Write for the naive reader

Here is some good advice for the lawyer struggling to make a brief understandable.

Write the brief for the naive reader. In other words, assume the court knows NOTHING about the law and the facts in your case. Thus, you must make things CHRYSTAL CLEAR for the judge, who is seeing your issue for the very first time.

Imagine the questions she must addresss:

• Why am I reading this?
• What law should apply here?
• What are the relevant facts in this case?

With those simple questions in mind, the first words in your brief should provide her with the answers to those questions. The first words will set the stage and provide a road map for her understanding.