Persuasion: start with a punch

I like a persuasive document (motion or brief) to use a "start with a punch" technique in the facts, the summary of argument, and the first paragraph under any main point-heading.

Specifically, I like to the see the facts, for example, start with something punchy--attention-getting--and favorable to the author's side. I like to see the first paragraph under a main point-heading start with an assertion about the case that is relevant to the legal argument to follow but phrased in favorable terms using factual detail. Here are some before-and-after openers:

Before
The grounds for establishing owner liability in dog-bite cases are well established in Colorado precedent.

• A dry and lifeless sentence introducing an abstract legal principle. Add a new opening sentence:

After
Robert Wilson knew his dog was vicious, and he should have known it could attack a child like the plaintiff, Samantha Garcia. The bases for establishing owner liability in dog-bite cases are well established in Colorado precedent.

Before
The Missouri Human Rights Act provides broad protection for those who allege or oppose discrimination.

• Lacks a human element. Rephrase to include the people:

After
The Missouri Human Rights Act protects one who opposes discrimination, such as Lee Convy, who was fired in retaliation after his wife reported sexual harassment.
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