Consider what you say

Very few people write like they talk.  For examples, I can’t speak Latin, so I would guess that most judges would rather you not speak Latin.

I like to personalize each party by name.  It’s hard to keep straight plaintiff v defendant, or appellant v appellee.  I prefer you refer to the parties by their name.  Please, please try to avoid using initials (IBM is ok).

A court’s should not decide a case based on feeling or a belief.  So, please don’t argue “I feel that the evidence was insufficient”; or “I believe that the trial court erred. . . .” Instead, you should argue “The evidence was insufficient,” or “The trial court erred because . . . .”

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