NJSBA Family Law Section

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  • 1.  Good language or omit?

    Posted 01-29-2016 12:38 PM

    Reply certification in a fairly serious / dire / hard-fought enforcement motion. Adversary says several times "this is not an enforcement issue" when it plainly is.

    I'm thinking of saying at one part:

    12. Defendant's repetitive statements that "this is not an enforcement issue" is so baseless that it appears to be an attempt at a Jedi mind trick. Yes, "these are the droids the Empire is looking for" and yes, "this is an enforcement issue."


    Opinions: Does it detract or is it good?


    (PS Everyone going tomorrow to the Symposium? At least there doesn't look like there will be a weather issue like last year....)



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    David Perry Davis, Esq.
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  • 2.  RE: Good language or omit?

    Posted 01-29-2016 12:46 PM

    Nah. Put yiurself in the law clerk's or judge's place. Just plainly say what you need to say.

    Hanan


    hanan.gif

    Hanan M. Isaacs, Esq.

     

    t 609.683.7400   f 609.921.8982

    e [email protected]   w www.hananisaacs.com

    4499 Route 27, Kingston NJ






  • 3.  RE: Good language or omit?

    Posted 01-29-2016 12:52 PM

    I'm going to presume that your remark has something to do with the recent Star Wars movie.... but since i am not a "fan" of  Star Wars, the reference is lost on me  and potentially lost on the judge hearing your matter. 

    Its like suggesting that you find yourself  stuck between Scylla and Charybdis  and finding your audience not recognizing that you are simply suggesting that your are stuck between  "having to choose between two evils" or stuck   "between a rock and a hard place" with the sound of the sirens attempting to lure you down a dangerous path. 

    Other than Judge Jones ( whom I gather has given up on the idea of sleep), I think that most judges today are simply too busy with too much paperwork from too many applications and not really interested in our attempt at humor. 

    ------------------------------
    Richard Diamond
    Managing Partner
    Diamond & Diamond P.A.
    Millburn, New Jersey
    973-379-9292
    [email protected]



  • 4.  RE: Good language or omit?

    Posted 01-29-2016 12:58 PM

    agree, just say what you want to say, plain and simple.

     

    'This is clearly an enforcement issue, because [you fill in the blank here]'

     

     

     






  • 5.  RE: Good language or omit?

    Posted 01-29-2016 06:02 PM

    I think it's hysterical and brings a little levity into an otherwise serious matter.

    I'm at the symposium tonight and staying over.   Good turn out.