Today’s Practice Tips

1. Argue the facts when they help you, argue the law when it helps you and if you have neither, ask the court for more time.

2. You need to have a good poker face when the client tells you that under no circumstances will he have the money to pay the $50,000 judgment until 2014. You must maintain this poker face at all times despite the client currently owing your firm in excess of $100,000 in attorney’s fees.

3. Nothing good can occur when opposing counsel says: “There’s something you should know about your client…”

4. “Objection, shut the f*ck up” is an appropriate phrase for the mental dialogue you are having while working. It is not something to leave in discovery responses that you’ve just handed to the client to review for her signature.

5. Nine times out of ten you can tell if your opposing counsel is an asshole from his voicemail message.