“What is your game plan?” That’s the first question I asked a lawyer who had requested my help with an important appeal. The lawyer’s first response was a blank stare, then a statement that the plan was to start writing the next day and to have a draft completed by the end of the week. I replied that that wasn’t the answer I was looking for and explained that in my experience writing a great brief takes great planning. One thing that busy trial lawyers who are used to re-using various standard form motions and other pleadings often have trouble accepting is that you can’t just cut-and-paste trial court pleadings into the form of a brief required by the appellate rules and expect to…