Rescue & Trace
beat the premature motion · enforce what you wonTwo ends of the case, one discipline. Rescue: a premature summary-judgment motion is beaten with a declaration naming specific unavailable facts and honest diligence — vague "we need more discovery" loses. Trace: a judgment is only as good as the assets behind it — the Fact Information Sheet, the transfer badges, and the alter-ego evidence map, gated lawfully.
The unavailable facts — specific or nothing
The diligence timeline
BLOCKED — the showing is incomplete
✕ Fact 1 is incomplete: missing the fact itself, why it defeats or genuinely disputes the motion, where it lives (witness, custodian, system), why you don't have it yet.
✕ No diligence record — the declaration must show you pursued this discovery; an empty timeline reads as neglect.
✕ No specific proposed discovery — name the exact depositions/requests and a completion date; open-ended continuances get denied.
The schedule belongs to the COURT: a private stipulation extends nothing the court controls. Relief from a summary-judgment clock or a discovery cutoff comes from an order — file the motion; don't rely on the handshake.
TrialVector is software, not a law firm — legal information, not legal advice; nothing you enter leaves your browser. Reopening a closed discovery period lives in the enforcement engine's good-cause analysis; the aggression governor is the Escalation Zone.