unfortunately, and this is supremely moronic, but if i'm going to file a motion under 37 about 38, and do so in writing, i'd need to be denied consent first.
but, i can't file with consent, anyways.
this is so bafflingly daft....
so, if they give me consent to file, i'll need to file without notice. and, if they don't give me consent, i'll need to file in writing. alright...
that means i need to type up a mock motion and see how they react.