The Aim of Motions

I received Lynn Hughes's Clearing the Fog of Words — Writing for Effect and Efficiency in an email not too long ago. His article has lots of good advice, especially when it comes to drafting motions. Here's what he says:

If you insist on filing a paper, you must want something from the court that the other side does not want you to have; otherwise there is no need for it. There are four steps:

  1. The first step is to think. No document can rise above the thought that generated it.
  2. Tell the court briefly, clearly, and precisely what you want.
  3. Tell the court briefly, clearly, and precisely why—legally and factually—you ought to get what you want.
  4. Furnish the court with a proposed order that grants the relief specifically.

Sounds pretty easy, but the proof of the pudding is in the eating.