I leave Nala at home. Today is a half day mediation. At my office. We will be done by 1:00. I can then come home and let her out. She will be fine for four hours.
The mediation drags a bit. Colleen Barrett is the mediator. First time I’ve used her. She was a defense attorney. Had several cases against her. Always liked her.
Slow going. How will we be done by 1.
I have another meeting that starts at 1. What was I thinking. Push it forward to 1:30. This will give me time to run home and let Nala out.
12:15. We are still dragging along.
12:20. Email Anne. Can you let Nala out of the house. This mediation is going to go over and then I have another meeting and Nala needs to go. Give me 10 more minutes just in case we start moving faster.
12:25. We are still dragging.
12:30. Anne comes in. I give her my house key. Write the alarm code down on a piece of paper. One slight problem – I transpose the numbers.
12:45 Miraculously Colleen doesn’t just break the log jam. She pulls a super slick move and settles the case in one fell swoop. Boom just like that.
12:50 We do a few more things
12:55 Colleen has the CR 2A agreement prepared and we are all signing it.
12:56 The alarm company calls to say the alarm has been set off. I tell them no problem. Anne must have tripped it. Put it all out of my mind
12:57 I go to another conference room down the hall. Shake hands with Greg Wallace the defense lawyers. We are chatting.
12:58 Mike rushes into the room and says: Anne is on the phone and says it’s an emergency.
12:58.5 I run to my office, pick up the phone. All I hear is heavy breathing. huh huh huh huh. I call out her name. Can you hear me. Are you okay. huh huh huh huh. She is either having a medical emergency or she’s running.
12:59 Slam down the receiver grab purse, keys and run out the door.
1:03 Arrive at house. Yes that’s right. I live 2 miles away. Park and see Anne kneeling on the front step next to Nala. Nala is wet and covered in mud.
Anne: She’s okay. She came back.
She (Anne not Nala) is still panting. Nala is actually smiling
I come in. Close the gate. Hug Anne and tell her how sorry I am that I asked her to get Nala. The mediation was done on time after all. Anne is still shaking.
The alarm is going off. She shows me the code I gave her. It is of course the wrong code.
I punch the right numbers in. This stops the main alarm. But the alarms on the other two levels of the house are still going off.
I relieve Anne of Nala. Take her over to the side gated area. Enter. Pull out soap. Anne tells me what happened as I wash off the mud. Here’s her story:
Everything was going well until she punched in the (wrong) code. The alarm was going crazy. Nala looked like she was scared (guarantee you she wasn’t scared – you can let a firework off right next to her and she won’t blink if she’s focused on a bird). Anne kept punching in the (wrong) code and it wouldn’t stop. So she decided to put poor delicate Nala in her car away from the noise. She scooped her up in her arms and walked out the door. Made it past the gate. When suddenly Nala started flailing and wiggling until she basically lunged right out of Anne’s arms. The bad girl of course landed cat like on her feet and without so much as a bye see ya, took off like a rocket. Anne started to run after her. This was a useless exercise. Particularly since Anne was wearing slip on wedge sandals. Anne called her name. At least once Nala looked back at her and winked. Or at least that’s what it seemed like. Anne ran back to her car and had just fired it up when Nala came running back.
I finish hosing off Nala. Bring her back to the front. Dry her. Put on booties.
Apologize again to Anne. Try to comfort her. The alarm is still blaring. She shakily leaves for the office.
Call the alarm company which is easy because they just called me. So I hit the call back button. Tell them the alarm won’t go off. They can hear it. Sounds like a smoke detector when the battery needs to be replaced but ten times louder. Beep. Beep. Beep.
Explain what happened.
