Field notes on sound money, good food & practical legal writing

ISSUE 002 / OCTOBER 2026

Three
obsessions.
One notebook.

I mine Bitcoin, chase memorable meals, practice law, and go to the Bitcoin conference every year. This is where the hash rate, hot sauce, and hard questions meet.

Rows of Bitcoin mining computers with circular cooling fans A woman's hand editing a printed court motion with a red pen Half a carne asada burrito with an orange Bitcoin logo resting on Mexican rice and black beans, with pico de gallo, avocado, lime, lettuce, and cilantro
Bitcoin

Mining notes, policy shifts, and the things worth watching past the price ticker.

Burritos

Great meals, practical recipes, and a strict refusal to accept a bad tortilla.

Briefs

Practical tips for legal writing and litigation practice, clearly framed.

01 / BITCOIN

Citi calls $113K

Wall Street’s most reluctant bull just turned.

$113K
12-month Bitcoin target Raised from $82,000 in a Citi note reported October 1, 2026

Citigroup raised its 12-month Bitcoin price target to $113,000 from $82,000 and lifted its ether target to $3,028 from $2,240. The bank expects “slower but stickier” ETF inflows of $5 billion over the next 12 months as advisers gradually increase Bitcoin allocations.

The call arrived with Bitcoin trading around $86,000. That made Citi’s target a meaningful vote of confidence, but the sharper story is the reversal. Citi began 2026 at $143,000, cut its target to $112,000 in March, and lowered it again to $82,000 in July. U.S. spot Bitcoin ETFs had recorded $5.8 billion in year-to-date net outflows by July 13; by late September, that had reversed to $800 million in net inflows.

The policy backdrop turned too. The Senate rejected the Clarity Act on September 15, yet Bitcoin still gained more than 10% by month-end, helped by SEC rulemaking Citi called “a temporary but meaningful positive” and by Treasury bond buybacks. Citi also warned that a change in administration in 2028 could roll back rules put in place by federal agencies.

The read: Citi did not become a moon-shot evangelist. It became a reluctant bull again, and the turn itself is the signal worth watching.

CoinDesk report Reuters report

MARKET COMMENTARY BASED ON A REPORT PUBLISHED OCTOBER 1, 2026.

02 / BURRITOS

Crash and hash

The “crash” is a motor vehicle crash. Car, truck, motorcycle, bicycle, or pedestrian. Lawyers say “crash” not “accident” because someone is usually at fault. Lots to hash out, so we start with the what-to-do-after-a-crash checklist. The “hash” is corned beef hash. Crispy comfort food for after you have hashed it all out.

Crispy corned beef hash with diced potatoes and onion, topped with a fried egg
Crispy corned beef, potatoes, and onion, one pan and about 30 minutes.
Front cover of the Injury Recovery Journal by Erin M. Evans
Injury Recovery Journal: a six-month guided record for pain, symptoms, treatment, costs, and daily limitations. Email me to buy one for $24.95 within the United States.

THE CRASH

After a car crash

A PRACTICAL CHECKLIST BY ERIN EVANS

At the scene

  • Call 911 if anyone is hurt. Call police even if the crash seems minor.
  • Move to safety if you can, but do not leave the scene.
  • Photograph every insurance card, driver license and plate, plus the scene, all vehicle damage and every injury.
  • Get witness names and numbers, the Collision Exchange Slip, and the Tow Slip if your vehicle is towed.
  • Give the facts. Do not apologize or discuss fault.

In the first few days

  • Get checked out promptly. Adrenaline can mask pain and injuries for hours or days, and documenting the visit connects later symptoms to the crash.
  • For every provider treating your crash injuries, write down the provider’s contact information and the injury being treated, then register for the patient portal so you can reach your records, results and messages.
  • Notify your insurer with only the date, location and vehicles involved. Check for uninsured/underinsured motorist and medical payments coverage.
  • Give no recorded statement and sign nothing until you speak with a lawyer licensed in the state where the crash happened.
  • Stay off social media. Preserve photos, video and damaged items; order the police report and body-camera footage quickly.

In the weeks that follow

  • Follow the treatment plan and keep every appointment.
  • Use my Injury Recovery Journal, shown below, to track pain, limitations, bills, receipts and missed work, or make your own. Email me to buy one for $24.95 within the United States.
  • Do not accept a quick settlement before you know the full extent of your injuries.
  • Talk to an attorney early. In Arizona, most injury claims must be filed within two years, and claims against public entities require a notice of claim within 180 days, but check with an attorney in the state where the crash occurred for the appropriate statute of limitations.

