It's just a term for ruling on everything on the table all at once. This is a hearing on a bunch of duplicative bullshit motions that are on the table. It's arguable Hardin shouldn't have even brought this final thing (262) up at all, about an already disposed of motion (213).
However, if he had to spend ANY TIME AT ALL even dealing with and trying to locate imaginary police reports to detectives and analyze legal issues about it, it's related to the sanctions (228, 218, 234).
In case it sounds like I'm trying to slither out of having been wrong about one issue (262 does not mention any specific motion on the table), this whole docket is a mess, but frivolous threats of bringing felony complaints to the police and Hardin having to do any research whatsoever is definitely relevant to sanctions (228).
But you caught me with my drawers down. It doesn't cite what I said it did. I was wrong about that.
I agree nothing should generally be filed without actually being some kind of motion or being related to a motion.
I do not agree this is the wrong time to file it, since it's relevant to something on the table.
I have no strong opinion as to whether it should have even been filed at all. I'm leaning towards yes. As counsel you have to respond to scandalous, damaging, and utterly false accusations filed by the other party or you are seen as conceding them. And if they're relevant to a hearing, the time to file is BEFORE that hearing.