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JoeRedskin · 07-03-2014, 01:14 PM

Please let it end ...

Case against very intelligent creepy stalker dude. Arguing he was sanctioned differently then others in similarly situated circumstances for illegal reasons, he asks for all relevant sanction letters to demonstrate this. We produce thousands of pages of documents including similar but different sanctions, client assures me all relevant documents. Plaintiff doesn't believe it and files a motion to compel and argues we are acting in bad faith.

Me to client: Okay, plaintiff has filed a motion to the court seeking to compel us to produce all the records. Have we produced all the records?

Client: Yes.

Me: You're sure. You have looked in all the nooks and crannies, boxes and e-files. I have everything that may even be possibly relevant.

Client: Absolutely. Checked and Double Checked.

Me: Okay. Please check ONE MORE TIME before I make any representations to the court.

Client: Okay. [24 hour pause] ... Yup, you have them all, every scrap in existence.

Me: Great, thanks.

Me to Court: We have given him everything relevant. Nothing has been withheld, we have carefully searched and all the documents he could possibly use to argue his point have been produced.

[24 hour pause] Court: In light of counsel's representations, no extension to Plaintiff. The order to compel is denied and no sanctions for bad faith levied.

THREE HOURS LATER ...

Client: Oh hey, we just found this sanction letter involving another individual who was both criminally charged and administratively charged ... just like the Plaintiff. For the same violations as the Plaintiff. With a different sanction than the Plaintiff. It was in the same box as the other letters. Sorry, WE JUST MISSED IT.

Me: <Head Explodes>

I cannot WAIT to tell the Judge "ooops!"

Hey client, way to snatch defeat from the jaws of victory and double your litigation expenses.

I need alcohol on an intravenous level.

07-03-2014, 01:14 PM	#10
JoeRedskin Contains football related knowledge Join Date: Mar 2004 Location: Second Star On The Right Age: 63 Posts: 10,401	Re: What REALLY grinds your gears? Please let it end ... Case against very intelligent creepy stalker dude. Arguing he was sanctioned differently then others in similarly situated circumstances for illegal reasons, he asks for all relevant sanction letters to demonstrate this. We produce thousands of pages of documents including similar but different sanctions, client assures me all relevant documents. Plaintiff doesn't believe it and files a motion to compel and argues we are acting in bad faith. Me to client: Okay, plaintiff has filed a motion to the court seeking to compel us to produce all the records. Have we produced all the records? Client: Yes. Me: You're sure. You have looked in all the nooks and crannies, boxes and e-files. I have everything that may even be possibly relevant. Client: Absolutely. Checked and Double Checked. Me: Okay. Please check ONE MORE TIME before I make any representations to the court. Client: Okay. [24 hour pause] ... Yup, you have them all, every scrap in existence. Me: Great, thanks. Me to Court: We have given him everything relevant. Nothing has been withheld, we have carefully searched and all the documents he could possibly use to argue his point have been produced. [24 hour pause] Court: In light of counsel's representations, no extension to Plaintiff. The order to compel is denied and no sanctions for bad faith levied. THREE HOURS LATER ... Client: Oh hey, we just found this sanction letter involving another individual who was both criminally charged and administratively charged ... just like the Plaintiff. For the same violations as the Plaintiff. With a different sanction than the Plaintiff. It was in the same box as the other letters. Sorry, WE JUST MISSED IT. Me: <Head Explodes> I cannot WAIT to tell the Judge "ooops!" Hey client, way to snatch defeat from the jaws of victory and double your litigation expenses. I need alcohol on an intravenous level. __________________ Strap it up, hold onto the ball, and let’s go.