Seven things to check before a motion leaves your hands

The motion that loses on form never gets a chance to lose on substance. These seven are the most common ways a pro se motion gets denied without the judge ever reaching the argument.

1. Local-rule page limits

Every district has them. Many judges set tighter ones in their standing order. A 27-page brief in a 25-page district isn't an argument — it's a rejection waiting to happen.

2. Certificate of service

If you serve by mail, you need a certificate stating who, what, and when. The form is one paragraph. Forget it and the motion isn't properly filed.

3. Meet and confer (where required)

Most discovery motions require a meet-and-confer first. So do many summary judgment motions in certain districts. The certificate of meet-and-confer is its own paragraph and the judge will read it before reading anything else.

4. Exhibits referenced but not attached

Cite Exhibit A → make sure Exhibit A is actually in the packet, with a cover sheet, and listed in the index. The exhibit-cover generator handles this; the exhibit-index generator handles the index.

5. Standing-order overrides

The judge's standing order may change page limits, hearing formats, or meet-and-confer requirements. Pull it before every filing.

6. Signature block + pro se status

Your signature block must include your address and a clear statement that you are appearing pro se. Some courts have a specific form.

7. Proof of compliance with the page-limit rule

Increasingly, judges require a separate certification that the brief is within the page limit. Read the standing order.

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