[NutCrackerBoy]

Every motion I write states "and any other relief the Court deems appropriate."

So help me out here. If the filer writes that prophylactic phrase into the motion, it removes the judge's flimsy excuse for inaction re semi-colon? But, even so it is crystal clear that the judge copped out on a hyper-technicality, right?

I M P E A C H

[tort_feasor]

By adding that phrase, the other side can't claim they weren't prepared for that issue of relief. If it is open ended they have to be ready for everything inclusing an oral motion for summary judgment.