Yesterday, we brought you five ways to make the opposing attorney hate your guts. Whether you decide to use them for good (self-corrective measures) or for evil (returning the favor to the counsel from hell), today, we bring you five more.
1. Being a Technophobe
Yeah, old-timer. You're the one who doesn't use e-mail, doesn't send digital copies of court docs, and still uses a fax machine. When you realize that you are the only one with a fax machine, you insist on sending everything via snail mail.
2. Not Returning Calls
This goes without saying: pick up the dang phone and return a call. The hearing is in two days. There are trial dates and discovery issues to discuss. Don't ignore phone calls.
It doesn't take much effort to return a call. It takes even less effort to have a secretary, paralegal, or associate pick up the phone. Absolute non-responsiveness is inexcusable.
3. Abusive Discovery Dump
We asked for credit card statements. You sent statements, copies of statements, bills, copies of envelopes used to send statements, advertisements, credit card offers, and a photocopy of L. Ron Hubbard's first novel. Sure, there may be room for gamesmanship in discovery, but 10,000 pages of Hubbard is abusive.
Maybe someone wants a couple of extra weeks for discovery. Maybe there's a last-minute conflict with a hearing date. Don't be the guy who refuses to grant extensions, refuses to reschedule anything, and generally makes life hell. Guess what will happen when your child goes in for emergency surgery? The other guy will refuse your request to reschedule the trial. Full circle, good sir.
5. General Hard*** (Catch-All)
The guy who takes four days to do a one-day deposition. Who asks abusive, irrelevant, and intrusive questions. Who makes unwarranted threats of frivolous legal action to scare opposing parties. Who files motions for sanctions because someone gave him a funny look. Don't be that guy.
If you keep it up, word of your behavior will spread. No judge or attorney one will take you seriously. Your spouse, children, and family will hate you. You will die alone.
Of course, there are many ways to make opposing counsel's blood boil. Have one to share? Tell us on our Facebook page.