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Undergraduate Legal Writing: an Open Resource
  • Undergraduate Legal Writing: an Open Resource (version 2)
  • Getting Started
    • Course Overview
    • Succeeding in Legal Writing
    • The Legal Reader
  • Essential Concepts and Skills
    • Sources of Law and Court Systems
    • How to Read Case Opinions
    • Briefing Cases
    • Rule-Based Writing and CREAC
    • Rule-Based Writing and CREAC, adding Analogies
    • Legal Citation: Basic Concepts and Moves
  • Advice and Examples
    • Predictive Memoranda
    • Client Letters
    • Mediation Statements
    • Motions
  • References
    • References
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  • CRARC Organization for Advocacy Writing
  • Example #1 of Motion
  • Example #2 of Motion
  1. Advice and Examples

Motions

PreviousMediation StatementsNextReferences

Last updated 2 months ago

Wayne Schiess offers excellent advice about writing to a trial judge:

CRARC Organization for Advocacy Writing

Judge Gerald Lebovits argues that CRARC is a better, more persuasively organized format for advocacy writing than predictive writing forms, such as IRAC (or CREAC). Read his article closely. You will likely see more CRARC-style writing in advocacy than CREAC (for analysis). So it is important to learn both.

Below are two examples of motions. Read them closely and compare them to what you know about CREAC, to the advice in Wayne Schiess' article above and the CRARC paradigm in Wayne Lebovits' article above. What do you notice?

What are your questions?

Example #1 of Motion

Context: This motion was filed by attorneys representing Meta (formerly Facebook), another company, and Mark Zuckerberg in a case before the Federal Trade Commission. According to the FTC's website, the FTC "authorized an administrative complaint against the proposed merger between virtual reality (VR) giant Meta and Within Unlimited, the VR studio that markets Supernatural, a leading VR fitness app. [. . . ] Meta sells the most widely used VR headset, operates a widely used VR app store, and already owns many popular VR apps. The agency alleges that Meta’s proposed acquisition of Within would harm competition and dampen innovation in the U.S. markets for fitness and dedicated-fitness VR apps." This motion seeks to exclude the expert testimony of one of the FTC's expert witnesses.

Example #2 of Motion

Context:

This is another FTC case, this time against Intuit, Inc. which makes the popular tax software TurboTax. The FTC claims that Intuit misleadingly advertised "free" tax filing software as widely available, but that around two-thirds of tax filers were not eligible for the free option. This motion seeks to disqualify the chair of the panel of administrative law judges assigned to the case for allegedly being biased against Intuit.

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ssrn_id1653991_code708198 (1).pdf
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Schiess, Wayne, Writing to the Trial Judge – For Motions (2009). Scribes Journal of Legal Writing, Vol. 12, p. 131, 2009, Available at SSRN: https://ssrn.com/abstract=1653991
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ssrn-1650923.pdf
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Lebovits, Gerald, Cracking the Code to Writing Legal Arguments: From IRAC to CRARC to Combinations in Between (July 1, 2010). New York State Bar Association Journal, Vol. 82, No. 6, July/August 2010, Available at SSRN: https://ssrn.com/abstract=1650923
Motion in Limine by Meta, et. al.
Motion to Diqualify by Intuit, Inc.