Motion briefs in motion
No one wants a bad reputation
What's your issue
Acts, Acts, Acts
Facts, Facts, Facts
100

The first paragraph in the body of your motion brief.

What is your relief requested?

100

The rule that provides character evidence is not admissible for proving action in conformity.

What is Washington ER 404(a)?

100

A "whether", "under-does-when", and this format are all appropriate formats for issue statements.

What is a multi-sentence format?

100

In general, specific acts of violence cannot be used to show this.

What is conformity?  

100

In addition to legally significant facts and background facts, you should also consider using this type of facts in your statement of facts.

What are emotionally significant facts?

200

The section of your motion brief that comes before the arguments.

What is the statement of issues?

200

A type of character trait that ER 404(a)(2) allows evidence of as an exception to the general rule.

What is pertinent?

200

You should frame your issue statement so that it elicits this response from the judge.

What is YES?

200

A rule that allows prior bad acts to come in for the purpose of showing knowledge.

What is ER 404(b)?

200

You should always present your facts in a motion brief in a light that is most favorable to this person.

Who is your client?

300

Something in your brief you should never have just one of.

What are subheadings? 

If you have one, you should have 2.

300

The two foundational requirements for admitting reputation evidence.

What is valid community and remoteness?

300

You should have as many main argument headings in your brief as you have these.

What are issue statements?

300

Something defendant must have in order to find a prior bad act was sufficient to cause fear in or apprehension in his/her/their mind.

What is personal knowledge?

300

Two common types of organizational schemes.

What are chronological and topical?

400

The types of cases you mostly want to rely on in your motion brief.

What are published cases within your jurisdiction?

400

The case that expanded definition of "community" to a business community.

What is State v. Land?

400

You should always put this issue first in your brief.

What is your strongest argument?

400

True or False: Specific act character evidence relating to the victim's alleged propensity for violence is not an essential element of self-defense.

True. State v. Alexander.

400

True or False: You should always start your statement of facts with what occurred on the date of the incident.

False. Sometimes setting the scene with background facts is more favorable to your client.

500

The rules you want to refer to regarding formatting your motion brief in State v. Kramer. 

What are the Kitsap County Local Criminal Rules (KCLCrR)?

500

Two things that a community must be in order to be considered a valid community. 

What is neutral and general?

500

Something your issue statement should not contain.

What are legal conclusions?

500

True or False: To admit evidence of crimes or misconduct under ER 404(b), the trial court must identify by a preponderance of the evidence that the claimed misconduct occurred.

True.

500
You should never assert facts for the first time in this section of your brief.

What is the argument section?

OR issue statement I guess too.