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:
- The first step is to think. No document can rise above the thought that generated it.
- Tell the court briefly, clearly, and precisely what you want.
- Tell the court briefly, clearly, and precisely why—legally and factually—you ought to get what you want.
- 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.