Briefs often recite procedural histories from soup to nuts, setting forth precise dates when the complaint and answer were filed, when motions and cross-motions were made and argued and so forth. Procedural histories can go into excruciatingly boring detail.

Much of what is typically included in a procedural history can be referenced in passing or omitted altogether because it is implicit. Either the reader can deduce the information without your articulating it, or the reader doesn’t need the information.

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