OFFICE MEMORANDUM September 12, 2005
TO: All foreign and domestic summer interns
FROM: Director of Litigation
RE: Persuasive Briefs
All persuasive briefs, including Briefs in Support of Motions (also called Memoranda
of Points and Authorities), shall conform to the following guidelines.
All briefs shall include a Statement of Facts. The aim of the Statement of Facts is to
persuade the tribunal that the facts support our client’s position. The facts must be
stated accurately, although emphasis is not improper. Select carefully the facts that
are pertinent to the legal arguments. In the case of a motion for summary
judgment, our arguments must be based on undisputed facts.
This firm follows the practice of breaking the argument into its major components
and writing carefully crafted subject headings that illustrate the arguments they cover.
Avoid writing briefs that contain only a single broad argument heading. The
argument heading should succinctly summarize the reasons the tribunal should take
the position you are advocating. A heading should be a specific application of a rule
of law to the facts of the case and not a bare legal or factual conclusion or a
statement of an abstract principle. For example, improper: THE UNDERLYING FACTS
ESTABLISH PLAINTIFF’S CLAIM OF RIGHT. Proper: BY PLACING A CHAIN ACROSS THE
DRIVEWAY, BY REFUSING ACCESS TO OTHERS, AND BY POSTING A “NO TRASPASSING”
SIGN, PLAINTIFF HAS ESTABLISHED A CLAIM OF RIGHT.
The body of each argument should analyze applicable legal authority and
persuasively argue how the facts and law support our client’s position. Authority
supportive of our client’s position should be emphasized, but contrary authority also
should generally be cited, addressed in the argument, and explained or distinguished.
Do not reserve arguments for reply or supplemental briefs.
You need not prepare a table of contents, a table of cases, a summary of argument,
or the index. These will be prepared, where required, after the draft is approved.
MR. FREEMAN COHEN
(a.k.a. GAO FUMAN)
151 CONDUIT ROAD●SECOND FLOOR●JERSEY CITY, NEW JERSEY 07001, U.S.A.●917-567-4680●FREEMANCOHEN@AOL.COM
March 15, 2004
Mr. Wang Chiwen
Hiring Partner
Wang, Zhang & Lee, L.L.P.
666 Chang’an Boulevard
Beijing 100001
The People’s Republic of China
Re: Summer Internship
Dear Mr. Wang:
I should be obliged if you could consider me for a summer internship position in your
firm. As a first-year law student from the Columbia University Law School in
America, taking a profound interest in Chinese culture and law, I hope my enthusiasm
and English language skills can be put to work for your prestigious law firm during the
coming summer and possibly beyond.
Having studied as an exchange student in Beijing University of Foreign Studies for one
academic year, I am fairly fluent in Mandarin Chinese and can team up with Chinese
colleagues with ease. Back in the United States, I continue to advance my linguistic
skills in a local Chinese language school.
Before entering Columbia Law School, I volunteered for a long-term pro bono
program administered by Kings County Bar Association in New York, helping the
impoverished apply for state-subsidized housing. My initiative and ability to endure
strenuous working hours have gained high appraisal from my supervising attorney.
After entering the Law School, I also have performed quite well, being currently
ranked third in my class. I anticipate maintaining this momentum for the remaining
semesters.
Enclosed please find my resume, references, and law school transcript. I look
forward to having the opportunity to answer any questions you may have regarding
my application. I am free for telephone interviews at any time, provided you can
give me at least two days’ notice by email.
Yours sincerely,
Freeman Cohen.
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