Tips for Successful Motion Practice

1. Any word that you put on the paper can find new life when the judge publishes a written opinion about how much you suck.

2. It is not professional to dance a jig when the judge issues his ruling and he plagiarizes your brief for his reasoning on every argument that was before the court.

3. Do not object when opposing counsel hands up a case that she did not cite in any of her briefs. When the judge stops the oral argument to read the case in open court, then tells the attorney that the case doesn't mean what she thinks it means, you are looking good

4. Do not lose your temper while in front of the judge. Do push the opposing counsel into losing his temper while in front of the judge.

5. When your client is being held hostage to a dumb lawyer make sure that you bring the client to any oral arguments. Nothing validates your billable hours like a judge bitch-slapping the opposing counsel for being a moron.

It was a not a good day to be my opposing counsel. Just sayin...