Appellate Practice
Jun. 5, 2017
Statement of Facts: Part IV
Every part of your brief should be as clear as a bell. This includes the "Statement of Facts." If it ain't clear, it ain't there.
Myron Moskovitz
Legal Director
Moskovitz Appellate Team
90 Crocker Ave
Piedmont , CA 94611-3823
Phone: (510) 384-0354
Email: myronmoskovitz@gmail.com
UC Berkeley SOL Boalt Hal
Myron Moskovitz is author of Strategies On Appeal (CEB, 2021; digital: ceb.com; print: https://store.ceb.com/strategies-on-appeal-2) and Winning An Appeal (5th ed., Carolina Academic Press). He is Director of Moskovitz Appellate Team, a group of former appellate judges and appellate research attorneys who handle and consult on appeals and writs. See MoskovitzAppellateTeam.com. The Daily Journal designated Moskovitz Appellate Team as one of California's top boutique law firms. Myron can be contacted at myronmoskovitz@gmail.com or (510) 384-0354. Prior "Moskovitz On Appeal" columns can be found at http://moskovitzappellateteam.com/blog.
MOSKOVITZ ON APPEALS
Every part of your brief should be as clear as a bell. This includes the "Statement of Facts." If it ain't clear, it ain't there.
When I consult on appeals, sometimes I review a statement of facts that is pretty much unreadable gibberish to a reader who begins with zero knowledge of the case - i.e., an appellate judge or law clerk. The reason: The writer was so immersed in...
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