Suggestions for Motion Practice

  1. Before drafting a Motion, call the other party to see if you can work the matter out.
  2. If you must proceed with the Motion, please check my availability using the web page. The days I will be gone are listed.
  3. You can also see the calendar for the whole day. You may want to avoid a day that looks unusually crowded. If nothing is scheduled on the day you are looking at, it is probably a day I will not be present.
  4. When sending or delivering a Motion, please send the Judge's copy separately to my office.
  5. If possible, prepare a proposed Order and attach it to the Motion, or bring it to the hearing.
  6. If the case involves a lengthy caption or many attorneys, please make sure that the first page of the document includes the name of the Motion and the original hearing date.


Suggestions for Responding & Answering Motions


  1. Send a Judge's copy directly to the Judge's office.
  2. If you do not believe your Answer will get to the Judge until just before the Motion, consider emailing a Judge's copy to Patti's email for Civil Matters, or email Kelley for Domestic Motions.
  3. List on the front page of the Answer and Brief the date the Motion is currently scheduled for hearing.
  4. If you expect to win, bring a proposed Order to the hearing.
  5. You may confirm that the Motion has been placed on my docket by checking the Court Calendar, which is updated twice daily.  You may also see what else is on the docket for that day.