Appellate Practice
May 15, 2017
Statement of facts: Part III
Any appellate judge will tell you that the standard of review is the first thing they look for in a brief.





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
A persuasive brief is an integrated document. Each part should coordinate with every other part, employing a common theme towards a common goal.
So the story told by the "Statement of Facts" section supports the "Argument" section, and the "Argument" shows how the law applies to the story, and together they lead to appellate victory for your client.
The Importance of the Standard of Review
Lawy...
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