Actually, they are not that secret since it is self-evident and nothing more than common sense, but the two basic rules for preparing an appeal brief do bear repeating from time to time. To win an appeal, your brief needs to: make the judges want to rule for your client rather than the opposing party; and give the judges a reasonable, justifiable basis for the court to do so. These two rules are based on the real-world fact that appellate judges, although constrained to some degree by precedent, generally have enough wiggle room in the law and facts to decide an appeal whatever way they want. In other words, judges are seldom going to make a ruling that they have to “hold their nose”…