The senior writer of this essay, while an associate justice of the Appellate Division, First Department, had one overriding habit when it came to reply briefs:  he always read them first and worked backward.  More than a few judges have the same habit.

We believe that the reply brief is an important document that should be prepared carefully and thoughtfully by appellate counsel and certainly not treated as an afterthought.  The initial brief and the reply brief are unquestionably the most important part of your appeal – certainly more important than oral argument.

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