Foundation
My client will not answer the phone.
What is... try another form of communication.
The defendant or defendant's insurance carrier has not responded to me after many many attempts
What is..sue someone.
The other side is overdue on discovery
What is...file a motion
The other side is dragging their feet scheduling mediation
What is..File a motion.
I thought someone else was handling it.
What is.. confirm. Assumptions are for..
And then sue someone or file a motion.
The provider will not send their medical bills and records.
What is..Sue someone (and gain subpoena power).
I can't move forward putting a value on my case because the medical bills are not verified.
What is...assume they are due in full or verify them myself & sue someone if that does not work.
I've requested deposition dates multiple times but have not gotten a response
What is..Notice the deposition
My client is unavailable for mediation because they are in jail.
What is..Go get authority from the client in Jail.
It's pending.
What is..Move the case forward from pending to the next step in the process (prob. sue someone or file a motion)
Defense counsel and insurance companies asking for extensions
What is...say no (and then sue someone).
The Court will not schedule my hearing to approve the settlement
What is..try a different court.
The substantive responses from the otherside are littered with boilerplate objections
What is..send a rule 11 letter and file a motion.
The defense attorney wants to talk on the telephone about..everything.
What is..ignore that SOB.
What is..this is not a thing. Nowhere in the ethical rules is "flex was supposed to do it" cited.
My client is missing and i have followed the pre-investigator process and it's a really far drive for Alex.
What is..Raise at a meeting and hire a PI.
The core value that should guide what to do next if i hit a roadblock
What is..Be Formidable. Be Relentless
The defendant is evading service of process.
What is...File a motion.
We reached an impasse at mediation but my case is not yet on a trial roster.
What is..File a motion
My boss is my roadblock.
What is...Get it on a meeting to address with your boss. They will likely tell you to sue someone or file a motion.
My client has died and the proposed PR is not being cooperative.
What is..Find a new client.
I resolved a case and I am waiting on check..it has been weeks
Sue someone. Then file a motion.
I am insure of the SOL because of the discovery rule.
What is..Sue someone and do it asap so you do not get bit.
The other side disclosed experts and sent productions late to delay trial
What is..Be formidable and relentless and push towards trial
I already asked so and so.
What is..Get active. Ask again, and if you don't get the answer you like, sue someone or file a motion