10 Motion Filing Time Savers

Your motion or response has to be filed within two hours. You and your attorney are scrambling to get it finished. It’s a race against the clock and you didn’t eat lunch and you’re slightly panicked you’ll miss your deadline.

Sound familiar? Believe me, I’ve been there many times. It often feels as if everything conspires to prevent us from meeting these important motion deadlines. The copier breaks. An important document has been misplaced. The brief is behind schedule. The obstacles can seem endless.

Many times, the delays are outside of our control. That’s why I like to have checklists in place, and I like to have routine tasks done well ahead of time. I want to be as prepared as I can be, and I want the roadblocks standing between me and my deadline to be as few as possible.

Here are some tips to streamline that motion preparation!

10 Motion Filing Time Savers

  1. Know your local court rules. Make sure you know your filing deadline, and the procedural and formatting rules ahead of time so you’re not looking them up at the last minute.
  2. Have captions for each case stored on the system. Re-typing a caption every time you need to draft a document wastes time you could be spending on something else.
  3. Have proofs of service for each case stored on the system, and keep them updated with correct attorney and party names. For each filing, all you need to do is replace the date, the titles of the documents being served, and confirm the service method.
  4. Have templates ready for common supporting documents, such as notices of motion, declarations, or proposed orders. Don’t draft these from scratch for each filing.
  5. Make a checklist of tasks for your filing. Include everything you and your team will be responsible for. No task is too small to go on the list! Include documents to draft, cite check, or proof read. List logistical steps for filing and service. This helps you keep track of what remains to be done.
  6. Prepare your proof of service as soon as you know what’s being filed – don’t wait until the last moment. See #10 for a key reason why.
  7. Start gathering exhibits for the filing as soon as you learn of them. Even for paper filings, I like to store electronic versions of exhibits in system folders, so I can just print them. This saves the time of searching the server or racing around to physical files and photocopying exhibits on filing day.
  8. For paper filings, keep a supply of exhibit tabs handy at your desk for fast last minute declaration assembly.
  9. Do you have a lull where you’re waiting on a document? Use the time! Go through your checklist. Proofread a document one more time. QC electronic or paper exhibits. Double check messenger arrangements or mailing labels or e-filing readiness.
  10. Use a copy of your proof of service as a final checklist! As each document is finalized and signed, prepare it for filing and service by converting it to PDF (e-filing), or getting it copied and assembled. As they’re completed, store documents in organized electronic file folders (e-filing), or place copies in court and service stacks. Just before the filing is uploaded or sent out for filing and service, double check the documents against the proof of service. Make sure each document being filed and served is listed on the proof, and each document listed on the proof is present in each folder or stack.

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