Appellate Practice
Sep. 21, 2026
Working, Part 5: Adding meat to the bones with 'AOB 2'
In the latest installment of his brief-writing series, Myron Moskovitz explains how he builds an appellate opening brief by assembling key portions of the record, transcripts and legal research into a comprehensive working document.
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
This series of columns describes how I go about writing briefs. Adopt, modify, or ignore them as you see fit.
In my last column, I explained how I set up an "AOB 1" subfolder to draft the basic structure of the Appellant's Opening Brief: an outline of the issues. I may also develop the brief's theme through the In...
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