Alarm company tells me we will need to turn it off. Run downstairs. First need to unscrew the breaker. The breaker is in the ceiling. Get a step stool. Mount it with screwdriver in hand. Try to unscrew the screw. Strip the screw. Partly this is because of technique. And because I can’t see it. The aging process strikes again. Hold on I tell him. Descend ladder. Run up stairs. Find reading glasses. Run back downstairs. Back up on ladder. Yep. I stripped it. Back down ladder. Dig around in box. Find $9.99 black and decker electric screw driver. Battery is dead. Connect charger to outlet and look for corresponding hole on screw driver. Can’t find it. The guy thinks I’m an idiot. Finally find it. Wrong hole. Finally find it. Back up on ladder. The screw driver turns the wrong way. Figure out how to reverse. Jam into stripped screw. It comes out half way. Rip it out the rest of the way and unplug it. The beeps stop.
It is 1:35. Am late for the next meeting.
Where the heck have I been. Well, I started writing a book. I write it mainly when on airplanes. Decided I wouldn’t blog until the book was finished. But then changed my mind.
Since the last time I wrote here, we moved our office three miles down the street. We are in the top floor of a 1970s fishing company building that we bought and are in the process of refurbishing.
My partners were only too happy to let me take on the job of working with the designers/architects to fashion our new offices. Not only did I pick out everything from the kitchen sink to the paint colors and flooring. But since we have moved in I have micromanaged the décor to such a degree that I have literally hung every single painting. I have a level, hammer, and tape measurer in my closet. And haven’t created too many extra nail holes. None of my partners were clamoring to do this design work. But instead of feeling put upon or negative in any way, let me tell you – I am absolutely pleased as punch. I totally got my way.
My own office has been spruced up with a giant pop of color. Exhibit A is Nala who happened to get her hair done just before it was time to strike a pose. Hence the pink ribbons that match the pink carpet that match the even more pink chairs. You will gasp with delight when you see how cute this all turned out.
Whenever possible I like to visit with clients and lawyer friends in my office versus a conference room. Have never been a big fan of the “power desk” set up. Where the lawyer sits looking awesome and majestic on one side. The little people on the other. I sit on a ball. Plus there’s Nala. So I created a set up pretty much straight out of Mad Men. Now when we have meetings, we sit ensconced in velvet splendor around the coffee table. Under a black art deco chandelier.
We as lawyers spend so much time at work. There’s no reason we should not make it all as homey and comfortable as possible.
Photo: Nala catching some rare Seattle rays on the pink carpet.
Oh goodie. Oh goodie. Yay. Yippee.
We are up here at the cabin. Am looking out the window in the living room. Watching her carry the little blue kayak down the hill. She is trying to mimic Sol who balances the big kayaks on top of his head. Oops. There it goes over to the left. She hefts it up. Then it slops over again. She looks like a wobbly blue turtle as she makes her way down.
Lays the kayak on the ground. She’s looking at the river which is accessed by going over a steep embankment. Probably factoring me into the equation. Decides to lower the canoe to the river’s edge. Gives it a little push. It slips over the embankment into the river. I hear her shout. The kayak is travelling all by itself. She hops and slides down. Jumps into the river. Splashing. Not sure if she’s swimming or water-running. Grabs it. Makes her way back. Parks it where it should have stayed to begin with. She climbs back up to the cabin. Shorts leaving puddles as she rushes about.
Me, I’m being patient. Finally, she’s changed into a neon pink bikini. Waterproof wallet bag strapped around her waist along with a water bottle. The ice cubes clang each time she takes a step. Safari hat and sunglasses. A real fashion statement. I’m standing there. Thinking. Hurry up. Hurry up.
She straps on my life vest. Yah. I know. Sounds awful. I’m no baby. But actually, I feel quite snazzy in a nautical way. There’s a handle on the top of it so if I can’t figure out how to get back in she can grab and lift me to safety. It is bright orange and clashes hideously with her bathing suit.
We lock the door and head down the hill. I try to roll in something odorous and delicious but she tells me to stop. Reach the water’s edge. She puts the kayak in. Gets in. And so do I. This is the tricky part. It is small. My two front feet go on the prow. But the back feet just can’t get comfortable. So I put them on top of her thighs. Haven’t had a manicure lately but she doesn’t complain. Relieved we’re actually in. And off we go.
She’s decided to paddle up the river and then we will float back. This is so fun. I’m shaking with delight. There are gulls and little birds and baby fish in the water. I don’t know what to look at first.
