MOTION TO CHANGE THE LANGUAGE LAWYERS USE IN MOTIONS AND PLEADINGS: (Just to belabor the point some more) Comes Now, The Defendant, Geoffrey P. Golub, by and  through undersigned counsel, and hereby respectfully requests this Honorable Court grant this Motion to change the language used in motions, and as grounds therefore states as follows: (I would cross-out Honorable also, because it should be obvious, but why take a chance on upsetting some Judges, in fact I like to refer to a Judge as “The Honorable Judge…” because flattery is always a good idea. “Respectfully” may or may not fall under this category also, but it should be assumed. )

UNCLEAN HANDS: I had an compulsive-obsessive cleanliness client who got so upset at the accusation that she had unclean hands that she wanted to counter-sue for defamation of character. I’m thinking there should be a better way to say this.

COUNTER-PLAINTIFF/COUNTER-DEFENDANT: This just confuses me, can’t we just keep it Plaintiff and Defendant.  Most of the time that alone gives me problems, and I forget who I am representing.  But when you start adding Counter, forget it. Can you get a cross-counter-defendant? or a counter-counter-Plaintiff? Or a cross-dresser who counter-claims?

PLEASE ACT ACCORDINGLY: Which means, what? Is this really necessary to write? If it is left out can we act contemptible?

AS IF FULLY SET FORTH BELOW: Isn’t it obvious that’s the reason where re-alleging it in the first place.

SURI JURIS: Sounds like soup or something you eat at a sushi restaurant.

NOLLE PROSEQUI: Some lawyers and Judges love to say this word and add the “Qui” to it, and I admit it sounds nice. Personally, I just say “Nolle Prose.”  But the problem is except for my Latin-speaking clients, none of my other clients understand what either pronunciation means. So can’t we just say dismissed? And for my Latin-American clients I think we should say: de despida.

ANDERS BRIEF: I need to say one more thing about the Ander’s brief, because I love the concept of letting someone else do your work for you. An Anders brief is a brief filed pursuant to Anders v. California, in cases where counsel believes no nonfrivolous appellate issues exist. But I think if the Judges or rather their clerks, actually find something worth overturning on appeal, then the attorney who submitted the Ander’s brief should be billed by the Judges or their clerks for doing the attorney’s work.

NUNC PRO TUNC: This is the only Latin term I really like. Because it’s like giving a person a do over. Your allowed to go back in time and fix something that was wrong. A second bite at the apple so to speak. I love the way this sounds rolling off my tongue. I would like to be able to say this every time I am in court. “Could we just Nunc Pro Tunc that. Thanks.” DEPOSITIONS: Why is it that when you are scheduled to depose more than one person the only people who don’t show or cancel, are the people in-between the first and last deposition, so you have to sit around all-day.

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