To get good insightful answers, how the question is framed matters. I missed an opportunity on Thursday
A good read by Ian Hu on deadlines for plaintiff litigators:
f you discover or think of a deadline while you’re in a coffee shop, take out your phone and email instructions to your assistant to tickle it. If you’re in a discovery and find out about a deadline, email instructions to your assistant tickle it. And if you don’t have an assistant, then email yourself so you can tickle it when you get back into the office. Develop this simple habit – when you discover a deadline, tickle it – and take a big step to avoiding a big source of malpractice claims.