The pleader should fashion all pleadings to maximize the admissions in order to help convince the court that the motion has merit.
The Plaintiff's goal is focus on the real issues and keep the case simple: the Defense goal is smoke and diversion, and to consume time and resources. You can sell the Plaintiff view by convincing the judge that focus equals efficiency, and to play the role of moving the case forward quickly. Moving the case forward quickly generally will more benefit the Plaintiff than the Defendant.
“To love at all is to be vulnerable. Love anything and your heart will be wrung and possibly broken. If you want to make sure of keeping it intact you must give it to no one, not even an animal. Wrap it carefully round with hobbies and little luxuries; avoid all entanglements. Lock it up safe in the casket or coffin of your selfishness. But in that casket, safe, dark, motionless, airless, it will change. It will not be broken; it will become unbreakable, impenetrable, irredeemable. To love is to be vulnerable.”
― The Four Loves
― The Four Loves
“Just get it down on paper, and then we’ll see what to do with it.”
―
―
“Love is the only way to grasp another human being in the innermost core of his personality. No one can become fully aware of the very essence of another human being unless he loves him. By his love he is enabled to see the essential traits and features in the beloved person; and even more, he sees that which is potential in him, which is not yet actualized but yet ought to be actualized. Furthermore, by his love, the loving person enables the beloved person to actualize these potentialities. By making him aware of what he can be and of what he should become, he makes these potentialities come true.”
― Man's Search for Meaning
― Man's Search for Meaning
“Nothing worth doing is completed in our lifetime; therefore we must be saved by hope. Nothing true or beautiful makes complete sense in any immediate context of history; therefore we must be saved by faith. Nothing we do, however virtuous, can be accomplished alone; therefore, we are saved by love.”
―
―
Frank’s 2025 Year in Books
Take a look at Frank’s Year in Books, including some fun facts about their reading.
More friends…
Favorite Genres
Biography, Book Club, Business, Classics, Ebooks, Fiction, History, Memoir, Non-fiction, Philosophy, Poetry, Politics, Psychology, Religion, Self help, Spirituality, and Sports
Polls voted on by Frank
Lists liked by Frank

































