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Garner's Guide to Making Briefs More Persuasive: Tip 8 - Write a draft straight through without


Here's another tip from Bryan A. Garner's The Winning Brief: 100 Tips for Persuasive Briefing in Trial and Appellate Courts.

Garner recommends writing down a draft un-selfconsciously to the end, and only considering revisions afterwards. Don't risk losing momentum to choose exactly the right words. Writing rapidly is a good idea so long as a review for necessary changes takes place later. Nothing is wrong about waiting to correct a bad sentence while letting the ideas flow freely. An outline can serve as a map, as one tries to write as if speaking aloud. Doing this should help the words convey greater swiftness of thinking, and avoid making them laborious to read.

It's a also good practice to allow some time to pass between drafting and the editing.


Sean O'Shea has more than 20 years of experience in the litigation support field with major law firms in New York and San Francisco.   He is an ACEDS Certified eDiscovery Specialist and a Relativity Certified Administrator.

The views expressed in this blog are those of the owner and do not reflect the views or opinions of the owner’s employer.

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