First and foremost, a brief must tell a compelling story. It should cry out for relief for your client. Judges are people; they want to feel like they are doing the right thing. Help them rule in your favor: tell your client’s story. Use classic archetypes. Cast the characters of your lawsuit into traditional roles in a story: victim, hero, orphan, widow, prodigal son, etc. Convince the Court that the world will be a better and fairer place if your client wins.

“Not everything that can be counted counts, and not everything that counts can be counted.” ~ William Bruce Cameron, Informal Sociology, 1963

In response to last week’s Bard of the Bar post (Build Your House Part 2 – Blueprint), a colleague who receives this blog asked me to clarify what I meant by “annotated outline of the brief” in task five of the Blueprint Time Estimation Checklist. I would like to share my answer, and expound upon it a bit, in this post.

Below is a simple outline for planning a lengthy writing process, allowing you to work on several briefs simultaneously while managing the rest of your practice. It is necessary to jump into (and out of) each brief at a sensible point. Just like a contractor has to build more than one structure at a time, it is rarely possible to work on just one brief at a time. If you know where you are in the process, it is easier to start again after setting your brief aside for a few days.