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The email that set the tone landed at 4:52 on a Friday. A responding party had finally served, which meant a cross-motion I had been quietly hoping would slip a week was now firmly on for the following Thursday. That made five. Five motions, one me, five business days. I made a fresh coffee, sat down with a legal pad, and started drawing boxes.
Monday Morning, Five Files Deep
Here is what was actually on my desk when Monday opened. A summary judgment motion I was bringing, a motion to compel answers to undertakings, an urgent stay we were defending, a routine timetable motion, and the new cross-motion on a security for costs fight. Different judges, different courthouses, two of them by videoconference and three in person. One had a factum due Tuesday. Two needed motion records assembled and served with almost no runway.
The instinct in that moment is to grab the most pressing file and start drafting. That instinct is wrong, and it is the single most expensive mistake I see junior lawyers make in a heavy week. When everything feels urgent, drafting first means you spend your best hours on whatever happened to be on top, and you discover the real emergency on Wednesday night. So I did not open a single Word document on Monday morning. I opened my calendar and my task list instead.
Tip. On the worst weeks, your first hour should produce zero legal work product. Spend it mapping the terrain. You will earn that hour back three times over by Wednesday.
Triage Before You Touch a Single Draft
Triage is not glamorous, but it is the whole game. I laid all five motions on one page and scored each on two axes: how firm the deadline was, and how much of the work only I could do. A factum with a hard filing date and heavy legal analysis is high on both. A timetable motion where the other side and I already agree on ninety percent of the schedule is low on both, even if it is technically due sooner.
That gave me an order that had nothing to do with which email shouted loudest. The summary judgment factum went first because it was hardest and least delegable. The stay went second because it was genuinely urgent. The undertakings motion and the cross-motion could be built in parallel by our clerk and me trading drafts. The timetable motion, honestly, took twenty minutes once I stopped avoiding it.
The other half of triage is figuring out what is not yours to carry. Our clerk could assemble two of the motion records, tab the exhibits, and handle service and filing. A colleague owed me a favour and took a first pass at the undertakings chart. If you want a longer look at how to hand work off cleanly, we wrote a whole piece on delegation and who owns what, and it holds up under pressure precisely because it is written down before the pressure arrives.
The Running Checklist That Saved Us
By mid-morning Monday I had one document open that stayed open all week. Not a to-do list of vague intentions. A running checklist, one block per motion, with every discrete task, who owned it, and the real deadline for each step working backwards from the hearing.
Working backwards is the part people skip. A hearing on Thursday does not mean the record is due Thursday. It means the record is served and filed by a deadline earlier in the week, which means it is finalized the day before that, which means my draft affidavit needs to be signed two days before that. Once you write those intermediate dates down, a "Thursday" motion often reveals a Tuesday crisis hiding inside it.
| Motion | Hard deadline | Owner of next step |
|---|---|---|
| Summary judgment factum | Tuesday file | Me |
| Stay (defending) | Wednesday hearing | Me and clerk |
| Undertakings motion | Wednesday serve | Clerk, my review |
| Cross-motion (security) | Thursday hearing | Me |
| Timetable | Friday | Clerk |
We keep this kind of backward-planned view inside our matter tools in A1 CMS so the whole team sees the same deadlines, but I will be blunt: the discipline matters more than the software. A legal pad with honest dates beats a slick system nobody updates. The habit that actually prevents disaster is closer to the one we describe in docketing so you never miss a deadline: every date lives in one place, and one place only.
Note. Rebuild your checklist from the current state every morning, do not just cross things off yesterday's version. Two minutes of re-reading catches the task that quietly moved.
Where the Week Almost Went Sideways
Wednesday at 2 p.m. the wheels wobbled. The clerk pinged me: the stay motion record we were about to file was missing an exhibit that opposing counsel had served late, and the notary who was supposed to commission an affidavit had gone home sick. For about ninety seconds I felt the whole week tip.
What saved us was not heroics. It was that the checklist told me exactly what was and was not on fire. The stay was the only thing due before end of day. Everything else had slack. So I stopped work on the cross-motion without guilt, found another commissioner two floors down, and had the clerk re-serve the corrected record. We filed with forty minutes to spare. If I had been drafting the summary judgment factum by feel instead of following the map, I would have burned the afternoon on the wrong file and blown the stay.
A heavy week is won on Monday and lost on Wednesday, and the difference is almost always whether you know where every file actually stands at any given moment. My own notes, that Thursday night
The near miss also reminded me why duplicate data entry is so dangerous under load. When you are copying party names and dates by hand across five records at 1 a.m., you will eventually transpose something. Building your parties list once and reusing it, the way we describe in keeping a clean contacts and parties list, is not tidiness for its own sake. It is error prevention when your attention is at its thinnest.
What I Would Do the Same Next Time
The week ended better than it had any right to. All five motions went out on time. We won three, lost one on a point we expected to lose, and adjourned the timetable on consent. Nobody had to file anything embarrassing. Here is what I would repeat without changing a comma.
- Spend the first hour planning, not drafting. Every time I have skipped this to feel productive, I have paid for it later.
- Work every deadline backwards. The hearing date is the least useful date on the file. The dates behind it are the ones that hurt.
- Say the delegation out loud and in writing. "Can you handle this" is a wish. "You own the record for the undertakings motion, served by Wednesday noon" is a plan.
- Protect one honest source of truth. One checklist, updated daily, that everyone trusts.
None of this is a secret, and none of it requires you to be superhuman. A heavy motion week does not reward the lawyer who works the most frantic hours. It rewards the one who spends ten calm minutes each morning deciding what actually matters that day, then defends those decisions when Wednesday tries to take them away. If you want more of the same practical grain, the practice management writing is where we keep it, and you can find the rest of what I have written on my author page. The files will keep coming. The habits are what let you handle them without falling behind.
