Persuasive Brief Writing: How to Win Your Motions or Defeat Your Opponents’ (FL)

Audio program! (check our CLE Programs page for live versions)

This course is no longer approved for CLE credit in Florida. It is an excellent program on brief writing and has useful tips and strategies that are still very relevant today. It is now 50% off. 

With many judges no longer hearing oral argument, written advocacy has never been so important.  You are invited to attend Pincus Professional Education’s upcoming seminar on Persuasive Brief Writing, set for November 3rd in Ft. Lauderdale.

This practical, interactive seminar is designed to help attendees improve their brief writing skills. You’ll learn how to draft a clear, persuasive motions brief for state or federal court – from cover page to conclusion.

Faculty includes leaders in private practice and the public sector, and former clerks for state and federal judges who will give you the inside perspective regarding what judges want and need – and what they are likely to ignore – in your briefs.

The program includes writing exercises to let you try out the skills you learn.

The program recording date is November 3, 2017.


Do you want to improve your public speaking skills? Get Faith Pincus’ newly published book Being Heard: Presentation Skills for Attorneys, from the ABA now (ABA members receive 10% off). It is also available on Amazon in Kindle and paperback versions.

What You Will Learn

This agenda is tentative and will likely change a little. Please check back soon for more information.

  • What Makes a Motion or Response Brief Persuasive?
    • Following the Four C’s
    • Targeting Your Audience
    • Having a Reasonable Objective
    • Using Modern Tools
  • Motions to Dismiss
    • Structure of the brief

Exercise 1:  Drafting the Introduction and the Conclusion

  • Motions to Dismiss, continued
    • Citing and Using Authority
    • Responding to Motions to Dismiss

Exercise 2:  Drafting Persuasive Argument Headings and Sub-Headings

  • Motions for Summary Judgment
    • Standards and Burdens of Proof
    • Responding to Motions for Summary Judgment
  • Motions for Summary Judgment, continued
    • Facts: What is a Material Fact?

Exercise 3:  Drafting a Persuasive Statement of Undisputed/Disputed Facts 

  • Other Types of Motions
    • Motions to Compel/for Protective Order
    • Motion to Exclude Expert Testimony
    • Post-Trial Motions

Exercise 4:  Drafting Persuasive Arguments

  • Practical Tips
    • Alternatives to Motions
    • Strategic Considerations
    • Differences Between State and Federal Court Motion Practice
    • Other Writing Resources


“Fully satisfied…Barbara Junge was an excellent speaker and moderator. Her examples were concrete and applicable. The course challenged my way of thinking about legal writing…Jim Robinson brought a practical perspective to the course. He gave real-world examples that I could apply to my practice. Overall, his advice will be invaluable to me going forward in my writing. This was the best CLE I have attended on writing.” – Cecilia Walker, Esq.

“Exceeded my expectations and objectives. Really an excellent seminar/workshop. Very informative. Great speakers…interactive exercises were effective in promoting intended points.” – Colette Kienle, Esq.

“Overall, I enjoyed having stylistic ideas about writing more persuasive and organized [briefs]… Liked the wide range of additional resources that [Jim Allen] pointed to.” – Jerry Donnini, Esq.

“[Joni Coffey offered] great advice.” – Chancey Smith, Esq.

“Panelists provided insights and framework to improve briefs.” – Stuart Mermelstein, Esq.

“Jim Allen was a great presenter and speaker. He offered many examples that I could apply to my legal writing. Ana Romes was an excellent presenter who brought a valuable perspective to the course…Joni Coffey’s accomplished career lent itself to providing a unique perspective on legal writing.” – Cecilia Walker, Esq.

“Liked the examples and law from state and federal court… [Barbara Junge] was great. Very knowledgeable.” – Jennifer Harley, Esq.

“I liked the group work. Good mix of presentation and implementation.”

“[Jim Allen] Nice references to case law and cites…good sample documents [from Jim Robinson].”

“Overall, my personal objectives were satisfied.”

“Contained excellent tips on brief writing.”

“I enjoyed the exercises.”


Ana Romes, Esq.

Foley & Lardner

Ana Romes works in the Litigation Department, Business Litigation & Dispute Resolution Practice Group of Foley & Lardner’s Miami office. Ana recently clerked for the Honorable Robert N. Scola, Jr., of the United States District Court for the Southern District of Florida.  In addition, Ana was a litigation associate at Shutts & Bowen LLP and was a judicial clerk for the Honorable Dorian K. Damoorgian of Florida’s Fourth District Court of Appeal.

