SURVIVING MITCHELL 20: THE GREAT BIG OVERALL CHECKLIST
I suspect that this series could go on indefinitely. It is drawn to a close with a round up of the key points.
9. Was about agreeing extensions of time, again I repeat be wary even under the new rules.
10. Again considered extensions of time
12. “Mitchell proof your case from cradle to grave” (courtesy of Legal Orange).
13. Read Kerry Underwood’s Rules of Survival
15. Share the pain
17. Rule 3 repeated (without apology): make applications before deadlines and obtain realistic directions.
18. Know that 99.98% of litigators are stark raving bonkers
WHAT ABOUT RULE 20?
I have pondered this a lot. I think I will credit this to Chris Dale, who cites this extensively.