Good writing has a lot in common with pleasing music. That’s so for appellate briefs as much as novels. Good narration and argument stays with the reader, and makes the reader want more, just like a toe-tapping melody.
Bret Rappaport says your mind’s ear hears what you read. How do you use that thesis in your appellate briefs? Take a look at Rappaport’s article, “Using the Elements of Rhythm, Flow, and Tone to Create a More Effective and Persuasive Acoustic Experience in Legal Writing,” (Journal of Legal Writing Institute, Vol. 16, p. 65, 2010. Thanks to the (new) legal writer for the reference.