Writing appellate briefs isn’t easy because you have to encapsulate your entire case within a relatively small number of pages and have to do so for someone who knows nothing about it before he or she starts reading the brief.  Moreover, it has to be well written enough to keep the reader turning the pages instead of putting the brief down in favor of the opposing party’s brief. The problem for many lawyers who don’t handle appeals very often is that they use the same style and use the same techniques in writing an appellate brief as they do in writing trial court briefs. Another possibility is that they think that because their brief is now being filed with a higher court, they have…