The title of
a Action Motions 2K10 should catch the attention of the reader
and immediately begin to play a part in the basis system of advocacy
being used. It should sell some aspect of the case. It is archaic to
entitle every motion "Motion to . . ." . Get with it!
readerís eye; pique interest in the motion.
is important. The headline comes first. Don't waste words in the
important areas, the beginning and the end. Primacy and Recency
-- people best remember the first and last things they hear and read.
sell -- they must.
is not limited to the title of the motion. It is important that each
section of the motion begin with a new headline. The headlines for the
beginning section of each can also be effective lead sentences.
motion is complete a scan reader should be able to read only the titles
of each section and have a good understanding of the motion. Each
section headline should invite the reader to read the motion line for
line. If the people working at the filing desk do not read your motions,
most likely you should employ more forceful, direct language and
consider changing the content of the motions. When your Action Motions
Plus 2K10 are filed, they should cause a whisper storm in the courthouse.
of the Headline or Title
AND CONSOLIDATED MOTION SEEKING RELIEF CAUSED BY THE DECEPTION,
INCOMPETENCE, CORRUPTION, CONCEALMENT OF FRAUD AND OTHER
MISDEEDS BY THE STATE OF TEXAS
GASP, GASP, THE DISTRICT ATTORNEY RANDY SHERROD IS REACHING FOR
THE LAST SAND BAG TO DELAY THE FLOOD OF INFORMATION ABOUT DR.
ERDMANN'S WRONGDOING AND THE COVER-UP OF THESE WRONG-DOINGS BY
SOME DISTRICT ATTORNEYS INCLUDING RANDALL SHERROD HIMSELF -
a/k/a, The lesson politicians did not learn from the
SHERROD'S LEGAL AND MORAL MISCONDUCT HAS BROKEN JUDGE PATRICK A.
PIRTLE'S SWORD AND SCALES OF JUSTICE -- HELP IS REQUESTED