A trial lawyer's life one week before trial
The ringing is obnoxious. Reach over and turn off the alarm. Sleep in for hours it seems until finally get up at…7:45! What time did I set it for good grief.
Do my thing and out the house to see if Nala will do her thing. As usual it will depend on what’s going on out there. Oh dear. Another dog is walking its woman. Nala stays at attention until they pass by. Lunges and begins to act all crazy but a stern talking to makes her (kind of) behave. A car whizzes by – freeze and point. A leaf blows in the wind – freeze and point. Throw in some squirrels and birds. The dog drives me bonkers. Time is of the essence here. Which she ultimately remembers and finally gets the job done.
At the office by 8:30. Grab tray of berries, rinse and take to desk. Turn on computers – laptop and two monitors. Wouldn’t mind a few more monitors. Have 20 foot ceiling. Plenty of room to stack them.
Email chase begins. Hundreds of them will click in and out during the day. All of our paperwork is due other than motions in limine which were turned in Friday. Trial brief, jury instructions, joint statement of evidence, proposed neutral statement, general voir dire and a witness estimation grid. Garth (partner) is doing most of the briefing and John (paralegal) is putting it all together. Do this – do that – add this – add that. What about this. Bang bang bang. Will we end up getting it all done and filed by 4:00.
The day isn’t limited to just getting miles of paperwork out. Oh no. Phone calls with co-counsel, work on exhibits, seek out second opinions on strategy. We are rocking and a rolling. But there’s much more to be done. And not just involving the case.
Life doesn’t stand still for trial preparation.
Phone rings. 8:50. Expert on another case has some questions. Am answering them when email pops up from Paul S (partner)– where are you. Am supposed to be on another conference call on another case that started at 9. It is 9:15. Get off and then get on the call. Get off at 9:45. Run downstairs with Nala to see Cristina (daughter) who is covering the front desk today. Give her kiss. Nala gets tickles. There’s a mediation going on down there. Tim a lawyer from tri-cities comes out to say hi. Chat. Run upstairs. Realize forgot to make oatmeal. Pull out stash of nuts and raisins in desk drawer.
More emails and drafts of briefs are flying around. Have about a dozen windows open on the three monitors. Musiq Soulchild playing off the laptop. Phone call from Jon the builder (am in midst of home remodel – currently slightly homeless but that’s another story). Need to meet him at house at 3. Nala wants some attention. Get her some water. See Paul W (partner). Wants to know status of getting out a big settlement package in a wrongful death case we’re both working on. Trying to get it out today or tomorrow morning. Our part is done but paralegals need to do all the attachments, hyperlinking and formatting.
Get email that friend is letting me stay at his Whistler condo in December. Let family members know to save the date. Realize it is the second week of a trial setting. Hope that doesn’t mess things up. Most recent draft of trial brief pops up on email. Send to Catherine (contract attorney) and ask her to take a fresh look for typos. She finds some.
It is noon and have to run to WSAJ gathering downtown. Consider skipping it as must get trial papers done. Decide to pop in to show support and leave. Get there and see familiar faces of the true few. Grab small salad and one slice of cold pizza. Listen to part of speech and ask a question. Write and give note to Pat (former partner) sorry can’t stay. Head back to office.
But first a little detour to Trader Joes. Fill bag with snacks for college care package for Noelle (daughter) so she knows we miss her. Get back to office 1:15. Give bag to Cristina and ask her to mail it. Run upstairs to put a card inside. Only have glittery snowman card in red envelope. That’ll do. Run downstairs. Take Nala out for more potty time. She knows not to mess around and gets right to it. Rush back inside.
A few more of the briefs are now done and approved. John buzzes. Another conference call. Andrea from seminarweb needs a “technical rehearsal” for seminar am giving tomorrow via gotomeeting. Goes quickly because have done this before. While on phone have been drafting proposed voir dire questions for the judge to ask. Want feedback over one of the questions. Walk into Brad (partner’s) office. Another lawyer friend is in there as well. Ask them for their thoughts. Confirm strategy. Go back to office hit send to John and another piece of paper is done. Email comes in from Alysha (daughter) who is in Thailand. Needs help finding a package and a few other things. Send back and forth half a dozen emails with her.
Phone rings. Need to call back. Finish another brief. Anne (paralegal) comes in. Needs feedback and help on various cases. Handle that. Run out the door at 3 to meet builder. Return call of co-counsel on way (bluetooth is actually not fuzzy today). Arrive at house. Jon is the coolest contractor. Talks faster than me but only finishes half his sentences. Not to worry. Our brains are in sync and know where he’s going so answer them without skipping a beat. He asks next half question I answer it and so on. Nala has to go again. She gets smarter as day goes along and realizes, she needs to move on it. Get back in car. Rush back to office now 4.
Thirty new emails. Click through them. The other side has filed a motion. It should have been filed on Friday. Send them an email to do it right. This bugs me. It cuts out a day that we need to respond. Skim their trial brief and other filings. Send them to Garth, John, co-counsel. Ask partners for input. Cristina comes in before she leaves. Lies on floor and lets Nala play-attack her. Gets up gives me a hug and leaves. Decide to look at calendar to see what need to do tomorrow. Oh great. Video conference perpetuation deposition of a doctor who is in another state, do the webinar, and a few other things.
Kevin, partner comes in – may argue some of the trial motions for us. Three messages are showing on phone. Haven’t gotten to them yet. More photos sent in by family member for wrongful death demand. Determine which to include. It will go out tomorrow. Look up diagrams of orbital rim for the case with the doctors deposition tomorrow.
Sun is making the room warm. 6:00. If don’t leave now, sun will be setting. Nala deserves to go for a run.