I have written previously in this blog about using the concept of storytelling in an appeal brief. I wrote an entire 4-part series on the subject earlier this year, and the first post in that series is found here. Suffice it to say that from my five years as a staff attorney working for several justices at the Alabama Supreme Court and subsequently from my nearly fifteen years as a practicing appellate attorney, I believe that while no appeal can be won without a sound legal argument, the most important part of a brief in almost any appeal is the Statement of Facts and how the facts are presented to the reader. In most instances, you can either present the facts of your client’s…