
Also in today's DJ is Moskovitz on Appeals: Appellate Adventures, Chapter 6: "How do I write the procedural facts?" which suggests including when the original complaint was filed, the date of the judgment and notice of appeal, and the location of key procedural documents in the record. Also, tell the procedural story chronologically, starting with the original complaint and ending with the notice of appeal. Don't include over argument (or editorializing) in the statement of facts or procedure.