Joe Klock Asks Magistrate Judge Brown for an "Extension of Mercy."

Kids, when you need to ask a judge for an enlargement of time, this is how you do it:
This request is not meant to delay any matters before this Court.  The Order was issued in the middle of the holiday season, and as Plaintiffs' counsel clearly was not working as hard as the Court, were not addressed until after New Year's.  Moreover, if the extension of mercy is not sufficient cause, then Plaintiffs would suggest that waiting until after the pretrial stipulation may narrow the issues that the parties intend to try and the evidence which they intend to offer.

Counsel for the Plaintiffs, JC Atorcha, emailed and called counsel Robert Browning, in a good faith attempt to confer as to whether or not INA would oppose such relief.  Undersigned counsel has not heard back from Mr. Browning, who may or may not still be celebrating the holidays.
Indeed, that may or may not be a photograph of Mr. Browning taken mid-revelry earlier this morning.

(I'm sure he'll get back to JC later on today.....)


  1. Took 15 days to bang that thing out? Also, see S.D. E-Filing Rule 3J as to what your signature block is supposed to look like.

  2. This is something you write but don't file.

  3. my first groan was at "troops". Surprisingly I was able to get by the font.

  4. Darn I missed that -- must have been my somnambulance.

  5. It may be hard to believe but 20 years ago, Joe Klock had THE best book of business in town. Who woulda thunk we now get to glimpse at the real little man behind the curtain. I'm wincing at Joe like he's an old movie actress on her 6th facelift

  6. Fitzgerald was wrong. Don't count Joe out just yet.

  7. It is very sad. Poor guy is just scraping by, selling pencils, and handling collection cases in Small Claims Court.

  8. ..."I'm wincing at Joe like he's an old movie actress on her 6th facelift."

    Ha! One does wonder, of course.

    Wow of course i've been wrong before but my instincts are saying a better analogy would be John Wayne in *True Grit*: notable paunch, not necessarily the box-office draw of his prime (hey, neither is Katherine Harris) and cocky, ambitious new characters running amok.

    All he's got is his own grit (and that of his paying clients), his wily (and more beautiful every year, of course) cracker steed ("damn, fishin' time & the kicker won't start...yank the cord again"), and notably that deadly rapid-fire, impossibly-accurate, single-handed rifle trigger-trick that saved his ass and those of many others during scores of wild & legendary South Florida showdowns. The very same trick that gave his long and hallowed career a start (or was it Sandy's punch - 'reckon only the Gods will ever know for sure).

    His finger could finally slip. But (if we're lucky, of course) ole Joe will likely outlive The Duke's shortened years by an Everglades mile, as it were. Or at least until Cuba is finally free and the imperial U.S. colony it should be.

    And goodness gracious this humble soul never hopes to find himself across from ole Joe in small claims modest(ly legal) gig would be up for sure.



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