|Some tips are more helpful than others...|
1. Stay Away From Old Precedent (and don't cite uncitable cases, and understand stare decisis).
2. Be Wary of Precedent from Other Circuits (with a dig here from a Pittsburgh-based attorney saying to be careful about citing case from that wacky ol' Ninth Circuit...)
3. Tread Carefully When Citing Unpublished Cases (especially trial court cases that have no precedential value -- unless there's really nothing else to cite and perhaps it's from a "well-respected judge")
4. Don't Mask Facts in Cited Cases (and don't cite cases that have been overturned, disapproved or overruled by statute w/o noting that fact).
Over at The Recorder, Myron Moskovitz is back, this time with Writing a Powerful Statement of Facts--Part Two, with more tips:
1. Tell a good story: make your factual statement as interesting and readable as possible.
2. Clarity is paramount
3. Explain the basics