I try to disregard but there it goes again.
She keeps hitting my behind with her paddle. Tries to push me forward. Tells me to put my feet on the floor instead of her. But I don’t want to. I lurch to the right. The kayak is tipping because I weigh 28 pounds dry. And I’m wet. So she better leave me alone. My hind feet make their way back onto her thighs. And I decide to tolerate the bumps.
A group of four people in different colored kayaks are coming by. They are smiling and pointing at me. They get closer and say they thought I was a little kid until they got closer. She makes pretty with them. I’m focused on a bird and ignore them.
Next up are a couple in two kayaks. The man has a benji dog on his prow who is not wearing a life vest. Which is lame. In my opinion. They wave. She makes pretty with them too. And I act supercilious.
She’s doing a pretty good job of paddling until we get stranded. The water is low from lack of snow melt this year. We are not moving. Stopped on pebbles. She stands up and gets out. I do too. The water feels good. It hits me just below the knees which is not very high. I prance around in it. She starts pulling the kayak. We have a good ways to go. The river has been slow up to this point. Now it’s moving at a good clip. She gets to a part where the water is about a foot deep and tells me to get back in. But I don’t want to.
There’s a bird who is catching baby fish. I am transfixed. Imagining how wonderful it would be if she would let go of the leash. I would then skim over the water to the bird. And then get it. I’m not sure what I would do if I did get it. Since I’ve never gotten one before. And I don’t think she’d be happy with me. But I don’t care. And then she is ruining my day dream. Tugging at me and saying: Nala get in.
By now I’m wrapped around and under the kayak. She has to untangle me. I jump in. But the bird takes off. So I jump out. The kayak goes backwards and gets stuck on the pebbles again.
She tries to push us forward with the paddle but we are too stuck. She tries to push with her arms but that’s a fail. She has to get out again and pull it along. Gets back to the spot she thinks will work. Gets in. I’m still watching the bird and pull her backwards. Predictably she falls out of the kayak into the water.
This whole getting unstuck business goes on for about ten minutes. This is a long time for a human when there are people who have set up camp along the shore on the other side and you are their entertainment. Me, I don’t care. A second bird has now joined the first.
Eventually she gets us out of there. I’m firmly planted on her thighs. We go for a bit longer until we get to another point where she’ll have to get out again to pull us. Instead she decides that’s enough. So we turn around and go back the easy way. Downstream. Back to the cabin.
I try not to chuckle as she drags the kayak back up the hill in that bikini. Run in a perfect loop around her legs. Watching as my leash gets tangled. And almost drops her to her knees.
Photo: Me on my kayak trip on the Wenatchee River.
The movie gift that just keeps giving – is the showdown between Tom Cruise and Jack Nicholson in A Few Good Men. That moment on the witness stand when Jack defiantly declares his magnificence. Gets up to leave. And Tom says – sit back down. And Jack has to. Because he’s in court.
Mr. T, as you may recall , gave a rather similar performance in deposition last month. And then some. Because no judge was present.
I returned to my office. Waited awhile for the transcript. And during one of my afternoon runs with Nala, came up with a plan.
Mr. T is from Oregon though licensed in Washington. I decide to bring a motion to compel that is not your typical motion. Many areas of the law are quite form based. Not so with tort law. Too many variables. It’s fun that we can be creative and not complete paperwork by rote.
The motion asks the Court to put the burden on the defendant insurance company to produce Mr. T for another deposition at their expense and to require the production of his time records and any other missing file records before the lawsuit was brought. This type of motion requires that I show Mr. T’s conduct to have been evasive in the deposition. Here are three short examples :
- Q Why haven’t you done anything to prepare for today?
- LEID: Object to the form. Go ahead.
- A Because I’m a fact witness, and I don’t prepare for depositions when I’m a fact witness. You haven’t asked me to prepare for anything, and I’m not under an obligation to prepare anything.
- Q Okay. So you are just going by your memory?
- A No.
- LEID: Object to the form. Go ahead.
