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July 20, 2017


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Jack Chin

Super-interesting post. But (as I am sure you well know) lawyers file motions for reasons in addition to the hope of winning the motion; to educate the court about the case, communicate with the other side, get the client ready to take the plea, etc. In the case of cert petitions, filing continues the AEDPA clock. I suspect that some of this (i.e., multiple goals or potential benefits) is also true in different ways with respect to medical interventions.

Matthew Reid Krell

NNT for summary judgment motions is one, because the purpose is not to resolve the case but to bill for preparing the motion for summary judgment.

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