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9.2.5 SUMMING UP

When writing your fact statement, you should (1) decide what conclusions you want the reader to draw after reading the facts and note which presumptions the reader might bring to the fact statement; (2) collect the facts, noting which facts are positive, negative, and neutral vis-à-vis the conclusions you want the reader to draw; (3) organize the facts; (4) make the facts persuasive by exploiting positions of emphasis, context, level of detail, and specificity; (5) take care not to violate ethical or logical rules; and (6) make sure that you cite to the record as needed.

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Source: Beazley Mary Beth. A Practical Guide to Appellate Advocacy. Fifth Edition. — Wolters Kluwer Law,2018. — 475 p.. 2018
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