THE HASH

This weeknight hash keeps dinner simple: potatoes, onion, and corned beef crisped together in one skillet in about 30 minutes.

One-pan corned beef hash

EASY WEEKNIGHT SKILLET / ABOUT 30 MINUTES

THE RECORD

  • 2 medium potatoes, diced small
  • 1 small onion, diced
  • 2 cups cooked corned beef, chopped
  • 2 tablespoons butter or oil
  • Salt and black pepper
  • Fried eggs, optional

THE HOLDING

  1. Heat the butter or oil in a large skillet over medium-high heat. Add the potatoes and cook for 12 to 15 minutes, stirring occasionally, until tender and browned.
  2. Add the onion and cook for 4 to 5 minutes, until softened.
  3. Add the corned beef. Press everything into an even layer and cook without stirring for 4 minutes; turn and cook another 3 to 4 minutes, until crisp at the edges.
  4. Season with salt and pepper. Finish with a sunny-side-up egg, so the yolk runs over the hash when broken.

ONE PAN. CRISP EDGES. DINNER IN ABOUT 30 MINUTES.

GLUTEN-FREE NOTE: Potatoes, onion, corned beef, egg, and seasonings are naturally gluten-free, but check the corned beef label because some brands add gluten-containing fillers or flavorings.

03 / BRIEFS

Hyperlink to the record

I want to remove every ounce of friction between my citation and the judge’s eyes.

A woman's hand editing a printed court motion with a red pen
A clean citation gets the reader close. A working hyperlink gets the reader there.

Arizona is split on hyperlinks, so I start by asking which division will receive the brief.

Division Two (Tucson): ARCAP Rule 13.1(a) says an electronically filed brief must include electronic links when citing the record or other items, and must not include an appendix. Division Two even publishes step-by-step Hyperlink Instructions.

Division One (Phoenix): there is no published hyperlink policy. ARCAP 4.2(e) permits and encourages hyperlinks, while the appendix remains the norm under the Division One civil brief checklist. I found no published individual hyperlink preference for a judge in either division.

Difference from Division One: In Division One, bookmarks are commonly used to navigate internal multi-document exhibit appendices; in Division Two, because appendices cannot be attached to electronic briefs, bookmarks are reserved for the sections of the brief itself. Division One e-filing guidance.

Portal distinction: While Division One and the Arizona Supreme Court utilize AZTurboCourt, Division Two operates its own dedicated appellate portal called e-filer.

Two statewide rules matter everywhere: under ARCAP 4.2(e), a hyperlink does not make the linked material part of the official record. And when I cite an unpublished memorandum decision, Rule 111(c)(3) requires me to provide a copy or a free hyperlink to it.

GENERAL INFORMATION ONLY; NOT LEGAL ADVICE. THIS MAY NOT BE A COMPLETE LIST OF REQUIREMENTS, AND COURT RULES MAY HAVE CHANGED SINCE THIS WAS WRITTEN. THIS SUMMARY MAY CONTAIN ERRORS, SO VERIFY THE CURRENT RULES YOURSELF AS PART OF YOUR OWN DUE DILIGENCE.

MY FRICTION-FREE RECORD

Make every citation earn the click

01
Know the division

In Division Two, I link to the electronic record and leave out the appendix. In Division One, I use the appendix, bookmark it for navigation, and add links where they help.

02
Link the exact page

I send the reader directly to the filed-stamped PDF page that supports the proposition, not the first page of a long exhibit.

03
Preserve the links

I build hyperlinks in Word, then use File → Save As → PDF or Export. I do not use Print to PDF; it can strip the links.

04
Test the final PDF

I open the finished PDF and click every single link before filing. Division Two’s own instructions stress this step.

05
Check the court’s rules

Before filing, I check the applicable rules and the court’s current local instructions on hyperlinking.

06
I prefer footnotes

I put exhibits in the footnotes with the hyperlink, not in the body of the pleading. Pick one placement or the other, never both. Duplicating exhibits in the body and the footnotes just doubles the clutter.

ARCHIVE

Past issues

Every notebook entry, preserved in full.

Issue 002: Citi Calls $113K Read issue → Issue 001: Three obsessions. One notebook. Read issue →
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