EH, the MSJ Goddess
Posted on October 5th, 2010
I am the Queen of Material Issues of Fact, Duchess of Expert Affidavits, and Countess of the Objectively Reasonable Jurors. I am the MSJ Goddess. [Just in case there's some other definition out there, I mean Motion for Summary Judgment. (What? I thought Mothers In the Legal Field would be a great name for a group.)]
In any case, I’m not bad at defending against Motions for Summary Judgment. True: I haven’t lost one yet. (Knocking on wood! Knocking on wood!) No, I take that back. I did lose one, but it was partial and the case settled anyway for six figures.
At 8 this morning, my cell phone starts blaring “16 Tons,” which means one thing: the ex-boss is calling. Probably about a MSJ, the only part of litigation he ever really worries about/is willing to spend money on.
It turns out he’s written a response on his own, which frightens me (honest to god, he’s cited CLEs in responses when left to his own devices), and wants me to edit and Shepardize it. OK. My contract rates are not cheap, and I need money, so I’ll be going down to the office, P in tow, in a little while to chat about it. I am scared. It is sometimes more work to edit his work than to start from scratch and rewrite his work (something that made me beat my head against my desk on more than one occasion).
This happens, of course, on the day when I had a great idea for a short story, I’m raring to finish up my novel draft, but…well. I need money. That’s why I kept my copies of the West rules of court and my many binders filled with SJ case law. And I kind of want to dip my foot back into the pool, because after a day like yesterday, I am missing my pretty shoes.