Motions are tactical tools, and your decision to seek an order should be made in the context of your overall litigation plan. Always keep in mind that making a motion entails time, effort, and expense for the moving party. Is it worth it?
When it comes to litigating a case, your client’s objectives are only half the story. If you want to gain an advantage, you’ll also need to successfully assess your adversary’s goals, capabilities, and willingness to fight.