counsel, last minute attempts to modify deadlines, and similar issues are not "emergencies" and may not be styled as such to obtain expedited relief from the Court. Counsel are directed to meet and confer regarding such issues and either submit a stipulation and agreed order, or to schedule such matters for hearing on the Court's regular motion calendar.
Just wondering whether a lawyer's belated effort to read the rules on propounding subpoenas and his intention to bring a motion to compel on some unspecified future date meets this standard. More specifically, is it frivolous / a waste of time for me to argue this in opposition? |
 |
Date: September 27th, 2022 5:32 PM Author: spruce laughsome rehab You should file your opposition after the hurricane has passed, indicating there is still significant time prior to the motion and that the basis used is invalid. (http://www.autoadmit.com/thread.php?thread_id=5200659&forum_id=2#45240326) |
|
Date: September 27th, 2022 5:34 PM Author: brass galvanic stage 190 (http://www.autoadmit.com/thread.php?thread_id=5200659&forum_id=2#45240337) |
|
Date: September 27th, 2022 5:39 PM Author: hyperventilating indecent library rigpig funny.. but dont (http://www.autoadmit.com/thread.php?thread_id=5200659&forum_id=2#45240363) |
|
Date: October 4th, 2022 11:13 AM Author: flirting candlestick maker This was good advice. Since the hurricane ended up washing ZZZ’s “law office” away, I look like a coastal elite asshole for saying hurricanes are NBD (http://www.autoadmit.com/thread.php?thread_id=5200659&forum_id=2#45277159) |
Date: September 27th, 2022 4:30 PM Author: olive curious prole an act of God popped up. (http://www.autoadmit.com/thread.php?thread_id=5200659&forum_id=2#45239928) |
|
Date: September 27th, 2022 5:20 PM Author: Cerise parlour twinkling uncleanness Exigent circumstances. Hurricane Ian will wash away all the evidence. *Acceleration* is necessary. (http://www.autoadmit.com/thread.php?thread_id=5200659&forum_id=2#45240229) |
|
Date: September 27th, 2022 4:32 PM Author: Histrionic jet-lagged whorehouse Was it really styled as an emergency motion? (http://www.autoadmit.com/thread.php?thread_id=5200659&forum_id=2#45239934) |
|
Date: September 27th, 2022 4:36 PM Author: flirting candlestick maker Yah (http://www.autoadmit.com/thread.php?thread_id=5200659&forum_id=2#45239951) |
|
Date: September 27th, 2022 4:44 PM Author: Histrionic jet-lagged whorehouse lol is that why the motion says "12. On September 23, 2022, Governor Ron DeSantis issued a state of emergency in Monroe County and Lee County, Florida,4 stemming from Tropical Depression Nine—which is now known as Hurricane Ian."
the governor said so!
|
|
Date: September 27th, 2022 6:47 PM Author: flirting candlestick maker It has recently come to our attention that four days ago an emergency was declared in this state. (http://www.autoadmit.com/thread.php?thread_id=5200659&forum_id=2#45240721) |
|
Date: September 27th, 2022 4:32 PM Author: Umber bearded market he might kill self if he has to present in front of 25 rick panamas so yes, it qualifies (http://www.autoadmit.com/thread.php?thread_id=5200659&forum_id=2#45239935) |
|
Date: September 27th, 2022 4:59 PM Author: Vivacious fat ankles gay wizard *ricks panama (http://www.autoadmit.com/thread.php?thread_id=5200659&forum_id=2#45240081) |
|
Date: September 27th, 2022 5:12 PM Author: Umber bearded market (http://www.autoadmit.com/thread.php?thread_id=5200659&forum_id=2#45240159) |
|
Date: September 27th, 2022 4:38 PM Author: Poppy irradiated ape sandwich Never lift the hammer when the judge may do it for you.
A simple, "I do not believe opposing counsel's request meets the Court's standards" should suffice.
