After extensive experience with the matter these are impressions I surmise:
A Refusal for Cause is abatement. Processing abatement detailing reasons for the Refusal would be a memorandum of law. Any attorney looking at a memorandum of law is looking for case citations. I heard somewhere recently that nobody ever cites jury decisions. I have not thought that through yet. Maybe it's true. That seems to be the gist of the Tenth Circuit in the note at the bottom of Page 1. This res judicata decision was decided by jury.
http://friends-n-family-research.inf...nsminger_1.jpg
http://friends-n-family-research.inf...nsminger_2.jpg
http://friends-n-family-research.inf...nsminger_3.jpg
Experience tells me that if you want to talk to an attorney (in a black robe or not) about Bouvier's and Black's or get this; what is right or wrong, you are wasting your breath. While he may still be paying off his student loan do you think he will lend you an ear to teach him about law? Especially when his livelihood depends on him adhering to the private intellectual property of the Bar?
Get the R4C process down and learn how to elevate the authority of the Act with Registered Mail rounddates etc. Use process servers and they can be your friends for cheap as long as they detail the event and sign with a notary.
However sometimes people want an extraordinary writ in the style of a memorandum of law and so they hire me. I tend to overcharge them to discourage them from hiring me in the future - next time do it yourself [at over $100/paragraph]. And since the process works, mainly because of the R4C in my opinion, who's to say the memorandum did not contribute to the success?
Regards,
David Merrill.