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The Statement of Facts is a critical segment of an appellate brief. In crafting it, a writer should take a somewhat different approach from that taken when he writes a memo. The Statement of Facts should be written persuasively, consistent with the overall persuasive nature of the brief as a whole.

ABOUT PLEADING PAPER Your name must start on line 1. The Court name and location must start on line 8. The caption of the case must start on line 11. You must have a footer with the title of the document.

Writing an Outstanding Appellate Brief Frame the issue to maximize the persuasiveness of your argument. ... Simplify the issue and argument. ... Have an outstanding introduction. ... Tell a story. ... Don't argue the facts (unless absolutely necessary) ... Know the standard of review. ... Be honest and acknowledge unfavorable law and facts.

WHAT SHOULD AN ISSUE STATEMENT INCLUDE? An effective issue statement includes three critical components: (i) the controlling law, (ii) the legal question, and (iii) the legally significant facts. by mentioning only your client's right to freedom of speech.

Writing a Statement of Facts Tell a story. ... Don't be argumentative. ... You can – and should – still advocate. ... Acknowledge unfavorable facts. ... Eliminate irrelevant facts. ... Describe the record accurately. ... You can include law in the facts if it's appropriate. ... It's not just what you say, but how you say it.

(1) A brief may be reproduced by any process that produces a clear, black image of letter quality. All documents filed must have a page size of 81/2 by 11 inches. If filed in paper form, the paper must be white or unbleached and of at least 20-pound weight. (2) Any conventional font may be used.

The preliminary statement must depict the real-life factual story. It should also broadly describe the law that requires the appellate court to find error below and therefore come out in your favor. You should write and rewrite it (and then write it again)—because it is critical to success.