Do judges really read what lawyers submit? They do in Travis County. Since this is one of the few counties in Texas that employs staff attorneys for sitting district court judges, lawyers can rest assured that their motions and briefs receive a thorough reading — so thorough that problems will not escape notice.

I am not a legal writing expert, so this article will not cover nuances of language and writing advice. Instead, I’m sharing my top three broad tips for motion practice. They’re based on my own observations after reading hundreds of motions, ranging from complex summary judgment motions that don’t even fit into a large binder to short opposed motions requesting one small order from the court.