If Garcia asks you to bring the hammer, then be ready to do so. But I suspect you can just sit back and watch |
|
Date: September 27th, 2022 5:22 PM Author: hyperventilating indecent library rigpig (http://www.autoadmit.com/thread.php?thread_id=5200659&forum_id=2#45240247) |
|
Date: September 27th, 2022 4:39 PM Author: insanely creepy peach address Worked for a partner who may have been too nice but he said to never bring attention to an "emergency" motion that wasn't really an emergency. If the judge gives a fuck about this-- and the language implies he does-- he'll do it himself and you just have to stand there like a statute while the other lawyer gets yelled at. If he doesn't then you won't talk him into a non-emergency emergency. (http://www.autoadmit.com/thread.php?thread_id=5200659&forum_id=2#45239965) |
|
Date: September 27th, 2022 4:42 PM Author: brass galvanic stage standing there like the Internal Revenue Code tp (http://www.autoadmit.com/thread.php?thread_id=5200659&forum_id=2#45239978) |
|
Date: September 27th, 2022 4:43 PM Author: Transparent multi-colored immigrant partner (http://www.autoadmit.com/thread.php?thread_id=5200659&forum_id=2#45239983) |
|
Date: September 27th, 2022 4:43 PM Author: insanely creepy peach address fma (http://www.autoadmit.com/thread.php?thread_id=5200659&forum_id=2#45239985) |
|
Date: September 27th, 2022 4:44 PM Author: brass galvanic stage happens to the best of us. ZZZ's shitwriting is rubbing off on the boart, i think. (http://www.autoadmit.com/thread.php?thread_id=5200659&forum_id=2#45239990) |
|
Date: September 27th, 2022 11:25 PM Author: Transparent multi-colored immigrant partner https://m.youtube.com/watch?v=iq8gfaFqFpI (http://www.autoadmit.com/thread.php?thread_id=5200659&forum_id=2#45242244) |
|
Date: September 27th, 2022 4:44 PM Author: Poppy irradiated ape sandwich btw its increasingly clear that the storm will not affect plantation key, which is like 2 hours from miami and as far east as you can be in the keys. maybe - maybe - key west gets clipped. But that is like saying "there's a storm in buffalo, lets cancel court in cleveland" (http://www.autoadmit.com/thread.php?thread_id=5200659&forum_id=2#45239996) |
|
Date: September 27th, 2022 4:47 PM Author: brass galvanic stage ZZZ done here (http://www.autoadmit.com/thread.php?thread_id=5200659&forum_id=2#45240005) |
|
Date: September 27th, 2022 5:01 PM Author: Vivacious fat ankles gay wizard There’s still the “storm” created by EPAH’s malevolently frivolous and felonious-proximate litigiousness in this matter to date (http://www.autoadmit.com/thread.php?thread_id=5200659&forum_id=2#45240089) |
|
Date: October 4th, 2022 11:48 AM Author: lemon hospital useless brakes (Rudolph) (http://www.autoadmit.com/thread.php?thread_id=5200659&forum_id=2#45277369) |
|
Date: September 27th, 2022 5:09 PM Author: Big Orchestra Pit Dude, how can the Judge NOT sanction him at this point? it's clear to pretty much any of us looking at this objectively that this is a harassment suit that wasn't thought through and he's doubling down with the harassment. If I were the Judge I'd give you every cent ur asking for EPAH. (http://www.autoadmit.com/thread.php?thread_id=5200659&forum_id=2#45240141) |
|
Date: September 27th, 2022 5:22 PM Author: Vivacious fat ankles gay wizard The judge probably won’t issue sanctions because EPAH comes across as a bit of a scum bag too, between the felon client, the snarky attitude, and seeking insane hourly fees. (http://www.autoadmit.com/thread.php?thread_id=5200659&forum_id=2#45240246) |
|
Date: September 27th, 2022 5:25 PM Author: Big Orchestra Pit lol at 1 and 3.
tons of lawyers have felon clients. what is your point? and wasn't it a pro bono case?
his hourly fees are reasonable and if anything the Judge would just downgrade to what he thought was reasonable.
the snarky attitude is where I agree with you. The Judge will give him some leeway because it's obvious this lawsuit is intended to harass, but he shouldn't be making condescending jokes in the pleadings if he wants fees. still don't think he's totally crossed the line enough to forego them... at this point. If I were the Judge I would still award. if he kept doing it I might not but would still dismiss. |
|
Date: September 27th, 2022 5:27 PM Author: Vivacious fat ankles gay wizard Generally I’d agree with you re 1, but this Judge is a hard ass cuban former prosecutor. Those guys can’t stand felons or the crooked lawyers who represent them. (http://www.autoadmit.com/thread.php?thread_id=5200659&forum_id=2#45240281) |
|
Date: September 27th, 2022 5:32 PM Author: brass galvanic stage do you think there's a chance that Judge Luis sentences EPAH to a jail term bc of his felonious association with a felon? (http://www.autoadmit.com/thread.php?thread_id=5200659&forum_id=2#45240319) |
|
Date: September 27th, 2022 5:38 PM Author: Vivacious fat ankles gay wizard LOCK HIM UP! (http://www.autoadmit.com/thread.php?thread_id=5200659&forum_id=2#45240360) |
|
Date: September 27th, 2022 5:34 PM Author: Histrionic jet-lagged whorehouse lol wtf. "I only represent innocent people" (http://www.autoadmit.com/thread.php?thread_id=5200659&forum_id=2#45240341) |
|
Date: September 27th, 2022 5:31 PM Author: brass galvanic stage i haven't found his snark to be over the top but do think he should tone it down. that email he wrote to the judge's clerk i thought was kind of inappropriate.
having said that, i dunno if he gives a shit about the sanctions and maybe he's just pissing around with these guys. |
|
Date: September 27th, 2022 6:39 PM Author: olive curious prole they will probably cut his hourly rate. state law judges hate biglaw-ish hourly rates for what they deem "simple" work and act like spending any more than a couple hours on a motion is "excessive." (http://www.autoadmit.com/thread.php?thread_id=5200659&forum_id=2#45240694) |
|
Date: September 27th, 2022 5:26 PM Author: Cerise parlour twinkling uncleanness What are reasonable fees down there?
