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.