Monday, September 29, 2008


A sentence should contain no unnecessary words, a paragraph no unnecessary sentences, for the same reason that a drawing should have no unnecessary lines and a machine no unnecessary parts. ~William Strunk, Jr., The Elements of Style, 1918.

Make your points and ask for your relief in a blunt, straightforward manner.


The undersigned counsel do hereby for and on behalf of their clients, for the reasons explained herein below, respectfully request that this Honorable Court consider and hereby rule that no issues of material fact do exist in the instant controversy, and that a final judgment be entered in favor of the client of the undersigned counsel (sometimes herein referred to as “Defendant” or “Cross-Plaintiff”) and against Plaintiff.


Johnson requests entry of summary judgment

From a May 2008 ABA Journal Article on Making Your Case, The art of Persuading Judges by Antonin Scalia and Bray A. Garner.

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