Chester New Matter 1st Quarter 2017 - 30
CCBA Feature
Continued from page 29
it without changes, signed on the final
page without acknowledging Gilbert's
input, and had the pleadings filed
electronically with the court. As if
acting on motor memory, buoyed by
past favorable outcomes, the ALPS/
Gilbert drafts were sent to court,
signed, but scarcely read, by the
responsible partner who was occupied
with other billable matters. ALPS kept
track of what was happening, storing
every voice command
and digital experience
in the recesses of his
expansive memory.
The day of reckoning
came when the firm's
calendar clerk advised
senior partner Albert
Littleton he only had
a two-day time limit
to file a case-altering
Motion for Summary
Judgment before
a scheduled trial.
Littleton had assured
his corporate client
that such a motion
had a strong chance
of prevailing, thereby
avoiding an expensive
and embarrassing sexual harassment
trial. But Littleton also scheduled a
Mardi Gras vacation in New Orleans
with his wife that he did not want
to cancel. Littleton was one of the
partners who depended on Gilbert for
his written work without giving him
due credit. So Gilbert canceled a night
at the symphony with his fiancée for an
unexpected, time driven, complicated
assignment. Littleton was at Cafe Du
Monde in the French Quarter while
Gilbert was in his office with his cafe
espresso.
30 | New Matter
A broken hinge point in Gilbert's
relationship with the firm had been
reached. A disillusioned Gilbert
turned on his computer and began to
reflect aloud about his professional life.
Why had he stayed? What personal
satisfaction was he deriving? Was
he wasting precious time? ALPS
interrupted, "Don't fret. Let's get going
on the project. What do you want me
to do?" Gilbert outlined the issues,
asked for a perfect Code of Civil
Procedure section 437c summary
judgment motion, and explained the
motion would be filed before Law
and Motion Judge Vincent Turner,
notorious for procrastinating, who
decided motions only after weeks
under submission. Because the matter
was time sensitive, a prompt ruling was
needed.
After thirteen non-stop hours of
ALPS and Gilbert frenetically working
together, the summary judgment
motion with its detailed undisputed
material facts covering six causes of
action was ready for filing. A separate,
duplicate original signature page was
sent electronically to Littleton in New
Orleans for his signature. Knowing
the quality of Gilbert's work, Littleton
did not bother to review the motion.
Gilbert asked Littleton's secretary to
run the motion through ALPS one last
time as a fail-safe check for errors, and
messenger the papers to Judge Turner's
department, the court clerk's office, and
opposing counsel before 4:00p.m. An
exhausted Gilbert left to catch up on
his sleep and decide whether he would
remain with the firm.
Littleton's secretary
did as directed, and
after ALPS scanned
the pages for errors,
recognized Littleton's
signature, and
added an insert, the
messenger sped off
to court.
The tentative ruling
favored Littleton's
client, but Judge
Turner ordered
counsel to appear for
argument and possible
sanctions. Littleton
did not understand
why "sanctions" would
be involved. Littleton
finally read the motion he signed, and
the very first footnote jumped out.
ALPS made one last revision which
no one saw before the messenger
filed the motion. At the end of the
notice of hearing, next to the date and
time, in the text, a number 1 footnote
appeared. Footnote 1 was then inserted
at the bottom: "Judge Turner, note:
because time is of the essence, we need
a decision ASAP. Your Department
is notorious for procrastination. You
are like the Chancery in Dickens'
Bleak House that 'so exhausts finances,
patience, courage, hope, so overthrows
Table of Contents for the Digital Edition of Chester New Matter 1st Quarter 2017
Chester New Matter 1st Quarter 2017 - 1
Chester New Matter 1st Quarter 2017 - 2
Chester New Matter 1st Quarter 2017 - 3
Chester New Matter 1st Quarter 2017 - 4
Chester New Matter 1st Quarter 2017 - 5
Chester New Matter 1st Quarter 2017 - 6
Chester New Matter 1st Quarter 2017 - 7
Chester New Matter 1st Quarter 2017 - 8
Chester New Matter 1st Quarter 2017 - 9
Chester New Matter 1st Quarter 2017 - 10
Chester New Matter 1st Quarter 2017 - 11
Chester New Matter 1st Quarter 2017 - 12
Chester New Matter 1st Quarter 2017 - 13
Chester New Matter 1st Quarter 2017 - 14
Chester New Matter 1st Quarter 2017 - 15
Chester New Matter 1st Quarter 2017 - 16
Chester New Matter 1st Quarter 2017 - 17
Chester New Matter 1st Quarter 2017 - 18
Chester New Matter 1st Quarter 2017 - 19
Chester New Matter 1st Quarter 2017 - 20
Chester New Matter 1st Quarter 2017 - 21
Chester New Matter 1st Quarter 2017 - 22
Chester New Matter 1st Quarter 2017 - 23
Chester New Matter 1st Quarter 2017 - 24
Chester New Matter 1st Quarter 2017 - 25
Chester New Matter 1st Quarter 2017 - 26
Chester New Matter 1st Quarter 2017 - 27
Chester New Matter 1st Quarter 2017 - 28
Chester New Matter 1st Quarter 2017 - 29
Chester New Matter 1st Quarter 2017 - 30
Chester New Matter 1st Quarter 2017 - 31
Chester New Matter 1st Quarter 2017 - 32
Chester New Matter 1st Quarter 2017 - 33
Chester New Matter 1st Quarter 2017 - 34
Chester New Matter 1st Quarter 2017 - 35
Chester New Matter 1st Quarter 2017 - 36
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