What to Do When Time is Not on Your Side

After we won Parsons vs. Parsons (W2018-02008-COA-R3-CV) at the Court of Appeals, opposing counsel applied for permission to appeal to the Tennessee Supreme Court. The Rules of Appellate Procedure gave them 60 days to prepare and file their application for permission to appeal. Under the rules, we had only 15 days after they filed to file our answer.

Knowing that opposing counsel would do an extensive brief, 15 days (during which we would be dealing with other cases) was inadequate.

Our solution was to meet and analyze opposing counsel’s case. We anticipated what their arguments would be. We began writing our answer before they filed their application. Upon receipt of their 34 page Application for Permission to Appeal, we found we had correctly anticipated the bulk of their arguments. While there were small differences, we were able to get our answer completed and out well before the deadline.

This is a product of a great team working at their best. Thank you Erin O’Dea and Faith Sanford for your outstanding work.

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