In "The Occasional Litigator's Guide to Making the Most of Pleadings and Motions," Patrick M. Kinnally warns that knee-jerk motions to dismiss may do little more than educate your opponent:
[D]etermine whether your motion will be counterproductive--that is, will you be educating your opponent, who will simply replead based on information you supply? Leave-to-amend pleadings and file amendments are construed liberally by our trial courts, as well they should be. Filing motions to show how smart you are may boost your ego but deplete your client's pocketbook.
Kinnally's article appeared in the August, 2004, edition of the Illinois Bar Journal. I can't link to the article directly, but the sentiment about motion practice easily stands alone.
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