Due to court closures, some courts may proceed in a remote format. You may see more Skype-conducted or telephonic hearings. Imagine that after a lengthy telephonic hearing, the judge in your case speaks the words that confirm your victory, “Counsel, would you please draft the order of the court?” You think to yourself that this would be a good opportunity to do a literary victory lap over your vanquished opposing counsel. However, I would caution you that this opportunity is fraught with perils. This article is a quick guide to some of the better practices used when drafting the proposed order when requested by a judge.

Take Copious Notes About the Facts of Your Case. Taking notes while argument happens and while the judge lays out her reasoning for reaching a conclusion will save you time as you develop the findings in the order. It also will leave out error that can come when relying on memory alone.

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