Translate

Sunday, January 6, 2013

APPEAL: MY REPLY BRIEF'S MENTION OF HIS COUNTERSTATEMENT

Excerpted from my Reply Brief, this was my very brief statement in regards to his Counterstatement to my Statement of the Facts and Case.  I couldn't actually find anything in the Florida Rules of Appellate Procedure that allowed for a section in a Reply Brief to counter the Counterstatement.  But I wanted to address it some way.  I saw similar statements in some of the books I studied and decided to keep this very very brief and to the point, while barely touching upon the personal attacks.  Participating in attacks is in bad form and judges do not like that.

ARGUMENT

Husband’s Brief is permeated with factual misrepresentations, discrepancies and invective towards Wife, designed to disparage her. As such, Husband’s counterstatement fails to comply with the requirements for an accurate, unbiased and supported recitation of the case. Therefore, Wife respectfully requests that this Court rely upon her Statement solely, as it is not only accurate, but appropriately annotated consistent with the record.

No comments:

Post a Comment