Currently, every court which permits or requires the electronic filing of motion papers still requires the litigants to file paper copies of the motion papers. In federal court, the hardcopy of the motion papers is called a “Courtesy Copy.” In state court, the hardcopy is called a “Working Copy.” I recently encountered an example of the judge who issued a directive that hardcopies of motion papers would no longer be needed. The judge stated that he would be relying on the electronic version of the motion papers. It looks as if judges are truly moving, though slowly, to the fully electronic processing of papers. Trees are likely to be grateful about this development.