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Think of the motion as the request by itself. The reasoning for the request (the argument) is a separate document. That is the Brief or, in lieu of the brief, Points and Authorities. Some motions may be governed by specific standards set forth by court rule or statute.
What is a Motion Brief? The Motion Brief is a document that gives you a chance to refer to relevant cases and statutes, provide argument, and highlight relevant facts from your affidavit.
The word brief has two general meanings in legal parlance. As a noun it can be the written argument a lawyer files with a court in support of his or her clients case. As a verb (as used here), briefing the decision means to prepare a short summary of the courts written decision in a case.
A Brief in support of motion is a written explanation of why you, the moving party, should have your motion granted. A Brief takes the rules and laws that support your request and explains how they apply to the facts of your particular situation.
How to Write a Kick-Ass Motion Make an Outline. Keep Your Motion Simple. Maintain Credibility. Mind Your Citations. Focus on Facts. Keep Your Intro Short. Respect the Opposition. Write in English, Not Legalese.
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Original jurisdiction refers to a courts authority to hear and decide a case for the first time before any appellate review occurs.

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