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When personal computers were new, they came with little plastic templates that fit over the function keys to label the various purposes of the keys and to help users find the correct one.

In a brief, you can provide a symbolic template by using headings, roadmap paragraphs, and topic sentences, and by using effective connection-conclusions within each CREAC unit of discourse.

A template of this kind helps in three ways. First, creating the template forces you to break your argument into smaller parts, and this lightens the reader’s burden. Second, judges and clerks can use the template to skip the parts of the document they don’t need and to find the parts they do need. Likewise, those who are reading the brief digitally will use headings and other signals both as finding tools and for information. Finally, readers will look for connections in the template items so that they can understand how each section of the document relates to the other sections or to your overall thesis, thus increasing their understanding of your arguments.

The template can be created in a four-step process. First, identify or write topic sentences for every paragraph. Second, identify your large-scale organization and insert headings that reveal that large-scale organization. Third, use the headings to create as many roadmap paragraphs as are appropriate. Finally, insert connection-conclusions at the end of each unit of discourse.

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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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