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Every component of your submissions from the memorandum of law through the exhibits should be so organizationally sound that the Judge and/or clerk wants to “live” in your brief.
For example, don’t just cite a voluminous exhibit plainly “See Exhibit A;” rather, cite “Exhibit A, pg. [X] (manager noting “this would be the plaintiff’s last chance and that he should stop coming in late”). “
When we’re looking for something you want us to keep coming back to YOUR brief.
I 100% agree. My philosophy when helping my lawyers organize their briefs is to assume whoever opens it knows nothing about the case. Make it so accessible to reduce time in navigating and increase time to present and argue. Great tip!
Know the issue. Too often attorneys submit 30-page briefs for a simple MTD. Probably because they don’t know what the case truly turns on. The best briefs focus on the dispositive issue, wasting no time with irrelevant and weak arguments.
Don’t try to trick the court. It makes it hard to take the remainder of your arguments seriously.