A wise and winning argument in opposition to motion to extend discovery cut-off date. XL SERVICES helps you drill down to the facts and resolution without delay.
This poetic pleading was written in 1992 by Matt Steiner, Esq. (deceased), posthumous recipient of the LACBA’s 2014 Robert B. Flaig Award for Outstanding Professional Achievement in Construction Law and LACBA’s 2014 James Acret Award for Outstanding Achievement in Construction Law Legal Writing. A brief biography of the late Mr. Steiner follows as the poem.
Generations to come will hear lawyers tell
of the case of the Huntington Ritz-Carlton Hotel.
It is the stuff of construction law lore –
how law firms now numbering over two score
slugged it out for months, and then on into years,
while their fee bills confirmed all their clients’ worst fears.
It seemed for a time that total deforestation
Would come from the paper used in this litigation.
But one day a ray of hope appeared –
Lien claimants and counsel in one voice all cheered.
That was the day that Commissioner Levin
handed us one little piece of heaven
by stating ex cathedra, as we all remember
“This case will go to trial no later than December”
