Mind Your ABCs
Steven B. Katz
Partner - Appellate Practice Group Co-Chair at Constangy, Brooks, Smith & Prophete LLP
Always Be Connecting. As you write, every element should connect to the last one (or the next): grounds to results, section to section, paragraph to paragraph, often sentence to sentence. Keep the reader connected at all time to the superstructure of the argument.
Your judge should never wonder, “Why I am reading this?” They should know.