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Let's talk about our motion for continuance checklist, so this is your template and this is your master template which you can edit, or you can edit it once you've pulled it into a specific client so when you are considering a motion for continuance we have a reminder in here that you can assign to a paralegal or to yourself to call the court night coordinator and find out what dates are available now anytime you see this I in the blue circle that means there's additional information, and you can just cursor over it and see it, and sometimes you can't fit all the statement in the original box, so you have to move on to the rest of the sentence there so if you click on it this is what it looks like action title it's basically the initial and that can hold up in up to 255 characters or action plan where you have additional information, so you have a little hint with that blue eye that you have additional information then send a letter to posing counsel asking if they will agree to the continuance and offering specific dates that are available this is assuming you haven't already had that conversation then draft the motion for continuance include a request for attorneys fees if appropriate now it may not be appropriate why judges don't always even like to give it a continuance so if you just want one because you want one, and it's good for your case, but there's no good reason really one maybe you shouldn't be asking for one but if you still are maybe your client insists it may not be appropriate to ask for fees but let's say that there is a good reason let's say that there's a social studies psyche val being conducted, and it's not going to be done in time or somebody's going to have surgery your clients going to have surgery, and we all know they're going to be in hospital something like that then you'd want to consider asking for attorneys fees when you set the motion you definitely want to check in advance with opposing counsels schedule because you know you have an opposing counsel, and you need to check with their schedule and sometimes the clients don't like that because they think we're being too courteous, but we're really not being courteous we just need to accommodate a date where we can all be there and if you don't do that they're just going to complain and ask the judge to make you move it anyway because logistically they can't be there then set the motion with the court, and then you'll want to draft two orders it's the best practice to have an order with you a proposed order with you, and you'll want to have one that grants your motion and one that denies it they're very simple motions and the one that's granting your motion you'll want to include a place for the court to fill in the new date and time of the new hearing or trial and if you are trying to protect your record, and you may need to go in the future, and you don't know at that time right if you might need to appeal it's very important to have the denial in written form,...
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