Barbara A. Junge, Esq.
Chief Assistant Attorney General, Civil Litigation Division
Florida Office of the Attorney General

Barbara Junge has extensive work experience in the legal field. Barbara is currently serving as the Bureau Chief for South Florida Civil Litigation at the Florida Office of the Attorney General since June 2022. Prior to this role, Barbara worked as an Assistant Attorney General at the same office from March 2020 to May 2022.

Before joining the Florida Office of the Attorney General, Barbara worked as a Judicial Law Clerk at the United States Courts from April 2018 to February 2020. Barbara also briefly worked as Counsel at their own firm, Barbara Junge, PLLC, from January 2018 to April 2018.

Barbara has a strong background in litigation, as they previously worked as Counsel at Damian & Valori, LLP from January 2015 to December 2017. Barbara also gained valuable experience as a Judicial Law Clerk at the United States Courts for a significant period from October 2004 to October 2014.

Earlier in their career, Barbara worked as a Partner at de la O & Marko from January 2003 to August 2004. Barbara also served as an Assistant United States Attorney at the United States Attorneys’ Office from October 2000 to January 2003.

Barbara’s legal career began as a Judicial Law Clerk at the United States Courts from September 1995 to September 2000. Before that, they worked as a Staff Attorney at Gulfcoast Legal Services, Inc. from August 1994 to August 1995.

During their early years, Barbara served as a Volunteer in the Peace Corps from 1985 to 1987.

Barbara Junge has a diverse education history. Barbara first attended New College of Florida from 1981 to 1985, where they obtained a Bachelor of Arts degree with a major in math and natural science. Barbara then pursued a Juris Doctor degree from New York University School of Law, graduating in 1993. During this time, they also earned a Master’s in Public and International Affairs from Princeton University, completing the program in 1993. Additionally, Barbara Junge obtained a certification as a Divemaster from PADI in August 1993.

James N. Robinson II, Esq.
White & Case, LLP

Drawing on his significant experience in state and federal courts handling virtually every type of civil case, Jim’s practice is primarily focused on commercial trial work. He works to limit his clients’ exposure and to protect their interests.

Jim has particular experience of representing regional and national law firms in legal malpractice lawsuits. In such cases he takes a thorough, hands-on approach, managing all aspects of the lawsuits.

Many of Jim’s recent commercial cases include representation of clients connected to the banking industry. Such cases include representation of financial technology (fintech) companies involved with merchant services and credit card processing in both domestic and international disputes. In addition, Jim has represented a series of banks against multimillion-dollar lender liability lawsuits, most of which were resolved with summary judgment in Jim’s clients’ favor. For banking clients, Jim also brings his experience of prosecuting dozens of commercial foreclosure lawsuits on loans totaling over US $ 1.5 billion. Jim represents foreign and domestic corporations in contract disputes, regulatory and compliance matters, and consumer class actions at various stages, including appeals. He has successfully defended numerous director and officer liability actions, and has successfully represented real estate developers and contractors in real estate disputes throughout the United States.

Jim is an active member of a number of professional associations, including the Federal Bar Association, the Trial Lawyers Section of The Florida Bar, the International Law Section of The Florida Bar, the Miami-Dade County Bar Association and the J. Reuben Clark Law Society.

He has taken lead roles in a significant number of professional committees, including as the Chair of the International Litigation and Arbitration Committee (2008), the Chair of the International Litigation and Arbitration Committee Conference (2007), a Steering Committee Member on the International Litigation Update (2005–2006), and as a Chair of the FGCU Alumni Association Board of Directors (2009–2011). He has also served on the Law Alumni Council, University of Florida Levin College of Law.

Joni Armstrong Coffey, Esq.
Broward County Attorney’ s Office

In March 2011, the Board of County Commissioners appointed Joni Armstrong Coffey as the eighth County Attorney since the Broward County Charter went into effect in 1975.

Ms. Coffey joined Broward County after a long career in public-sector practice and leadership in the legal profession. Her practice has included litigation before federal and state courts and administrative agencies, as well as experience in transactional and regulatory matters. She spent many years with the Miami-Dade County Attorney’s Office, most recently as section chief of the Land Use and Environmental practice group. Before that, she was an associate with the private law firm of Steel, Hector and Davis. Immediately after law school, she served as a judicial law clerk to Judge Peter T. Fay of the U.S. Court of Appeals for the (then) Fifth Circuit.

