The motion that shapes — or ends — the case.

Motions we routinely handle

Summary judgment & summary adjudication (CCP § 437c)

The single most consequential motion in California civil practice. MSJs require a separate statement that fact-by-fact establishes that no triable issue exists. The opposition lives or dies on the separate statement. We draft both — and the moving and opposing evidence — with the appeal in mind, because that's where the order usually ends up.

Demurrer & motion to strike (CCP § 430.10, § 435)

The first chance to narrow a case. A well-drafted demurrer doesn't argue facts — it tests whether, accepting the complaint's allegations as true, a cause of action exists. Sustained without leave to amend is the goal; with leave is often a strategic win anyway.

Anti-SLAPP (CCP § 425.16)

California's anti-SLAPP statute lets defendants attack lawsuits that target protected speech or petitioning activity. The motion is a two-step burden: defendant shows the claim arises from protected activity, then plaintiff must show minimal merit. Loser pays fees. Denials are immediately appealable.

Motions to compel & for protective orders

Discovery motions decide what evidence the jury ever sees. We handle the high-stakes versions: privilege fights, third-party subpoenas, deposition disputes, sanctions motions, and discovery referee proceedings. Every motion is drafted to build a record for sanctions or for the trial-court appeal.

Motions in limine

Drafted in the weeks before trial. The best in-limine motions are short, specific, and tied to a clear evidentiary rule — not omnibus motions to exclude "any reference to" some topic. We work with trial counsel to identify which in-limine fights actually matter.

Post-trial motions

Motions for new trial, JNOV, additur/remittitur, and motions to vacate. These are the bridge between trial loss and appeal. The standards are different from anything else in civil practice and the deadlines are short.

How a motion engagement usually works

Most clients come to us in one of three ways:

1. Brief-only. Trial counsel handles the case; we write the motion (or opposition) on a fixed or capped-fee basis. We can stay ghost-written or appear of counsel — your call.
2. Motion-and-argument. We draft, file, and argue. Useful when the motion is technically complex or the judge is one we've appeared before.
3. Discrete representation. You're self-represented or your firm doesn't handle this kind of motion. We come in for the motion only, with a clear scope letter.

What a good motion brief looks like

Two pages of judges' time, ten pages of attorney's reading. Most judges decide motions on Sunday night for Monday's calendar — sometimes earlier — and they're deciding eight to fifteen at a sitting. The brief that gets read carefully is the one that:

• Tells the judge what to do in the first sentence. "This motion should be granted because the complaint pleads no facts establishing a duty." That sentence answers the question the judge actually has.
• Has a Table of Contents that is the argument. The heading "Plaintiff cannot establish duty as a matter of law" already wins the case in the judge's mind.
• Front-loads the standard of review or burden. Tell the judge the test before you tell them why your side wins under it.
• Cuts string cites. One good California case beats four. Two if you need an out-of-state case for a federal issue.
• Treats the separate statement seriously. Especially in MSJs. The judge reads it line by line. So does the appellate court.