Any seasoned brief writer will tell you how important it is that your brief has a “theme.” What is meant is that it’s important that the brief tell a story, whatever it may be, that helps present the client’s position in a way that will create the best chance for success in the appeal.  That theme should be able to be stated in one sentence (X should win because …. ) and the theme should be pushed forward in every section of a brief. That concept is not difficult and most lawyers writing an appeal brief are able to follow that strategy to some extent. But what can you do to make your brief a little different and memorable, to reinforce that theme. Try…