Appellate Practice
May 8, 2015
Briefs: If it ain't clear, it ain't there
Appellate justices and law clerks are busy. They do not want to - and won't - take the time to decipher and untangle ambiguous phrases and complex sentences.





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
Suppose the following lead sentences appear in the statement of facts of an appellate brief. What's wrong with them?
On July 28, 2014, the trial court found for Mega Big Corporation (hereafter "MGC"), which was incorporated on May 5, 1995, and against Mundy Tools, Inc. (hereafter "MTI"), which was incorporated on August ...For only $95 a month (the price of 2 article purchases)
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