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If you’re talking about a motion AND a memo/brief in support, anything less than 10-12 and you’re going to lose. More realistically it’s in the 3 full day range, ideally spread out over a week, unless it’s a single issue.
Write it all out, put it down, come back a day or two later, and you’ll probably delete at least half of what you wrote. Wash, rinse, repeat until it’s shaped and polished down to the absolute bare essentials.
The more time you spend on a brief, the shorter it’ll be. Shorter = less likely there’s a fact issue (in genuine dispute) = you win.
The clown who says “3-6” has never won.
Honestly, thinking that not filing an MSJ in nearly every case is ‘borderline malpractice’ is pretty excessive in and of itself. Not to mention the ethics rules and various other provisions that require you to have a good-faith basis for each and every motion you file. Filing an MSJ for the sake of filing an MSJ is borderline unethical. But what do I know 🤷🏻♂️
Whatever amount you bill, do it in as many specific segments as possible. You may find yourself 10 hours deep into research (if there’s several/complicated issues). If that is the case, have entries of 1.0-1.5 or so specifying “research re premises liability duty- rowland policy factors”. Same with drafting. “0.7- first draft of introduction and statement of facts” and specify things like “first draft” because you may spend another 0.5 later on for “revise and supplement” of the same sections. ~*~Tell the story~*~ of your work and progress with your billing. Good luck.
Thank you! I will absolutely break down my entries like this.
There is no way an msj can be written in 3 hours (in my experience). I don’t think I have ever spent less than 10/15 hours on one.
Also just as a general note, most partners will tell you to bill all of your time fully and accurately. They know that the first few times you do something it’s going to take longer. If they feel like it’s too much time they will cut it down when they are preparing the pre-bills for the client.
Thank you, I’ve heard this from many and am accurately recording time. Especially given how slow it is with my office WFH, I need these hours lol. I was just curious how much time other associates generally bill to see if I’m in that ballpark.
It reallllly depends on the case and the issues. It’s taken me anywhere from 5 to 30+.
Between 10-15 typically, depending on how many issues/arguments you have
Hard to say! Depends on the number of issues, number of parties, complexity, etc. I’d say with research, drafting, and revising probably close to 8? But maybe more if it’s super complex.
Thanks!
Employment discrim defense = 40.
I am in fed court. Thanks for the advice!
F
It takes however long it takes you, ya know. Let someone else tell you you’ve taken too much time to draft it. You’d be doing your client a disservice if you’re more worried about billing time than quality and substance of work. Just my opinion 🤷🏻♂️
When it is a simple premises liability issue, I’ll probably get all docs done in 15-20 hrs. If it is a complicated use of force case with multiple expert reports to incorporate, it could be as high as 70 hrs. Just depends.
That’s a lot of time for a standard premises sjm.