Month: March 2023

Mr. Hwang sent his email from Local Rule 5(H) to counsels today on March 3, 2023. He sent it to attorny Whittemore, attorney Scofield, other attorneys, and other related people.

This is the content of the email as belows.

[The Beginning of the Email]

To Counsel,

1. I am thinking of/am considering for filing and/or am going to file “Motion for Extension of Time to Retain Counsel”.

2. I would like to respectfully request the Honorable Court to extend the time allowed to retain an attorney for my case.

3. I would like to obtain and/or need to have an additional 45 days to find a lawyer to prosecute my case and/or participate in the hearing(s) or/and the pending hearing.

4. I would like to and/or am trying to comply with the Local Rules of this Honorable Court by sending/giving this email(correspondence) to the opposing counsel before I file the motion.

5. I would like to ask/request and/or am asking/requesting the opposing counsel his opinion, cooperation, and/or agreement about/with the motion.

6. If you agree to the motion, we can/may submit the agreed Joint Motion to the Honorable Court.

It can/may be Plaintiff’s and Defendant’s Joint Motion for Extension of Time to Retain Counsel.

7. I can/may draft and/or give you a proposed order for/about the motion if you agree.

8. I hope you agree. I sincerely request the opposing counsel to agree to the motion.

9. Before filing the motion, I am consulting and/or am expressing my effort to attempt to consult with the opposing counsel for the other party in this email.

10. I respect the MEMPHIS BAR ASSOCIATION GUIDELINES FOR PROFESSIONAL COURTESY AND CONDUCT.

I respect, especially and particularly, the GUIDELINES’ II. 14.

I sincerely request the opposing counsel to see and read the GUIDELINES’ II. 14.

II. PROFESSIONAL CONDUCT IN LITIGATION
14. A lawyer should grant reasonable extensions of time to opposing counsel where such extensions will not have a material adverse effect on the rights of the client.

11. I am not a licensed counsel/attorney/lawyer in the United States YET, but I respect the GUIDELINES’ I. 11., PREAMBLE, & II. 2, too.

[Legal Ground]

Local Rule 5(H).

RULE FIVE. NON-DISPOSITIVE MOTIONS
[H] On all motions, the movant must certify that all counsel have participated in a conference to attempt to resolve the matters at issue in the motion before filing the motion.

[Reference]

(A)

MEMPHIS BAR ASSOCIATION GUIDELINES FOR PROFESSIONAL COURTESY AND CONDUCT II. 14.

II. PROFESSIONAL CONDUCT IN LITIGATION
14. A lawyer should grant reasonable extensions of time to opposing counsel where such extensions will not have a material adverse effect on the rights of the client.

(B)

MEMPHIS BAR ASSOCIATION GUIDELINES FOR PROFESSIONAL COURTESY AND CONDUCT I. 11.

I. COURTESY, CIVILITY AND PROFESSIONALISM
11. A lawyer should make every reasonable effort to cooperate with opposing counsel.

(C)

MEMPHIS BAR ASSOCIATION GUIDELINES FOR PROFESSIONAL COURTESY AND CONDUCT. PREAMBLE.

PREAMBLE
A lawyer owes to opposing counsel a duty of courtesy, fairness and cooperation.

(D)

MEMPHIS BAR ASSOCIATION GUIDELINES FOR PROFESSIONAL COURTESY AND CONDUCT II. 2.

II. PROFESSIONAL CONDUCT IN LITIGATION
2. A lawyer should consult opposing counsel in an effort to resolve matters by agreement before filing motions or requesting hearings.

Sincerely,

Hwang

[The End of the Email]

Yeah, this was the email which Mr. Hwang wrote and sent today.

What do you think?

Written by Mr. Hwang

Published: March 3, 2023