Here in the Phoenix area, $300/hr passes without comment for every commercial shitlawyer in existence. $500 for a former biglolyer who is now partner in a firm regularly doing 7 and 8-figure cases would be scrutinized, but it definitely wouldn't be seen as insane. |
|
Date: September 27th, 2022 5:30 PM Author: Vivacious fat ankles gay wizard Rates in EJ’s jurisdiction in Florida are much, much lower. EPAH shouldn’t be able to tortuously interfere in Florida and then demand California rates for his time defending his spreading of scandalous lies. (http://www.autoadmit.com/thread.php?thread_id=5200659&forum_id=2#45240309) |
|
Date: September 27th, 2022 5:22 PM Author: Cerise parlour twinkling uncleanness "It is ORDERED that the motion is granted. Defendant shall submit any supplement to his request for fees by November 11, 2022." (http://www.autoadmit.com/thread.php?thread_id=5200659&forum_id=2#45240248) |
|
Date: September 27th, 2022 5:24 PM Author: talented skinny woman tattoo I thought that sanctions were not likely to be granted. At this point, if he continues to piss off the judge, you may very well win (not that you can ever collect).
Why does ZZZ have it out for you so much? This is insane that there's multiple lawyers looking this over and agreeing to continue pushing this case |
|
Date: September 27th, 2022 5:26 PM Author: Big Orchestra Pit it sounds like they're all of a similar shitlaw mindset, they should really have an outside observer friend from law school look over this shit as a sanity check. they'd immediately realize that they need to dismiss this. (http://www.autoadmit.com/thread.php?thread_id=5200659&forum_id=2#45240275) |
|
Date: September 27th, 2022 5:28 PM Author: Vivacious fat ankles gay wizard You’re forgetting this is state shit court. A decent shitlawyer can keep a frivolous case like this alive for years. (http://www.autoadmit.com/thread.php?thread_id=5200659&forum_id=2#45240285) |
|
Date: September 27th, 2022 5:31 PM Author: Big Orchestra Pit harder in this situation IMO because it's clear there are personal issues that spurned this case.
if it was a typical shitsuit about some contract or car injury but the facts were weak I could see that. but it's clear to anyone with a brain that this shitsuit was a harassment shitsuit from the beginning and basically playing games with the legal system as opposed to the run of the mill shitsuit which is just a frivolous suit seeking some nuisance or low dollar settlement to go away. |
|
Date: September 27th, 2022 5:32 PM Author: spruce laughsome rehab Here is what ZZZ doesn’t understand. RT does not give a fuck about ZZZ and there is probably no written agreement. The moment things go south, RT will disavow this lawsuit and even if he didn’t, he’s not licensed in Florida and this falls on ZZZ. All he did was find a lawyer desperate for work who would be his patsy for this lawsuit. The moment it ends up badly, ZZZ will be on his own.
This is all speculation on my part, but there is no way RT has any respect for ZZZ or think he’s a good lawyer. |
|
Date: September 27th, 2022 5:34 PM Author: brass galvanic stage i was with you until you said RT doesn't think ZZZ is a good lawyer. come on now. (http://www.autoadmit.com/thread.php?thread_id=5200659&forum_id=2#45240334) |
|
Date: September 27th, 2022 5:35 PM Author: spruce laughsome rehab There is no way RT would think this legal work is good or acceptable. (http://www.autoadmit.com/thread.php?thread_id=5200659&forum_id=2#45240347) |
|
Date: September 27th, 2022 6:42 PM Author: olive curious prole RT at least did biglaw for some period and managed to form his own firm with associates working for him, however disreputable its business model is. he is likely a much better lawyer than ZZZ. Can't believe he's signing off on these shitpapers. (http://www.autoadmit.com/thread.php?thread_id=5200659&forum_id=2#45240704) |
|
Date: September 27th, 2022 6:49 PM Author: flirting candlestick maker He's about equal to ZZZ. A little more histrionic. (http://www.autoadmit.com/thread.php?thread_id=5200659&forum_id=2#45240732) |
|
Date: September 27th, 2022 5:36 PM Author: Big Orchestra Pit what about the P? (http://www.autoadmit.com/thread.php?thread_id=5200659&forum_id=2#45240352) |
|
Date: September 27th, 2022 6:50 PM Author: flirting candlestick maker The P will very shortly be bankrupted by W.D. Tex. ruling, so it's not much concern to him if $20K gets tacked on to that. (http://www.autoadmit.com/thread.php?thread_id=5200659&forum_id=2#45240736) |
|
Date: September 27th, 2022 11:42 PM Author: Big Orchestra Pit So 180. LMAO so hard right now. (http://www.autoadmit.com/thread.php?thread_id=5200659&forum_id=2#45242368) |
|
Date: October 4th, 2022 11:09 AM Author: brass galvanic stage (http://www.autoadmit.com/thread.php?thread_id=5200659&forum_id=2#45277146) |
|
Date: October 4th, 2022 11:09 AM Author: Erotic Canary Mad-dog Skullcap Hall (http://www.autoadmit.com/thread.php?thread_id=5200659&forum_id=2#45277142) |