All prompts4Check what came back
Research
Work out how this judge decides this motion
Builds the research plan for the judge in front of you: standing orders first, then the written record, then the procedural habits that decide outcomes, with an explicit line between what is knowable and what is courthouse talk.
Your prompt
2
Pressure-test it
3
Go deeper
Before you run it
What to gather first
Watch for
What comes back
See an example of what you’ll get
*(After I answered: I am the moving party, I would rather have it decided quickly than perfectly, this is my first appearance before her, and it is a discovery motion so I want the cheap version.)*
1. Published and binding. Do this first: it is an hour and it decides the most.
| Look for | Where | How | Time |
|---|---|---|---|
| This judge's standing order for civil cases | The court's own website, judge's page, not a database | Read it end to end, twice for the discovery section | 20 min |
| Chambers rules or civil standing order on discovery disputes specifically | Same page; often a separate document from the general standing order | Note whether a joint letter, a pre-motion conference, or a certification comes before any motion, and the page limit for it | 15 min |
| Local rules of this court on discovery motions | Court website | Note the meet-and-confer certification requirement and its form | 10 min |
| The scheduling order in my own case | The docket | Confirm the discovery cutoff and whether motions must be heard rather than merely filed before it | 5 min |
You have already told me a joint letter is required before any discovery motion. If that is right, it changes the deliverable entirely: what you are writing is a letter section, not a motion, and everything below about brief length is moot until you confirm it. [UNVERIFIED - confirm the current standing order; it is the single highest-value item here and the one most often out of date in a colleague's memory.]
2. The written record. Two hours, and skip it if the joint-letter procedure holds.
Search categories rather than names. In your database, run a search restricted to this court and this judge for written discovery rulings, sorted newest first, and read the five most recent. Extract three things from each: the procedural route the dispute took to get to her, whether she resolved it on the papers, and the verb she uses in the disposition. On the docket side, discovery orders are frequently unpublished, so a database search alone will miss most of them; pull two or three docket sheets of closed cases before her and read the discovery entries directly. I cannot name a single one of these orders, and any citation you see me produce would be invented.
3. The procedural pattern. Observable from dockets, and more predictive than anything in block 2.
Whether a hearing is set at all on a discovery dispute; whether the entry says "submitted without argument"; the interval between filing and order; whether she orders the parties back to meet and confer instead of ruling. All four are visible from the docket text of three closed cases and cost about forty minutes. That interval number is the one that matters to you, because you said speed is what you want.
4. Reputational sources, labeled.
| Source | What it gives you | Label |
|---|---|---|
| The standing order | The procedure, bindingly | Record |
| Docket entries across three cases | The pattern of how disputes resolve | Inference from a pattern |
| The courtroom deputy, on scheduling and form only | When she hears discovery matters, what format she wants | Record, if you confine the call to logistics |
| Your partner's two appearances in 2024 | A recollection of one person about another | Hearsay about a person. Useful for orientation, and it does not go in an email to a client |
| A judicial analytics product, if you had one | Coded outcomes across all movants | Inference at best, and you told me you do not have one |
What this research cannot reach. It cannot tell you how this judge will view your specific dispute, what she thinks of proportionality arguments, or whether she is inclined toward or against your side. Nothing in a docket establishes that, and any source that claims to is selling a characterization of a person. Treat the procedural findings as reliable and the substantive ones as orientation.
The three decisions.
- Length. Governed entirely by the standing order, not by preference. If the joint-letter procedure holds, you have a hard page allocation and the decision is made for you.
- What the first paragraph does. If the docket pattern shows she orders parties back to meet and confer, the first paragraph is not about the documents. It is about what the two meet-and-confer rounds already produced and why a third would produce nothing.
- Whether to request argument. You want speed. If the pattern shows she resolves discovery disputes on the papers in under three weeks, requesting a hearing costs you time and buys nothing. If the pattern shows hearings, asking for one costs nothing and may shorten the interval.
What your answers changed. That you want this decided quickly rather than perfectly is why block 3 is where the real work is and block 2 is marked skippable. On a dispositive motion the order reverses: you read the written record for how she reasons and the docket pattern becomes background. That this is your first appearance is why the courtroom deputy is in the plan at all and why your partner's recollection is labeled the way it is; if you were a regular here, the deputy call is unnecessary and the recollection is worth more. Your answer that you are the moving party changed the argument-request analysis at the margin only, and I could have built the same plan without it.
Why this prompt is built the way it is
## Framework
1. **Published and binding first.** Standing orders, chambers rules, local rules, the scheduling order. These decide more motions than preferences do.
2. **Then the written record.** Opinions on this motion type, unpublished orders on the docket, the language used when granting versus denying.
3. **Then the procedural pattern,** which usually predicts better than the substantive one: hearings or papers, bench rulings or submission, referral to a magistrate, tolerance for length.
4. **Then the reputational sources, each labeled** as record, inference, or hearsay about a person.
5. **Draw the line out loud** between what is knowable and what is rumor. Never attribute a view to a named judge from memory.
6. **Convert findings into three filing decisions:** length, what to lead with, and whether to ask for argument.