- A So if you ask me a question, I’ll do my best to answer it, if I recall it. If you show me a document, I’ll answer to the best of my ability about what the document is and my involvement in it.
- Q Do you intentionally not prepare when you’re called as a fact witness?
- A I don’t understand your question. I don’t know what you mean by that.
- Q Is there any mention of Mr. V and November 29 in there?
- A Okay, I just read the paragraph. The document speaks for itself. This paragraph is about Mr. R’s effort to secure a recorded statement.
- Q Why didn’t you include Mr. V’s —
- A You’re asking me to remember — You’re asking me to speculate as to why that wasn’t put in there in August of 2011. Is that your question? I have no idea.
- Q All right. And then on December 5, you wrote that Mr. S — You can read it if you want. Why don’t you read it.
- A Here’s what I would generally say: This is an exhibit; it speaks for itself. I don’t have a recollection of this. I’ve never found it effective to ask someone to discuss a document that’s an exhibit, that they’ve said is an accurate exhibit. I think it’s an incredible waste of time. And I don’t really want to sit here for three hours and have you go over documents like this, because you’re wasting time. I’m not going to elaborate on this because I cannot elaborate on it. It was four years ago. The document was produced by my office, okay.
- Q What I find to be an incredible waste of time is for me to come down here and hear that you didn’t even look at your file to prepare for your deposition. And then when I show you a document, you don’t even answer the questions because you find that to be a waste of time. So I think we’re at an impasse as to who is wasting whose time.
- LEID: Objection. Is that a question, Counsel?
- (BY MS. KOEHLER:) Did you not get your own file documents from your own counsel?
- A Go ahead and ask your next question.
- Q Were you given your file documents before today?
- LEID: Object to the form.
- A Go ahead and ask another question.
- Q That is my question.
- A I’m not going to answer that question.
- Q On what basis?
- A I’m just not going to answer it. You’re welcome to call the judge and have her require me to answer it, if you’d like.
And so, that’s exactly what I did by motion. And what the Judge Ordered.
The motion is attached here.CompelTMtn
The order is attached here. CompelTOrdr
Photo: Nala and the reason running helps with thinking things through.
Anne has started off the new year with a Fitbit. Her goal – add steps to her sedentary work day. Tearing herself away from her desk has proven difficult. Anne always has more work than she can complete.
Enter Nala. She comes to work most days. There are many hours spent lying on the floor, chewing an old antler, digging the stuffing out of her bed, and otherwise being bored. She doesn’t complain though. Afterwards we typically go for a run.
About three weeks ago, Anne had an aha moment. She was watching Nala who as usual, was exercising bad manners and jumping on someone who had come into my office for a visit. Hmm, Anne thought. And just like peanut butter and jelly the two souls came together.
Nala now has a new walking pal. And Anne has found a fun way to add between 1000 and 2000 steps to her new contraption each day.
Photo: Sunny, 50 degrees, and 3:00 Monday afternoon.
Today Nala almost killed herself.
It is drizzling. We are running around the neighborhood. Both of us in our rain gear. Splish. Splash. It starts pouring. Get home. Wash off the dirt. Towel her. Repeat process with myself.
Need to file a brief this morning. A discovery teleconference is scheduled to start soon.
Grab large bunch of delicious red grapes. Rinse them. Wrap in dishtowel. Place in purse.
Run out the door to office. Arrive. Anne is waiting. Follows me into office.
Close door. Throw down purse. Go over final briefing touches.
Two minutes late for teleconference. Dial number. Rory and Jennifer are on the phone. We chit. We chat. Write confirming email.
Cristina brings in cupcakes from Morpheys. This is good because never got to eat breakfast. Also some samples of cake and frosting that we are to taste for her wedding purposes.
Go to grab grapes. Want to eat something healthy before sugar rush commences. Pull dishtowel out of purse. It is wet. But empty.
The other night saw the very depressing movie: Still Alice. Julianne Moore may win the Oscar. So went to see it. Look at towel and think. Pretty sure washed grapes and put them in towel in purse. Maybe didn’t. Maybe did. Hmmm. Look at Nala. She stares blithely past me. Bear down. Make eye contact with her. There’s no doubt.
