Law Practice,
Appellate Practice
Nov. 2, 2020
Word Counts
When I receive an appellant’s opening brief or respondent’s brief from my opponent, I print it out. Then I close my eyes and hold it in my hand, feeling its weight. Then I ask myself: “How many words?” The wheels of my brain turn for a few seconds, and then I proclaim the answer:
Myron Moskovitz
Legal Director
Moskovitz Appellate Team
90 Crocker Ave
Piedmont , CA 94611-3823
Phone: (510) 384-0354
Email: myronmoskovitz@gmail.com
UC Berkeley SOL Boalt Hal
Myron Moskovitz is author of Strategies On Appeal (CEB, 2021; digital: ceb.com; print: https://store.ceb.com/strategies-on-appeal-2) and Winning An Appeal (5th ed., Carolina Academic Press). He is Director of Moskovitz Appellate Team, a group of former appellate judges and appellate research attorneys who handle and consult on appeals and writs. See MoskovitzAppellateTeam.com. The Daily Journal designated Moskovitz Appellate Team as one of California's top boutique law firms. Myron can be contacted at myronmoskovitz@gmail.com or (510) 384-0354. Prior "Moskovitz On Appeal" columns can be found at http://moskovitzappellateteam.com/blog.
When I receive an appellant's opening brief or respondent's brief from my opponent, I print it out. Then I close my eyes and hold it in my hand, feeling its weight. Then I ask myself: "How many words?" The wheels of my brain turn for a few seconds, and then I proclaim the answer: "Around 13,990 words." Then I turn to the last page of the brief, the certificate of word count. Bingo! The number is almost always within four or five words of my g...
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