Attorneys frequently have to calculate dates to determine the deadlines for trial court pleadings, appellate briefs, contractual obligations, etc. Almost two years ago I reviewed a $0.99 app called Court Days from attorney Dan Friedlander (who runs the website Law on my Phone) which gives you the ability to calculate dates even when you need to exclude legal holidays such as weekends and holidays.
Last night, Friedlander released an advanced version of that app called Court Days Pro. Court Days Pro is the first rules-based legal calendering app for the iPhone. This means that the app is designed to take one event (the trigger event) and then calculate one or more other deadlines based on that trigger event. You simply set up each of your rules once, and then you can use them again and again in the future.
Perhaps the best way to illustrate this is by an example. Appellate practice in Louisiana state court is a big part of my law practice. The deadline for filing a notice of appeal in Louisiana state court is computed based on a trigger date of when the clerk of court mails a notice of the trial court's judgment. Once that happens, parties have 7 court days (excluding weekends and holidays) to file post-trial motions such as a motion for new trial of motion for JNOV. Assuming that no such motions are filed, the deadline for a suspensive appeal (an appeal that suspends the execution of the judgment) is 30 days later, and the deadline for a devolutive appeal (an appeal that doesn't suspend the execution of judgment, something a defendant will rarely use but plaintiffs often use when they lose at trial because there is no judgment on which one can execute anyway) is 60 days later. You set up rules by giving the app a trigger date and then other dates that come after it. So in this example, my trigger date is the date on which the clerk of court mails a notice of the trial court's judgment. Then my first resulting date is 7 court days later (i.e. days on which the court is open, excluding weekends and holidays). To set up this date, I just tell the app to take the trigger date and add 7 court days to it:
Next, I set up my second result item, the deadline for a suspensive appeal. Three calculations are required to figure out this date. First, I have to count the 7 court day deadline to file post-trial motions. Second, I have to add 30 calendar days (including weekends and holidays) to that 7 court day deadline. Finally, if that 30th day falls on a weekend or a holiday, Louisiana law advances the deadline to the next court day. On this screen you can see that I have told the app to perform all three of those calculations:
I performed the third calculation by selecting "cal fwd." The other choices include "cal" which would apply if the 30th day were the deadline even if it falls on a holiday. The "cal bk" choice would have given me the last court day that falls just before the 30th day when the 30th day falls on a holiday.
I then set up a similar rule for a devolutive appeal. Everything is the same as a suspensive appeal, except that the second calculation is 60 days instead of 30 days. Once I have all of those entered, I can see that my rule looks like this:
It obviously takes a little time and thought to set up your rule, but then once you have done it, it will be in the app forever. So now, I can always use my rule to perform a calculation without my needing to do any math at all. Let's say for example that I want to see what my appeal deadlines would be if I get a notice of judgment mailed on March 1, 2011. All I need to do is select the first date (3/1/11) and the app instantly shows me the deadlines:
You can see in the prior image that for each deadline, you are also shown the number of days from today based on a calendar and based on the court (non-weekend, non-holiday) days. How does the app know the holidays? The app comes pre-populated with the federal court holidays. You can then modify that list to add your local holidays. For example, you can see on the following image that I told the app that Tuesday, March 8, 2011 is a court holiday in Louisiana (Mardi Gras), and as you can see in the prior image, the app took the Mardi Gras holiday into account when counting the 7 court days for post-trial motions and then using that date to calculate the two appeal deadlines.
You can set up as many rules as you want. For example, here is another rule that I set up that calculates several appeal dates in Louisiana state court such as an Appellant's Original Brief, an Appellee Brief, and a Reply Brief:
I had to fudge a little in this rule because technically the reply brief is due 10 days after the Appellee Brief is filed, but there is no way to tell this app to calculate a resulting date based upon the previously computed date; everything has to come from the trigger date. Thus, in my rule, I just told the app to count 55 days from the date that the record is lodged, which in the example shown in the above images is actually a little early. Nevertheless, the app can give me a sense of how all of the deadlines will work out. Perhaps in a future update Friedlander will add the ability to make rules even more sophisticated to account for situations like this one.
Note that in these two examples I created my own rules, but the app comes with a number of sample deadlines based on the California Code of Civil Procedure. If you don't practice law in California, you can delete those entries, but I left them in when I created this image just to give you a sense of some of what is there, along with my two Louisiana appellate rules that I created:
This is a universal app, so you can also use it on an iPad and the app is formatted for the iPad's larger screen. Frankly, though, the app works just fine on an iPhone and I don't think that you gain much with the iPad screen.
Calculating dates may seem simple because it is just math, but it is very easy to make a mistake when you do so, and I know several examples of attorneys missing appeal deadlines, resulting in prejudice to their client and a malpractice lawsuit for the attorney. You may know of some of these examples yourself. An app like Court Days Pro is incredibly useful because after you take the time to carefully set up a rule-based calculation just once, in the future you can just give the app a start date and have the app do all of the hard work for you, making it easier to calculate dates for your clients (note to mention avoid malpractice lawsuits based on miscalculating dates). There is a slight learning curve to using this app — just as there is a slight learning curve to figuring out how dates are calculated based on the federal and state rules of procedure – but once you get over that learning curve, this is an incredibly useful app that I encourage every lawyer to consider buying. Note that the app will cost $3.99 starting next week, but if you buy it this week you can pay the introductory price of $2.99, so save yourself a buck and buy it today.