A recent bar journal article by appellate lawyer and former judge Raoul Cantero entitled "Three Simple Ways to Improve Your Briefs" offers some practical advice for immediately improving one’s appellate advocacy.
The author suggests three basic ways to improve briefs:
Shorten the brief - Shorter briefs have more impact than longer ones. To shorten your brief: 1) detail only the facts relevant to the issues on appeal; 2) reduce the number of issues on appeal; and 3) improve your writing by cutting the fact.
Include an introduction - A short introduction allows the judge to place the facts of the case in context.
Divide the brief into subsections and introduce those subsections with an outline. This gives the judge a psychological break as he reads the brief.
For more, read the entire article.
Hat tip to the Legal Writing Prof Blog.