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By: Daphne Drescher, CP

Reprinted with permission from Proparalegal: www.proparalegal.com.

I felt inclined to add a bit to the title of today’s post because it truly is “ridiculously helpful.” If the first paragraph doesn’t paint you right into a typical day in the life of a brilliant paralegal/legal secretary/law clerk/some other form of a legal miracle worker, I don’t know what will! But enough about paralegal biographies served up desk-side. Keep reading!

Your motion or response has to be file stamped within two hours. You and your attorney are scrambling to get it finished. It’s a race against the clock and you didn’t eat lunch and you’re slightly panicked you’ll miss your deadline.

Sound familiar? Believe me; I’ve been there many times! It often seems that everything conspires to prevent us from meeting these important motion deadlines. The copier breaks. An important document has been misplaced. The brief is behind schedule. The obstacles can seem endless.

Many times, the delays are outside of our control. That’s why I like to have checklists in place, and I like to have routine tasks done well ahead of time. I want to be as prepared as I can be, and I want the roadblocks standing between me and my deadline to be as few as possible.

Here are some tips to streamline that motion preparation!


1.  Know your local court rules. Make sure you know your filing deadline and the procedural and formatting rules ahead of time so you’re not looking them up at the last minute.

2.  Have captions for each case stored on the system. Re-typing a caption every time you need to draft a document wastes time you could be spending on something else.

3.  Have proofs of service for each case stored on the system, and updated with correct attorney and party names. For each filing, all you need to do is replace the date, the titles of the documents being served, and confirm the service method.

4.  Have exemplars ready of common supporting documents, so they don’t have to be drafted each time from scratch. For example, having templates with common language used in Notices of Motion, Declarations, or Proposed Orders can be a huge time saver.

5.  Make a checklist of tasks for your filing. List all the tasks you and your team will be responsible for. No task is too small to go on the list! List documents to draft, cite check or proof read. List logistical steps for filing and service. This helps you keep track of what remains to be done.

6.  Prepare your proof of service as soon as you know what’s being filed – don’t wait until the last moment. See #10 for a key reason why.

7.  Start gathering exhibits for the filing as soon as you learn of them. Even for paper filings, I like to store electronic versions of exhibits in system folders, so I can just print them. This saves the time of racing around to physical files and photocopying exhibits on filing day.

8.  For paper filings, keep a supply of exhibit tabs handy at your desk, for fast last minute declaration assembly.

9.  Do you have a lull where you’re waiting on a document? Use the time! Go through your checklist. Proofread a document one more time. QC the exhibits. Double check messenger arrangements or mailing labels.

10.  Use a copy of your proof of service as a final checklist! As each document is finalized and signed, get it copied and ready for filing and service. Place copies in court and service stacks as they’re completed, and check them off. Just before the filing goes out the door, double check the stacks of documents against the proof of service. Make sure each document being filed and served is listed on the proof, and each document listed on the proof is present in each stack.

Got any time saver tips of your own, TPS readers? Share them via a comment.

Daphne is a virtual litigation paralegal and owner of California-based Drescher ProParalegal. She is also an instructor in the Paralegal Degree Program at Empire College. For more information, visit Daphne’s website http://proparalegal.com where you can subscribe to the free Drescher ProParalegal Newsletter full of litigation practice tips and resources for legal support staff.

©2011 Drescher ProParalegal. All rights reserved.


Let me set the scene – you’re a race horse and the door to your loading gate is flying open, so you can begin to make your surging charge around the legal track! (It does kind of feel exactly like that most days – doesn’t it? Keep drinking the caffeinated beverage of happiness – and don’t answer that.)

Now get out there and charge into your incredibly productive work week, paralegals! We’ll get that crown of roses ready…

See you Friday!