Fixed fees, banded by what the motion actually is.
A summary judgment on a signed note with a defined sum is not the same animal as one between partners with competing valuations. So the fee is banded, and you are told which band before you engage — not after.
What moves a file between bands: whether the sum is liquidated; whether an expert is required on either side; how many affirmative defenses have to be taken down and whether any of them has evidence behind it; whether a records custodian has to be proved up; whether there is a hearing that will actually be argued; and how much of the record has to be reconstructed before anything can be drafted.
On price generally: the reading, record reconstruction and first draft that used to make small cases uneconomic now take hours rather than days. That is why a flat fee can be quoted where a firm would have to bill hourly. The judgment about which mechanism to use is unchanged, and it is the thing being sold.
| Engagement | What it looks like | To filing | Flat fee |
|---|---|---|---|
| Tier I — Documentary | Liquidated sum, signed instrument, no expert, no real fact dispute. A note, a guaranty, a lease balance, a sworn account. | 2–3 weeks | $3,500 – $8,500 |
| Tier II — Contested | Live affirmative defenses, a records custodian to prove up, evidentiary objections to brief, a hearing that will actually be argued. | 4–6 weeks | $15,000 – $25,000 |
| Tier III — Technical | Competing valuations, fiduciary duties, multiple movants, expert challenges, partnership or construction facts. The motion that decides the case. | 6–10 weeks | $30,000 – $60,000 |
| Hearing only | Your motion, your brief, my argument. I read the file, prepare, and stand up. | By setting | $2,500 – $6,000 |
| Read & opinion | Send the file, get a written answer: which mechanism fits, what it is worth, what it costs to get there. Credited against any engagement that follows. | Same day where the file arrives before noon | $1,500 |
| Enforcement | Abstract, writ, turnover, receiver. Quoted on the judgment and the debtor, after a look at what there is to reach. | By posture | Quoted |
Murphy v. Liberty Hill Construction & McGrathEight causes of action, arbitration waiver, three evidentiary strikes, then a receivership.
Aramcor, Inc. v. Tri Marsh Retail LLCCAM reconciliation. Opposing declaration struck; judgment granted in full the day of the hearing.
Johnson & Farst v. CarnesHunting lease. Response struck for want of competent evidence; judgment on the whole case.
Restaurant tenant · partial defaultDamages proved by affidavit against an out-of-state defendant.