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Appellate Practice

Nov. 2, 2026

Working, Part 8: The respondent's brief

A practical approach to drafting appellate briefs emphasizes early organization, concise arguments, continuous editing and a structured work routine that encourages fresh ideas and avoids writer's block.

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

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Working, Part 8: The respondent's brief

This series of columns describes how I go about writing briefs. It's about the journey more than the destination. Adopt, modify, or ignore them as you see fit.

When I represent the respondent, my work begins when I receive my opponent's Appellant's Opening Brief (AOB). At the same time, I'll receive her Appellant's Appendix (AA), or, occasionally, a Clerk'...

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