Google: dogs and grapes. https://www.aspca.org/pet-care/virtual-pet-behaviorist/dog-behavior/foods-are-hazardous-dogs
Grapes are toxic for dogs and related to kidney failure.
Call Dr. Clare at Urban Vet.
Receptionist: How many did she eat. If just a couple she’s fine.
K3: I think she ate an entire two handed bunch of grapes.
Receptionist: Let me check with Dr. Clare….can you bring her in right away.
Pack her up. Tail wagging. Drive down the road. Get to Urban Vet. Dr. Clare comes out to get her. Tells me to go back to office. Will call when ready to be picked up. She needs to be given some medicine to make her throw up.
Drive back to office. Walk in door. Brief has been filed. Cristina returns. We eat cupcakes. Very tasty. Except the almond frosting is yucky.
Phone rings. They say it worked fast. She just vomited about 70 grapes. Three times the level at which they would be toxic.
Cristina drives with me to get her. Pay enough money to buy 25 entire grape vines fully loaded.
Thank Dr. Clare. She says if we hadn’t caught it so quickly it would have been a big problem. There would have been many more medical tests and procedures. To say the least. Thank her for being such a good and caring doctor
Return to office. Attend meeting of an accident reconstructionist with Brad.
While Nala cruises around. Happy as can be.
Photo: Dr. Clare of Urban Vet and Nala
Am wound up tight. Aggressive tendencies barely restrained. Okay, maybe not restrained at all. In full warrior mode.
The defense lawyers haven’t been too bad lately. Wish they were bad. Then could have an outlet for this simmering fury.
Sometimes there are organizational politics involved in being a trial lawyer. We need to band together to deal with the insurance industry and big corporations. Even when we are on the same side, people get their feelings hurt. Or want their way. Or are unhappy that you are going your way instead of theirs. Or want you to be quiet. Or want you to stop fighting for what you think is right – because others don’t agree. Or are scared that dissension will lead to collapse.
Today is a day filled with these politics. Would much rather be doing client work. Would much rather be doing just about anything else.
It is pouring outside. The wind is knocking all the giant maple leaves off their stems. Blowing them down the road. Until they give up – waterlogged. Unable to float anymore.
Go home. Put on gear. Rain coat over gear. Rain vest on Nala. Leash. And we are out the door.
The rain has lessened but is constant. Shoes squish. By the time we reach the top of the hill, rain coat is completely soaked. Am warm. Toss off hood. Roll up sleeves. Cold rain hits skin.
A squirrel runs across our path. Nala zooms after it. I am braced for impact. Saw the squirrel at the same time she did. Nala’s leash is tied around her torso. Attached at her chest. Not neck. So she bounces back to me. We keep going. She keeps looking. Anticipating the next squirrel sighting.
Up we run. Past Betty Bowen Park and Kerry Park. Wind through the residential roads. Two stooped Asian women are at their usual haunting place on the East side of the top of the hill. With bumpy bags and grabbers. Scouring the ground for fallen chestnuts.
Squish. Squish. Squish. Back we run through the parks. Down the hill. To home. Wash down Nala. Dry her off. And smile.
Photo: Nala still wet after her run.
J.R.: Hi Karen, I thought of you when reading the SuperLawyer Top 10. Are you the first woman to do this? CONGRATS!
Go to www.superlawyers.com top list for Washington. Interesting. Appear to be in the top 10. Walk down hall to Catherine’s room.
K: Someone said I made Top 10 superlawyers.
C: I told you that months ago, but you were typing and said – oh nice – and didn’t even pause.
Return to own office. Look up past 11 years of superlawyers’ existence. Two other females have made the top 10. Carolyn Cairnes, an employment lawyer in 20o4. Karen Jones, deputy general counsel for Microsoft, the last time in 2009.
Write back to J.R.:
K: Hi J.R. I didn’t even look at the list until I read your email. I wish more women were listed in the top 100/top 10. At least there’s 1 this year.
And wish it didn’t matter.
