The last few hours of my life have been a lot like that upcoming Tom Cruise-Jamie Foxx movie, except without all the violence and frosted hair. But I'm getting ahead of myself.
I got to work at 9:30 yesterday morning and took a half-hour break for lunch. Otherwise, I worked straight through to 12:30 a.m., drove home, set my alarm for 4 a.m., and was back at work at 5:20. Assembling a large pleading is a frighteningly complex, mindless job. Basically we had to put together 6 copies of the following: my declaration (3 pages) plus exhibits (approx. 1,000 pages), my boss's declaration (14 pages) plus exhibits (approx. 2200 pages, 1100 in one exhibit), five three-page declarations without exhibits, a proof of service (a two-page document saying we mailed a copy to the other side), the motion itself (57 pages) and a notice of motion (3 pages). We make a file copy, one for each of the 2 lawyers on the case, one for the US Attorney, 1 to file with the court, and 1 for the judge.
The first sacrifice we made was that we'll assemble our copies next week, leaving only the 3 that had to go out of the office. The copy for the government just needed to be mailed today. The copies to the court, however, needed to be filed today by 4 p.m. in San Francisco. This meant they had to be taken to FedEx by 7 p.m. last night, or else someone had to fly them up to the Bay Area today.
That is why I'm typing this from Matt Bruce's office in Emeryville, at the east end of the Bay Bridge.
We made not one, not two, not three, but four outgoing flight reservations from LAX--8:30, 11, 11:30, and 12:30. By the time my boss got done with the P's and A's (Points and Authorites, aka "the brief") at about 8:15 a.m., we assemble copies and tracked down original signature copies for the court's copy, and I went Al Haig on the assembly process for about the fifth time, it was almost 10:45 and I despaired of getting here at all. That doubled when I found out at curbside check-in that none of the four tickets had actually been paid for, but fortunately the reservations still existed (That bill will go on the pile of the enormous number of reimbursements I'll be putting in for next week.), so I got on the plane.
After landing, I got the three boxes worth of motion from baggage claim and headed out to the taxi stand, where I was picked up by Sunday who, as required by federal law, was an immigrant. Specifically, Sunday immigrated to the Bay Area 14 years ago from Nigeria. When I then asked him, "Yoruba or Ibo?" I got this look that suggested, "I've been telling people for a decade and a half that I moved here from Nigeria, and you're the first white boy to ask me that." (Yoruba, as it turns out.) Sunday took me to the courthouse, circled the courthouse, and then brought me here. I left my carry-on bag in his cab while I filed the motion; I was slightly nervous that he'd drive away with my bag still in tow, but not that nervous since I hadn't paid him the $55 fare yet. By the time we got here, the fare was $95, which is easily the largest taxi bill I've ever compiled.
So I'm here, on three-ish hours sleep, not too much the worse for wear. I'm apparently engaging in Basque-related activities tomorrow (or, rather, BASQuE-related), and then a Giants game. Other than that, I will do some sleeping, and maybe some sleeping.
You know, come to think of it, the motion is a Freedom of Information Act request on behalf of a convicted multi-murderer (though we're, of course, trying to do something about that), so maybe the only real difference is the hair...
Friday, July 09, 2004
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