letters for divorce lawyers

Sometimes imagination is better than reality. Oftentimes, come to think of it.

Thus, as I was killing time while doing TimeMatters database maintenance this afternoon, my eye was caught this afternoon by a "Just Published" notice of a volume entitled Letters for Divorce Lawyers (and yes, I am aware of the tired old joke that those two letters should be "F" and "U").

Now, what kind of letters would such a volume have to have in order to be useful to me?


Dear Counsel:

This letter confirms our conversation of this afternoon, in which I reminded you that your client, Snidely Whiplash, has, despite his stated support of the sale of the former marital residence posthaste, failed to sign the listing agreement with the agent he selected, failed to call the painters as agreed, and failed to remove assorted personal effects in order that the staging of the property can be completed. It is my understanding that my client, Pauline Perilous, cut and groomed the entire half-acre lawn with a push mower over the course of this past weekend in order to make the property ready for sale. As a consequence of her labors in the heat of the day, her promising career as a hand model for Dove soap has now been placed in jeopardy by the blisters that she developed. We shall be forced to seek temporary maintenance in the amount of $10,000 monthly if this continues, as we estimate that Ms. Perilous's career was on the verge of taking off prior to the blistering of her hands.

Please discuss this with your client. Prompt sale of the house will be to the parties' mutual benefit.

Best regards,

the dark goddess of replevin


Dear Counsel,

This letter is a followup to my letter of yesterday, the day before yesterday, the day before that, and last Friday, confirming that my client Mr. Wonderful is ready, willing, and able to spend time with his daughter while your client Little-Miss-Can't-Be-Wrong searches for employment. I am in receipt of your facsimile of this morning requesting a $2,400 monthly payment to LMCBW for daycare expenses while she searches for work. In light of the fact that the parties' daughter is thirteen years old the daycare estimate seems a little high to me. I hasten to add that Mr. Wonderful wishes to support your client fully in her efforts toward financial self-sufficiency. Would you please call me to discuss this at your earliest convenience?

Best regards,

the dark goddess of replevin


Dear Counsel:

Enclosed please find my proposed edits on the Seventh Amended Separation Contract between the parties. I note with some dismay that this litigation has now been pending for longer than the entire active length of the parties' marriage, which was three months.

I am hoping that this time you will accept my representation that "i" is before "e" except after "c," or when sounded like "a," as in "neighbor" or "weigh," and incorporate our proposed changes, which are purely nonsubstantive (as were my last three rounds of changes). Although some may regard this as an eccentricity, I believe that we as lawyers are judged by the documents we generate which survive on file at the courthouse, and my very strong preference is to have the parties sign a document that at least has proper grammar and spelling. I certainly agree that proofreading is a time-consuming enterprise, but I for one do not believe that we can eliminate proofreading entirely.

May I remind you that your initial draft by pure inadvertence had provided for an award of property to my client of eight dollars when in fact the correct number was eight million dollars. Naturally we both want to avoid having any further such errors creep in in subsequent rounds of drafting.

Warmest personal regards,

the dark goddess of replevin


better than a fist fight

Okay, I am looking for confirmation now that the following pleading is real:


AVISTA MANAGEMENT, INC., d/b/a Avista Plex, Inc.,







This matter comes before the Court on Plaintiff's Motion to designate location of a Rule 30(b)(6) deposition (Doc. 105). Upon consideration of the Motion – the latest in a series of Gordian knots that the parties have been unable to untangle without enlisting the assistance of the federal courts – it is

ORDERED that said Motion is DENIED. Instead, the Court will fashion a new form of alternative dispute resolution, to wit: at 4:00 P.M. on Friday, June 30, 2006, counsel shall convene at a neutral site agreeable to both parties. If counsel cannot agree on a neutral site, they shall meet on the front steps of the Sam M. Gibbons U.S. Courthouse, 801 North Florida Ave., Tampa, Florida 33602. Each lawyer shall be entitled to be accompanied by one paralegal who shall act as an attendant and witness. At that time and location, counsel shall engage in one (1) game of "rock, paper, scissors." The winner of this engagement shall be entitled to select the location for the 30(b)(6) deposition to be held somewhere in Hillsborough County during the period July 11-12, 2006. If either party disputes the outcome of this engagement, an appeal may be filed and a hearing will be held at 8:30 A.M. on Friday, July 7, 2006 before the undersigned in Courtroom 3, George C. Young United States Courthouse and Federal Building, 80 North Hughey Avenue, Orlando, Florida 32801.

DONE and ORDERED in Chambers, Orlando, Florida on June 6, 2006.

Copies furnished to: Counsel of Record

Unrepresented Party

Please, God, let this be real.

First update: it seems to be.


dances with fans

Having learned to dance (so far) with castanets, manton, and small rocks (clapped together for percussion in lieu of castanets--dramatic and earthy but hurts like hell when a finger gets in the way), I took a new step on Saturday.

We started dancing alegrias with fans.


All I'm going to say is that it's a lot harder than it looks. Since I'm left-handed, having to manipulate the fan with my off hand makes it all the worse. I already know I will throw myself into mastery of the fan, at which point I will possess yet another highly-developed skill that is of no general application to my life (like my ability to discuss opera and ballet in fluent Russian).

Update 6-14-2006

For the record the score is now Goddess 1, Fans 0, since I managed to break the handle on my first fan by snapping it open just a touch too briskly last Saturday. I need me a supply of cheap fans. Ah, the complex life of a twenty-first century goddess.


mercy, mercy me

I really had no idea when I created a blog persona how much fun I would have with it. Her. Whatever.

The dark goddess's credit card has become a piece of performance art: I received a cheery notice in the mail yesterday that the credit limit of my corporation sole now stands at $12,500.00.

Now, it's true that it's not at the world's best interest rate, but the fictitious can't afford to be choosy.

Lest anyone from First Equity be reading this blog, I hasten to note that the dark goddess's bill will always be paid. With real, not imaginary, money. As a general rule, however, corporations sole are chancy credit risks. Look at the Archdiocese of Spokane.