The 22 MB Filing at 3:40 p.m.
It is 3:40 p.m. on the day a motion for summary judgment is due. The court's electronic filing portal closes at 5:00 p.m. and rejects PDFs larger than 15 MB. Your draft is a 22 MB PDF scanned at 600 dpi. It includes 38 pages of exhibits, a scanned signature page, and an OCR layer. A colleague reviewed it and inserted an internal comment on page 12: 'Check cite-this may be wrong.' The file properties still show the author as 'R. Patel' and the title as 'DRAFT-do not file.' The motion also contains a one-page exhibit that is a client's medical record with a visible account number. You have the original Word file and the scanner. The certificate of service is unsigned. The attorney is in a deposition and texts: 'File it-I will sign later.'
1. List the steps you would take, in order, to produce a compliant filing before 5:00 p.m.
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First, stop and fix the known cite; do not file a document your colleague flagged as possibly wrong. Pull the source and correct or remove the citation. Second, redact the medical-record account number from the exhibit, using true redaction rather than a black box, and verify by copying text. Third, remove the internal comment and all metadata with the document inspector, set author and title appropriately, and flatten a clean copy. Fourth, reduce file size: rescan exhibits at 300 dpi black-and-white, split exhibits into separate files if the court permits, and compress images; confirm the OCR layer survived and the page count matches. Fifth, obtain the attorney's signature through the firm's approved e-signature method; a paralegal may not sign the attorney's name. If the attorney cannot sign before 5:00, file a motion for a short extension before the deadline, not an unsigned motion. Finally, file, save the confirmation, and verify the docket entry.
2. How should the metadata, internal comment, and medical record be handled, and why?
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The comment 'Check cite-this may be wrong' is work product and reveals internal doubt; if filed, it could be used to attack the motion. Metadata such as author and 'DRAFT-do not file' embarrasses the firm and may reveal the file path or prior versions. Remove both with the word processor's inspect-document feature and by printing to PDF; do not rely on deleting the visible comment only. The medical record account number is personal health information; redact it unless the court requires the full record, and consider a protective order. True redaction removes the underlying text, not just the display. Keep an unredacted copy in the confidential file with a redaction log. Before filing, open the final PDF in a viewer, search for the account number, and check that no comments or hidden layers remain.
3. The attorney texts 'File it-I will sign later.' What is the ethical and practical problem?
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The text is not a signature and does not satisfy Rule 11 or the court's e-filing rules. Filing an unsigned motion risks being stricken, and if the court later finds the citation error, sanctions. A paralegal also cannot sign the attorney's name or use the attorney's e-filing credentials unless the firm has a documented, authorized process; doing so could be unauthorized practice or forgery. The practical fix is to reach the attorney during a break, use the firm's remote e-signature, or file a motion for extension before 5:00 with a declaration explaining the need. Do not file the motion with a placeholder signature and 'sign later.' If the attorney expressly authorizes you to file under the firm's procedures and the court permits electronic signature by the attorney, document that authorization. Otherwise, the deadline does not override the signature rule.