Appellate Practice,
Law Practice
Jan. 17, 2023
Be kind to your reader
Writing clearly requires getting out of your shell as a writer, and thinking about your reader.
Myron Moskovitz
Legal Director
Moskovitz Appellate Team
90 Crocker Ave
Piedmont , CA 94611-3823
Phone: (510) 384-0354
Email: myronmoskovitz@gmail.com
UC Berkeley SOL Boalt Hal
Myron Moskovitz is author of Strategies On Appeal (CEB, 2021; digital: ceb.com; print: https://store.ceb.com/strategies-on-appeal-2) and Winning An Appeal (5th ed., Carolina Academic Press). He is Director of Moskovitz Appellate Team, a group of former appellate judges and appellate research attorneys who handle and consult on appeals and writs. See MoskovitzAppellateTeam.com. The Daily Journal designated Moskovitz Appellate Team as one of California's top boutique law firms. Myron can be contacted at myronmoskovitz@gmail.com or (510) 384-0354. Prior "Moskovitz On Appeal" columns can be found at http://moskovitzappellateteam.com/blog.
When you write a brief - to a trial judge or an appellate Justice - you are trying to persuade your target to rule in your favor. So you'd like that person to like you. How?
When the judge gets home from work, he or she might well enjoy reading a good book. Maybe a novel, or poetry - something that makes the best use of some ambiguity and vagueness.
But during the work day, the judge is reading not for fun, but...
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