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. Enclosure
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