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Emergency Verified Motion To Have Judge Brown Speak With Judge Bailey!

Emergency Motion to Have Two Judges Speak to Each Other

Wouldn't you like to be a fly on the wall on that conversation?

BTW, there's some good stuff in the email discussion between the lawyers attached as Exhibit C (Judge Brown had earlier denied the motion for not having a certificate indicating that counsel conferred).


  1. I like your title for the motion better; was really hoping someone had filed that.
    When I was in law school (back in the day) I was taught that you should title pleadings based on what you want; especially if there didn't seem to be an 'established' motion for what you were asking.
    Only had the guts to do it a few times though, knowing which judges would be okay with it.

  2. I do like the idea of simply titling the motion what you want the court to do, although I've seen that concept taken too far, with over the top advocacy embedded in the title of the motion.

  3. What's wrong with "Motion to Compel Deposition of Plaintiff and Defense Counsel's Office Because Plaintiff's Counsel Has One of Those Conference Room Sharing Offices That Smells Like Stale Coffee and No Windows"

  4. It cannot have effect in reality, that is what I consider.


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