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The statement of facts in an appellate brief can be the most important section.  Even if your opponent’s strengths are legal arguments.  Don’t follow them down their rabbit hole and ignore your own strengths.  If you have great facts, make that your focus.  If you get the judges to agree with you that what the defendant did was just plain wrong, you have a good chance at persuading them.
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Check out my latest blog post.  "Quick tips on writing appellate briefs."
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