I realize it is Christmas, and I do not say this lightly, but we have a client situation that simply cannot wait and I need you fully online and responsive until we get this across the finish line. Please acknowledge receipt of this email within 10 minutes and confirm you are at a computer with remote access and the ability to turn drafts quickly.

Here is what I need, in order, and I need all of it today:

Motion package refresh (filing tonight)

Update the notice of motion, memorandum, and proposed order to incorporate the new facts from the client call this morning.

Rework the introduction and the requested relief so it tracks the judge's most recent standing order. Do not assume our prior language is compliant.

Confirm every factual assertion has a citation to the record. If anything is not supported, flag it and propose a fix.

Build an updated exhibit list and make sure it matches the declarations. Page and paragraph pin cites must be correct.

Full cite check and authorities

Bluebook check the entire brief. Every single citation. Do not leave anything "close enough."

Pull the latest versions of the cases and make sure nothing has been abrogated or distinguished in a way that hurts us.

Add a short parenthetical for each case in the string cites so the logic reads cleanly.

Prepare a one page authorities chart with: case name, court, year, proposition, and where we cite it.

(http://www.autoadmit.com/thread.php?thread_id=5812525&forum_id=2,#49525654)

I'll turn this around by tonight or tomorrow morning at the latest.

(http://www.autoadmit.com/thread.php?thread_id=5812525&forum_id=2,#49525679)