Who among us has not, from time to time, strung a random collection of facts and citations together and just filed the sucker?
Well apparently this is now frowned upon, at least in certain epic toe-tapping broken yacht cases:
2. Facts shall not be rambling narratives, but shall refer specifically to pages/lines of testimony and/or pages or paragraphs or lines of admitted exhibits.This is a fantastic practice tip -- I only wish someone had clued me into this a few decades ago.
For example, here is a sampling of my last findings of fact that I submitted recently in a federal case:
By the waters of Leman I sat down and wept ... Sweet Thames, run softly till I end my song, Sweet Thames, run softly, for I speak not loud or long. But at my back in a cold blast I hear The rattle of the bones, and chuckle spread from ear to ear. A rat crept softly through the vegetation Dragging its slimy belly on the bank While I was fishing in the dull canal On a winter evening round behind the gashouse Musing upon the king my brother's wreck And on the king my father's death before him. 192 White bodies naked on the low damp ground And bones cast in a little low dry garret, Rattled by the rat's foot only, year to year. But at my back from time to time I hear 196 The sound of horns and motors, which shall bring 197 Sweeney to Mrs. Porter in the spring. O the moon shone bright on Mrs. Porter 199 And on her daughter They wash their feet in soda water
(These findings were actually upheld on appeal.)
Don't even ask me about my conclusions of law!