I have a friend that recently complained about the other party wasting time by generating huge lists of things that need to be evaluated and refuted. Does this happen with opposing counsel from larger firms that deal with bigger cases where the lawyers generally communicate directly? Do you have any experience dealing with this in smaller cases?
But why give the opponent an opportunity to withdraw? I like spending the time to meticulously call out their BS and slop. Once the other side is shown to have filed slop once, its credibility is destroyed for the rest of the case. As a bonus, the court might issue, sua sponte, an order to show cause why sanctions ought not be imposed anyway.
But say the client is very cost-sensitive. There, one can still make a bullet-point list of all the cases cited, placing them under the heading "Cases that Do Not Exist" or similar.
The court should get the idea.
Obligatory disclaimer: this shouldn't be construed as legal advice; it's just part of my thought process regarding the OP's hypothetical.
ggm•1h ago