- It is an unfortunate fact of life that you must practice law defensively in the current day.
- Judge Jones personally looks at all leave applications.
- Places them in piles--meritless and potentially meritorious.
- Disagrees with assertion that if application sits around with the court for too long, it's bad news. In his chambers-some meritorious cases actually take a while to process once flagged as possibly meritorious.
- Judge Jones likes to speak with attorneys on phone, so may want to suggest a phone conference in your letter accompanying the leave application.
- Most preservation issues are confronted and resolved in the Appellate Division, and if you lose on that basis at AD, it's an uphill battle. Make best, persuasive argument regarding preservation at intermediate appellate court.
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