§ 21. Plan all three parts: the beginning, the middle, and the end.
Exercises
Basic
Find a brief or judicial opinion that has a particularly good opener and closer. (For a brief, you might look at books with model briefs. You might also look at continuing-legal-education materials on appellate practice.) If you belong to a writing group or class, bring a copy for each colleague. Be prepared to explain why you think the introduction and conclusion are effective.
Intermediate
Find a research memo that has no proper opener or closer--that is, one that's all middle. Write both a summary that could be added at the start and a fresh conclusion. If you're part of a writing group or class, bring a copy of your work for each colleague. Be prepared to discuss the problems in the original and how you tried to solve them.
Advanced
Find a motion (or memorandum in support) or a brief that launches straight into a statement of facts. Write a new preliminary statement that could be inserted at the beginning of the motion or brief. If you're part of a writing group or class, bring a copy of your summary for each colleague. Be prepared to discuss the problems in the original and how you tried to solve them.
© 2001, Bryan A. Garner
These exercises appear in Bryan A. Garner's Legal Writing in Plain English: A Text with Exercises, published by The University of Chicago Press and available at bookstores and on the Web at www.press.uchicago.edu.