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Paralegals across the country who have toiled away checking citations in lengthy briefs will likely have wondered at some point if the judges receiving the briefs pay much attention to the citations. Judge Jonathan Goodman of the United States District Court for the Southern District of Florida certainly does. The Tip of the Night for January 29, 2019 discussed Sosa v. Carnival Corp., No. 18-20957-CIV, 2019 U.S. Dist. LEXIS 12283 (S.D. Fla. Jan. 25, 2019). In a footnote to his decision, Judge Goodman faulted both parties for failing to provide a case docket number with citations to unreported Westlaw citations.
"The Undersigned does not view the Bluebook requirement of a parallel case docket number in a Westlaw citation in an unreported case to be a hyper-technical, nit picky-type obligation. To the contrary, there may well be a need or desire to evaluate the docket sheet and record evidence from the unreported case -- and the case docket number makes it easier to track down the case on PACER." Id. at *8 n.1. Refer to Bluebook Rule 10.8.1(a)