Stay Awake
“ You ought never to edit except when awake.”
- Mark Twain in a letter to his editor (1900)
You can write a longer brief if you are disorganized. Don’t prioritize your issues. Don’t distinguish your most important arguments. By all means, do NOT trim the fat from your paragraphs. Ignore the order of things. If you skip outlining, you can simply look at your notes and let your feelings guide you. Let the editing take care of itself. If longer is better, then organization is enemy number one. With a modicum of somnambulance, you can turn an eighty-page brief into a hundred-and-thirty-page brief no problem. After all, what judge doesn’t want more to read?
I would have made this sarcastic plea longer, but my paralegal is too organized.