My experience on the state district court bench taught me that trial judges are a conscientious lot who read the briefs and want to get their rulings right. In light of that, here are three things a lawyer should never write in court papers for fear of turning off the judge and hurting a client’s chances of prevailing at a hearing.

1. Don’t use words like “clearly,” “obviously” and “simply.” Most disputes in litigation are not clear, obvious or simple. By the time a judge is reading briefs to prepare for a hearing, a few things need to have happened. Two parties (or more) could not solve a problem, and at least one of them has hired a lawyer and filed suit. Yet, based on the fact that there is going to be a hearing, those lawyers have proved incapable of moving the case forward without seeking help from the court.

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