After practicing for almost thirty years, I have read a lot of briefs and seen many different writing styles. It still amazes me, however, that many lawyers ignore a fundamental tenet of persuasive writing- telling the reader their position in the opening paragraph. Instead, the rationale is not revealed until several pages into the pleading. Choose your words wisely. Drop the archaic language (e.g., COMES NOW) and get to the point. Your reader will thank you.
GET TO THE POINT
