The Volokh Conspiracy
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Lawyer's Motion "Does Not Contain a Single Citation Identifying Relevant Legal Authority That Supports Plaintiff's Position"
From Judge Jorge Alonso (N.D. Ill.) yesterday in Doe v. Doe Defendants 1-10; note that plaintiff is represented by a partner at a midsize law firm:
Plaintiff has filed two motions before the Court. A motion 3 to proceed under pseudonym and a motion 4 for expedited discovery. Motion 3 does not contain a single citation identifying relevant legal authority that support's Plaintiff's position. And motion 4 contains just one citation to the language of Federal Rule of Civil Procedure 26(d)(1). Motion 3 and motion 4 are denied without prejudice. If Plaintiff wishes to proceed on these arguments, Plaintiff shall refile these motions by 2/11/26 with proper citations that support's Plaintiff's position.
For a few uncontroversial motions, one can sometimes get away without citations. (That's especially so if the other side has appeared and consents to the motion.) But for motions like this, that's generally not enough, as the judge's order reflects.
