Compel re: Tax Returns.”
The possible exception is if the motion has
an impossibly long title (presumably because
the author hasn’t read this column). Even then,
it’s helpful if your first line refers to the Motion
by its entire title.
Here’s an additional tip if you think things
might get confusing for court staff: Use your
first line to specify by file date the motion to
which your response or reply pertains. For
example: “Plaintiff XYZ Corporation submits
this Response to the Motion for Partial
Summary Judgment filed on 11/5/13 by
Defendants.” Because we have to look up things
chronologically, this helps us marry the
response and reply to the right motion.
Combine motions rarely. This is the hard one.
Sometimes tactical or practical considerations
warrant combining responses and motions. An
obvious example is a cross-motion for summary
judgment that addresses the same issue as a
But know that it comes at a cost. When we
get a brief titled “Response to Motion to Extend
Deadlines and Motion to Strike and Consolidated
Reply to Response to Motion to Compel,” it causes
confusion on our end. That’s because, after
this doozy of a multi-motion, various responses,
replies, objections and counter-motions will be
filed, sometimes at different times. Then my
staff and I have to figure out which brief match-es what. The unfortunate truth is that, the more
convoluted things are, the greater the chance
that my staff will misconstrue things, or that I’ll
misunderstand what you’re asking for.
With due respect to the time-worn strategy
of obfuscation, clarity should be your goal. As
with any advocacy, putting yourself in the shoes
of your target audience (i.e., the judge) will
help you understand what we need to rule in
your favor. Clear and succinct titles help the
court understand what you’re asking for—and
that is always good for the client.
CIVIL PRACTICE POINTERS —continued from p. 10
for the Greater Tucson Leadership’s Class
of 2015. Every year, the Greater Tucson
Leadership seeks candidates with demonstrated
leadership potential and unique perspectives,
and selects approximately 35 individuals to
participate in the program. To date, GTL has
graduated over 900 participants.
Fella is a member of the Commercial Bankruptcy, Restructuring, and Creditors’ Rights
This fall, Phoenix Mayor Greg Stanton joins
the faculty of Arizona Summit Law School as
an adjunct distinguished lecturer-in-residence.
With his experience as a practicing attorney
and public servant, he will teach Designing
Land-Use Policies, which covers the intense
legal and social conflicts associated with land
and its use.
models operational in other jurisdictions,
court rules, and procedures. It makes recommendations on court rules, discovery, alternative dispute re solution, judicial staffing and
Federhar focuses his practice in professional liability, procurement, health care, telecommunications, municipal law, appeals and complex commercial litigation. He earned his J.D.
and B.A. from the University of Arizona.
Todd Jarvis of Breen Olson & Trenton LLP
became a member of the Patent Bar. He has 10
years’ professional experience in the computer
and software industry, a B.S. in Bioinformatics
and a Master’s degree in genetics.
Elizabeth S. Fella, an associate in the Tucson
office of Quarles & Brady LLP, was selected
Brian L. Henry, Phoenix
Danny L. Klein, Scottsdale
David G. Licht, Beverly Hills, Calif.
Alfredo C. Marquez, Ramona, Calif.
Melvin J. Owens, Phoenix
James Meador Smith, Phoenix
coming up in
Real estate law
Civil Rights Act
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