Q. How do I prepare a trial brief or trial memorandum?
"A trial brief is not a sketch of the case but a complete and comprehensive narrative of the pleadings, the admissions and denials, the issues of fact, issues of law, your expected proof in logical order, and your theory of the law of the case with citations of the authorities and short expositions of the applicable cases. Legal propositions should be stated in a simple, positive, and direct manner, and citations of authority used in support of the propositions should be few and on point. The trial memorandum is meant to convince the court that the picture of the case painted in it is the true and correct one, and this image is seriously damaged, if not destroyed, when the judge takes the trouble to read a cited authority and finds that it does not support the legal proposition for which it has been cited. " 7B Carmody-Wait 2d § 46:10