the argument section of the trial brief is the most important section. this is where you analyze the law that supports your client’s position and describe why and how the law supports the position of your client.

during part 1 of the argument section, you will focus on primary custody of the children, parental responsibility, timesharing with the children, and child support.

when presenting the cases and statutes to make your argument, make sure the favorable cases and statutes stand out and discuss how they apply to your client’s case. you should also include the unfavorable cases and statutes showing why they are different and how they should not apply to your client’s case.

do not just summarize your cases and statutes. using the irac approach, analyze and apply them to your client’s case so the judge will see how the cases should be used to rule in your client’s favor.