Garner's Guide to Making Briefs More Persuasive: Tip 5 - At an early stage, frame your issue sta
Don't draft a preliminary section of a brief before you can frame all of the issues. Briefs that are begun before issues are fully drafted will tend to be meandering and repetitious. A good writer should be willing to discard paragraphs if his or her understanding of the issues later changes.
The opening paragraph of a brief should make clear which side the author is on, and clearly state the problem. Concentrate on the legal issues and how their resolution will affect people. Don't begin by merely reciting what rule or statute a motion or appeal is made under, and who the parties involved in the matter are.