Best Briefing Tips of 2022

Timothy Kowal, Esq.
June 8, 2023

After interviewing dozens of guests on the California Appellate Law Podcast, Jeff Lewis and I recapped some of the best briefing tips from 2022. In this clip we cover:

  • 😱Judges’ three key fears when deciding cases (via Ross Guberman)
  • 🗡️Kill your darlings—find the cleverest line in your brief, and delete it (via Ross Guberman)
  • 🏔️Litigation is an expedition—you have to bring the judge along the journey with you. You can’t magically teleport your reader to the destination by way of adverbs. (Via Justice Lambden)
  • 📜It’s the best argument that wins—not the best citation. (Via Justice Lambden)

Watch the clip here.

This is a clip from episode 67 of the California Appellate Law Podcast. Listen to the full episode here.

Tim Kowal helps trial attorneys and clients win their cases and avoid error on appeal. He co-hosts the Cal. Appellate Law Podcast at, and publishes a newsletter of appellate tips for trial attorneys at His appellate practice covers all of California's appellate districts and throughout the Ninth Circuit, with appellate attorneys in offices in Orange County and Monterey County. Contact Tim at or (714) 641-1232.