Exactly one week before trial...uh oh


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.

John: Today.

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.

Start drafting.

Cell 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 you say it, you'll know that you'll be heard now.