The new bankruptcy lawyer sent me an email.
What do I file when there’s an objection to my client’s amended Chapter 13 plan: notice a hearing? file a demurer?
In her case, the form of the “objection” suggested the opposing counsel was as new to bankruptcy as the debtor’s lawyer.
First: figure out whether there’s a lawyer-to-lawyer solution before figuring out how to involve a judge.
Pick up the phone; find out what the other side’s position is. What do they want? Is it something your client can, or will, offer? Is there a compromise that might resolve the matter here and now?
The essence of being a good consumer lawyer is problem solving, usually for as little expense as possible.
Start with the assumption that the other lawyer wants to solve a problem, too. They may have some other goal, or just be going through the motions.
But until you understand what the other side thinks they want, you can’t craft a good strategy for your client.