Appellate Practice
Sep. 21, 2026
Working, Part 5: Adding meat to the bones with 'AOB 2'
In the latest installment of his brief-writing series, Myron Moskovitz explains how he builds an appellate opening brief by assembling key portions of the record, transcripts and legal research into a comprehensive working document.
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.
This series of columns describes how I go about writing briefs. Adopt, modify, or ignore them as you see fit.
In my last column, I explained how I set up an "AOB 1" subfolder to draft the basic structure of the Appellant's Opening Brief: an outline of the issues. I may also develop the brief's theme through the In...
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