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Anonymous User
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Additional Posts in Small Law / Solos
Any contract family law attorneys in Kentucky?
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I’ve been there. For almost every major motion or opposition I’ve ever had to file, I’ve thought at some point “I will never be able to do this.” 1) if you are at the point where even productive work between now and then won’t be enough time, can you ask OC for extension? 2) what works for me sometimes is just doing all the easy stuff first, can you format the page, add caption and signature block, copy and paste law sections from old oppositions, then do the fact section or whatever section is easiest? I find seeing a doc with the pages and some text and headings helps me realize it’s already underway. 3) how likely is it their motion gets granted? If not likely, just get the relevant arguments and facts on the page for the record. Dont worry about making it masterful. Just get it on the page. Easier said than done.
Usually, for me, writers block is a fear of getting it done. Advice above is good (working on formatting and other easy tasks first), but what also helps is just getting everything on the page. It is easier to make a good work product when you word vomit on the page and then cut / edit / format than it is to write 20 pages the night before because the pressure has forced you to get it done.
Word vomiting is so helpful to build some momentum. Every difficult thing I’ve had to write I just title “draft 2,748” or some other ridiculous version number and then let myself write absolute crap work with notes to self, sidebars, bad prose, repeated points, bullet points, whatever I need to try to get the important bits on the page. Revisions are so much easier when you have something to clean up.
You’ve already won half the war by completing an outline. Now, built it out section by section…small battles.
Ignore the introduction for now. Depending on the motion, I usually start with the statement of facts/procedural history. If a dispositive motion, or something like it, the statement of facts are the facts that tell the story of why the case exists in the first place. If a motion to compel discovery, I usually go with a more broad background of the case and then focus on the facts discussing why the motion is necessary. Then, take a break.
Then tackle your legal analysis section. Take a break between each of these subsections too!
At some point, your legal analysis will be built out. Take another break! At this point, you’ll have your facts/procedural history and legal analysis. Try to tackle the introduction sooner than later after this as you’ll be able to better summarize what this motion is having the meat of the motion fresh in your memory. Take another break!
Then, refine refine refine.
How’d you make out, OP?