A Florida Bar Board Certified City, County and Local Government Lawyer, Ms. Coffey is a past chair of the Florida Bar’s Board of Legal Specialization and Education, which oversees board certification for the Bar as well as all Continuing Legal Education course approval. She is also a past chair of the Florida Bar City, County and Local Government Law Section, and continues to serve on its executive council. Ms. Coffey has served on the Florida Bar’s grievance committees and CLE Committee, and as Chair of the Legal Affairs Management Committee of the City of Miami Financial Oversight Board and of the Children’s Home Society, Southeastern Florida Division. She has lectured in numerous continuing legal education courses, including courses for the National Judicial College, the Florida Bar, the Florida Municipal Attorney’s Association, and the Florida Planning and Zoning Association.

With an active interest in legal education and professionalism, Ms. Coffey teaches as an adjunct law professor in the areas of land use law, environmental law, administrative law, election law, and Florida constitutional law. She is active in Inns of Court as a means to foster professionalism and legal scholarship.

Awards and Recognitions:

Justice Harry Lee Anstead Board Certified Lawyer of the Year Award, Florida Bar, 2014.

Paul S. Buchman Award (1998) and Ralph A. Marsicano Award (2000) for public service, City, County and Local Government Law Section, Florida Bar

Robert L. Shevin Public Service Award, Dade County Bar Association, 2010

“Top 20 Women in Law in South Florida,” Daily Business Review, 2015

Legal Elite Hall of Fame, Florida Trend Magazine, 2015

AV-rated by the Martindale Hubbell peer-review attorney rating service

Published Articles:

“Private Property Rights Protection Legislation: Statutory Claims for Relief from Government Regulation,” in Florida Environmental and Land Use Law Treatise, Vol. III, Chapter 30.

High Hopes, Hollow Harvest: State Remedies for Partial Regulatory Takings, 39 The Urban Lawyer 619.

Practical Aspects of Quasi-Judicial Hearings: Basic Tools, Recent Fine-Tuning, 30 Stetson Law Review 931.

James Allen, Esq.
Retired Assistant County Attorney, Miami Dade County

Jim was Chief of Training and Development, while continuing to maintain a full caseload in state personal injury and federal civil rights actions.

As a litigator, Jim has practiced extensively in federal and state court at both trial and appellate levels. He has litigated and tried numerous cases involving serious wrongful death and civil rights allegations, including a taking action claiming in excess of 100 million dollars in damages. Jim has also handled numerous state and federal appeals, including a case filed in the U.S. Supreme Court.

After law school, Jim clerked for the Honorable James R. Jorgenson, Florida Third District Court of Appeals.  Jim is a graduate of the University of Wisconsin, J.D., Cum Laude, 1980.


Audio Course and Materials Package – Download or CD: $425 $212.50

CDs: plus $8.50 shipping and, in CA, sales tax.


This program is no longer approved for CLE credit in Florida.

CLE Credit

FL General:  This program is no longer approved for CLE in Florida. CLE expired on March 28, 2019. 

CA General:  This program is approved for 6.0 hours of CLE credit in California.

This program is approved for CLE in the states listed above.  Upon request, Pincus Pro Ed will provide any information an attorney needs to support their application for CLE approval in other states other than what is listed above.


Terms and Policies

Recording policy: No audio or video recording of any program is permitted.

Seminar Cancellations: Should you be unable to attend for any reason, please inform us in writing no later than 14 days prior to the event and a credit voucher will be issued. If you prefer, a refund, less a $50 non-refundable deposit, will be issued. No refunds or credits will be given for cancellations received within 14 days of an event. However, if you notify us within 14 days of an event, and wish to convert your in-person attendance registration to an Audio CD package (with handout), we can do so. A small additional shipping charge, and sales tax in CA, will be incurred. No shipping charge is incurred for downloads. We will also issue a voucher for the amount paid if you notify us within 14 days and prefer not to have the audio recording.

Substitutions may be made at any time.

Webinars, Tele-seminars and Webcast Cancellations: Once log-in codes and passwords are issued for a webinar, tele-seminars or webcasts, a refund is not possible. If for any reason you cannot attend the event after you have received the codes, we will automatically convert your registration to an instant streaming/instant download or CD format and provide you with the information you need to access the recording after the program concludes and the recording is available.  Conversions to CD require a $8.50 shipping fee, and in CA, 9% sales tax.

Downloads/CDs/DVDs – Refund policy:

Downloads are non-returnable/non-refundable once purchased and received. Tapes, CDs and DVDs are returnable for a full refund or replacement if defective, within 90 days of purchase.

Reminder: The room temperature at hotels and other seminar locations are notoriously hard to control. Please bring a sweater or jacket in case it gets cold and/or layer as if you are going to the movies so you are comfortable.

$425.00 $212.50 each

Recorded in 2017.