Photo: by Noelle Greig of me looking not particularly lawyer-like at Cheekwood Botanical Garden, Nashville TN
The Today show has its annual best of the best contest. The top three dogs are competing for the grand prize. Doggie #1 pushes a mini shopping cart. Doggie #2 gets a can of beer for his buddy. And Doggie #3 – well, you just have to see what he can do. Oh, and yes, he is a Brittany. Just like Nala.
Now, everyone in America at least, is probably rushing around trying to figure out where they can get such a wonderful dog. So pretty. And silky. And smart. And obedient.
This is similar to what happens when people visit Seattle in the summer. They realize it is the most beautiful place on earth. Move here. Then they experience October through April. And want to move back to wherever they came from.
So, now that we’ve seen the perfect Brittany, let’s see what a real one is like. Enter Nala Rose Koehler age 5. Nala for short. AKA Nalzoid. Zoid. Kah. And the Poopmeister.
- Very pretty and she knows it
- Silky hair – feels like a kitten
- Went to obedience school and was amazing for about a week – until the girls undid almost everything.
- Tell her to sit, she lies all the way down
- Her one claim to fame – if you tell her to stay, she won’t move until you say it’s okay.
- Manic beyond belief
- Hates being left alone anywhere
- Anytime anyone comes into the room, she jumps up on them to say hi
- Will eat just about anything that falls onto the floor
- This includes bad things.
- Like poo
- She has never in 5 years ever been the dog of the month at Downtown Dog Lounge. More than 60 opportunities and never once been chosen.
- This is probably because she eats poo
- To prevent this, at DDL she has to wear a muzzle. Which to me brings to mind Anthony Hopkins in Silence of the Lambs.
- DDL also makes her wear the brown tag of shame (affixed to her collar)
- Cannot take her to Marymoor dog park because all she will do is chase down the nasty stuff
- When running with me, she will cross directly in front to get at a squirrel or bird
- Have gone through half a dozen types of harnesses so that she won’t rub herself raw from pulling
- Can never leave her alone with leash as will chew it in half
- Pouts…for a nano second
- Can’t hold a grudge
- Always wants to be wherever you are
- Not allowed to get on furniture
- Always gets up on couch under the window when left alone
- Or on Alysha’s bed
- Drinks out of the toilet if you forget to close the lid
- Scarfs her bowl of food in under 30 seconds.
- To slow her down, spread food in trails around her mat
- Is so fixated on squirrels that she will stop in the middle of peeing if she sees one
- Forgets to do her business if she sees any type of movement – life a leaf blowing in the wind
- Never sits or lies down if you’re up and moving.
- A constant shadow.
- Always ready for action.
- Has to be bribed with treats when walking/running. If she sees another dog and doesn’t go after them like Kujo she gets a treat.
- She can’t help it if a dog looks at her the wrong way – she will sacrifice the treat
- Can’t figure out how to play catch
- Has favorite toys that she has kept in good condition for years. Her favorite is the red squeaky snake.
- She will squeak that snake until you can’t take it any more. You will go to take that snake away and end up having to chase her around the house
- If you let her cuddle with you on the couch, she is in heaven.
- Is good at playing hide and go seek
- Cannot figure out why Alysha gets so excited when she does down dog
- Extremely affectionate
- Likes Ludwig Von Beethoven and Gospel music
- Pretty bad swimmer. Looks like she’s trying to run on top of the water
- Will fetch, maybe, if she’s in the mood
- If you don’t set boundaries, she will smother you.
- When the girls are home and she is allowed to sleep with them, she will get up right under their necks
- Can catch bugs mid-air
- Barks hysterically everytime she things she hears the doorbell
- Rushes at anyone who enters the house
- Throws self against inside window-wall at the office when people walk by
- Throws herself especially hard against window at Ryan because she knows he is scared of dogs
- Will take off full speed in a heart beat if she gets off the leash
- Will always come back, but still scary
- Jumps out at cars
- Could care less about thunder, lightening or Fourth of July fireworks
- Cowers if you barely begin to knit your eyebrows to give her a scolding
- Closes the drawers with her nose if you leave them open
- Is mean to the timid new dog that moved in next door.
