Effective statement of the facts; why necessary.

• Jurisdiction: United States

Section 23. Effective statement of the facts; why necessary.—In many respects, the Statement of Facts is the most important part of the brief; hence the priority given it in the present discussion. The circumstances that numerous other matters may be required by rule of court to precede the Statement of Facts in the printed brief does not in any sense warrant postponing its consideration.

The greatest mistake any lawyer can make, after he has written a fine brief on the law, is to toss in a dry statement of facts and send the thing off to the printer. When I first came to the bar (now more years ago than I like to recall), my chief—Eugene A. Kingman, Esq., of the Rhode Island Bar—used to insist that that...