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

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.

In-class writing exercises will let you try out the skills you learn and get immediate feedback.


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

12:00pm – 1:00pm 

  • 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

Dates and Times and Locations

November 3, 2017

Time: 9:00 a.m. – 4:30 p.m. (includes networking lunch)

Courtyard Fort Lauderdale Airport & Cruise Port Hotel
400 Gulf Stream Way
Dania Beach, FL 33004

(Be sure to arrive at least ten minutes before start time if you want to make sure you have a good seat)


Here are a few testimonials about speakers at this program who have taught Pincus seminars in the past.

Testimonials for Jim Robinson, who taught at our 2017 Mastering the Deposition seminar:

“Wonderful speaker.” – Ivonne Duran, Esq.
“Good presentation.” – Richard W. Lauariere, Esq.
“Excellent presenter in keeping it lively. Good role-play.” – Kevin Hellmann, Esq.

Testimonials for Jim Allen, who taught at our 2017 Mastering the Deposition seminar:

“Great.” – Kyle R. Jackson, Esq.
“Very knowledgeable.” – Kevin Hellmann, Esq.
“Very thorough and helpful. Great tips.”

Testimonials for Barbara Junge, who taught at our 2012 Federal Court Boot Camp:

“Really helpful to have a seasoned federal law clerk on the panel – she had a different perspective than the rest of the panel.” – LeeAnne LeBlanc, Esq.
“Great job.” – Elizabeth Goueti, Esq.
“Pleasant. Knowledgeable.” – Stephen B. Grundstein, Esq.


Here are a few testimonials from our 2014 Persuasive Appellate Brief Writing program in California:

“The BEST writing CLE I have ever attended! The appellate ‘insider knowledge’ made this CLE extremely valuable.” – Marlyn Hawkins, Esq.

“Awesome! The first CLE I have been to where all the info was helpful and the presenters held my attention throughout.” – Inge Fordham, Esq.

“This was the best legal seminar I have attended. The material was topical, well-presented and entertaining.” – Guy Stilson, Esq.

“The particular combination of speakers was excellent to make a broad topic relevant to any practitioners. The depth of knowledge was amazing. Normally, I would have to go to 2-3 CLEs to get the variety of insight and compare information from various jurisdictions.” – Marlyn Hawkins, Esq.

“I have not filed/written an appeal for 15 years. I wanted the nuts & bolts. [Speakers] provided this in an interesting and informative manner.” – Chris Schaefer, Esq.

“Excellent program with comprehensive course material. I found this very helpful and was impressed with the high quality of this seminar. The faculty was extremely knowledgable. This course exceeded my expectations.” – Alice Peiler, Esq.

“Excellent job by both lecturers. Enjoyed the presentation very much. No wasted time.” – Maureen Pacheco, Esq.

“Not only did I learn tips crucial for appellate brief writing, I learned tips that are crucial to trial brief writing!” – Jully Pae, Esq.

“This program was really as nearly perfect as any I’ve ever attended.” – Tyna Orren, Esq.

“Our firm has experienced a recent rise in appeals – the subject matter is helpful and informative.” – Inge Fordham, Esq.



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.
Of Counsel
Damian & Valori LLP

Barbara A. Junge practices complex commercial litigation, in federal and state courts, with the Damian & Valori law firm. She also represents employees in negotiation of employment agreements, and has litigated fraud-related issues in probate court.

As an Assistant United States Attorney, Ms. Junge represented the National Park Service and other federal agencies in real estate transactions and employment litigation. She also has litigated as a legal services attorney and as a partner in a small law firm where she managed national class actions against four hospital corporations. And for sixteen years Ms. Junge served as law clerk for the Honorable William M. Hoeveler, Senior United States District Judge.

Throughout her legal career Ms. Junge has assisted in the training of new lawyers, including coordinating seminars for incoming federal judicial law clerks and serving as a faculty member for The Florida Bar’s legal education seminars on federal practice.

Ms. Junge has served as Chair of the Federal Court Practice Committee and of a Grievance Committee for The Florida Bar, and as a member of the Judicial Nominating Procedures Committee, the Judicial Evaluation Committee, and the Standing Committee on Professionalism. 

Ms. Junge was selected as a member of the Miami Foundation’s Miami Fellows Initiative from 2001-2003. She also has served on the Board of Directors of the Miami Coalition for the Homeless, the Florida Coalition for the Homeless, Touching Miami With Love, and Haitian Women of Miami. In addition, Ms. Junge is Trustee for Bay Shore Lutheran Church.

After graduating from New College in Sarasota, Florida, Ms. Junge served as a Peace Corps Volunteer in Togo, West Africa from 1985-1987, teaching high school math and developing one of the first young women’s small business skills development projects of the Peace Corps worldwide.  She was also a Rotary Foundation International Graduate Scholar at the University of Zimbabwe in 1990, and she worked on judicial education projects in the South Pacific for the Asia Foundation in 1992. She has served as President of the Returned Peace Corps Volunteers of South Florida, and was elected as a regional representative to serve on the Board of Directors for the National Peace Corps Association. 

Ms. Junge received her law degree from New York University and her Master’s Degree in Public and International Affairs from Princeton University. 

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.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 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.






Registration fees are per person:

Individual: $425

Group: $399 per person for 2 or more from the same company pre-registering at the same time

Government employee/Non-Profit* Rate: $375

Law Students/paralegals*: $235 (current JD students only)


Program materials:

We’ve gone green.  Registration fees include an electronic copy of your handbook emailed one week in advance of the program.  Be sure to check your spam folder if you don’t see it by then.

If you prefer, you may order a hard copy of the handout to be provided the day of the program for $25. To do so, please be sure to check the box when you register. If you want a hard copy, you must order it when you register; there will not be any available for purchase the day of the program.

** Legal Aid/Non-Profit attorneys are those attorneys employed by Legal Aid/Non-Profit firms. It does not include attorneys who have their own practice, or are employed by law firms, that volunteer their time for non-profit causes or take on pro-bono cases. Full and partial scholarships may be available to a limited number of non-profit/Legal Aid attorneys, based upon registration. Please call (877) 858-3848 to discuss or email your request to info@pincusproed.com.


CLE Credits

FL General:  This program is approved for 7.0 hours of general CLE credit in Florida.

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

NJ General: The LIVE session of this course is approved, under New Jersey’s CLE Approved Jurisdiction policy, for 6.0 CLE units. Pincus Professional Education is a CA Accredited Provider, which is a NJ approved jurisdiction. See the New Jersey State CLE Board Regulations and Guidelines for further information.

NY General: The LIVE session of this course is approved, under New York’s CLE Approved Jurisdiction policy, for 6.0 CLE units. Pincus Professional Education is a CA Accredited Provider, which is a NY approved jurisdiction. See Section 6 of the New York State CLE Board Regulations and Guidelines for further information.

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 & Refund 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.

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.

For policies related to audio products, please select “I want a download or CD” on the right.

$235.00$425.00 each

Because many judges no longer hear oral argument for your motions, written advocacy has never been more important.

This informative and practical seminar will show you how to draft a clear, persuasive motions brief for state or federal court.


Printed Materials

[ All attendees receive a pdf of the materials one week prior to the program. To purchase a printed hard copy, please select this option to order it now. ]

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