I drafted 7 perfect pages (or so I thought), but all I heard back was:
I drafted 7 perfect pages (or so I thought), but all I heard back was:
โ๐๐จ ๐ก๐๐๐๐ข๐ง๐ ๐ฌ?
๐๐จ ๐๐๐๐๐๐๐๐???
๐๐ข๐ ๐ฒ๐จ๐ฎ ๐๐๐ญ๐ฎ๐๐ฅ๐ฅ๐ฒ ๐๐จ ๐ 7-๐ฉ๐๐ ๐ ๐
๐๐๐ญ๐ฌ ๐ฌ๐๐๐ญ๐ข๐จ๐ง ๐ฐ๐ข๐ญ๐ก ๐๐ ๐ก๐๐๐๐ข๐ง๐ ๐ฌ?โ
The partner was incredulous, her voice rising in pitch and exasperation with each question
โ(all the while radiating that special, howโcouldโyouโbeโsoโstupid energy that BigLaw partners exude so well).
I was stunned. I genuinely had no idea what she meant. It was the first Statement of Facts Iโd ever written, I mumbled, in a pathetic excuse.
Well, lesson learned.
I never again forgot headings or the power they have to break up long facts sections to make them more readable (and more persuasive).
So assuming youโve already internalized that same lesson, hereโs my suggestion for your next Statements of Fact:
โก๏ธ Try to tell a story with the headings โฌ
๏ธ
By the time the court reaches your argument, it should already be leaning toward your clientโbecause of how youโve crafted your Facts section.
And you want the court to be able to scan it and see the story youโre selling through headings alone.
To illustrate, consider the following from the Statement of Facts in a gender-based employment discrimination case.
A: ABC Co. hires P based on her job application.
B: P regularly arrives late to work, without explanation.
C: ABC warns P in writing about her tardiness.
D: P continues to arrive late.
E: ABC discovers P lied on her job application.
F: ABC investigates and confirms the lie.
G: ABC terminates P for tardiness and dishonesty.
Thatโs a pretty compelling story from the employerโs perspective, right? And as you would have guessed, the above comes from ABCโs brief.
Might you try a similar framework in your next Facts section?
Try it and let me know how you do!
๐ Amanda
#DearLegalWriter