- Hates the terrier who lives on the other side
- Loved the big German Shepherd who lived across the street but mysteriously passed away
- Doesn’t like the girls talking to her on the phone
- Goes crazy whenever they are home
Yeah. Nala is not the best trained dog in the world. But we wouldn’t trade her for anything.
Photo: Nala at the office
Wake up at 6. Hear Alysha turn off the alarm and leave to teach her yoga class.
Lean down and grab ipad off floor. Check email. Check weather. Turn on Pandora Anthony Hamilton station. Lie there like a slug for another hour. Leisurely get up and out the door. Nala gets around to doing her business after first lunging for an imaginary squirrel.
Arrive at office. Make a bowl of oatmeal and rinse some blueberries. Eat. Check email. Look at calendar. Turn Pandora station to The Isley Brothers. It is 9:00.
Cut and paste a caption onto a document. Label it: “Trial Brief.” Start into the first paragraph. Divert attention to various other things. Ed comes in to play with Nala.
9:30 meeting with Kessler and Catherine. Finish up at 10:15. That was a long one.
Email comes in from John – is this document ready to go. It is a draft of the joint statement of evidence. Edit it. Then have uh oh moment. This is usually filed with the trial brief. Have sinking feeling. Send emails.
Me: When is the trial brief due.
Me: Oh holy cow.
John: Does that mean I should cancel my dentist appointment at 3.
Me: Cancel it.
Look at calendar. Oh. There it is. At the very top in fine print. It basically says: Everything is Due today!!!!
This is what has to be done. Trial brief, proposed neutral statement of the case, joint statement of evidence, general voir dire questions, jury instructions with citations of authority, proposed verdict form. If you are a lawyer you know what this involves and are thinking – oh holy cow.
Ask Mike in reception to please hold calls.
Give Nala a snack.
Cel rings. It’s Noelle. Payment deadline for the remainder of her study abroad tuition. Figure that all out and pay it on line.
Back to drafting.
John brings in mail. Allstate is objecting to a proposed judgment on our jury verdict from last month. Email co-counsel.
Back to drafting.
Send a thousand emails to John. What’s this. What’s that. How much is this. Whaaaaa.
Oatmeal wears off.
Give Nala more water. Head out to Whole Foods for delicious salad bar. But first, make detour. Her nails need to be filed down at Petco which is next door. Pick up salad and Nala. Rush back to office.
Eat while drafting.
Manage not to choke.
Note to self – vegan chocolate cookie is actually delicious. How did they do that.
Finish meal while typing.
Music is too sedate. Need more frenzy. Turn it to…Prince!
Send more emails. Ignore more phone calls. Sorry – I’ll get back to you tomorrow.
Finish one document after the other.
Email John: okay time to format.
John comes back in a flash. Wow he’s quick. A bit too quick. Razor eyes of his boss find bad things. He runs back upstairs to fix them. It is 3:02. If this had been a normal day, he would be just sitting down into his dentist’s chair. Instead, is being drilled by…me.
Whelan comes in for a quick chat. Pats Nala. Leaves.
Back to editing the trial brief.
Sheila E. thumps her drums and belts out: “She wants to lead the glamorous life.”
I bounce up and down on the ball. Nala raises her head to see what’s going on. Since food is not involved she loses interest.
John rushes back with the rest of the fixed documents.
Hand him back the piles. It is 3:27.
Am smug. We are finished and will be able to efile an entire hour before the clerk’s office closes for the day.
John says: it is going to be close, as he backs out the door.
Me: Isn’t it closed at 4:30.
John: Yes, but we have to get this to Snohomish County. [An hour away]
Me: Don’t they have efile.
John: No, the messenger will be here in five minutes. If I can get this copied and done in the next five minutes they can get down there.
He sprints away.
And so I write this blog. While Cameo chants:
Word up everybody say
When you hear the call, you’ve got to get it underway
Word up, it’s the code word
No matter where yo usay it, you’ll know that you’ll be heard now.
Photo: Nala getting her nails done.