- Unknown re: whether NY Court of Appeals will permit electronic filing
- Per Judge Jones--inescapable fact of life that entire legal community moving towards electronic filing, technological advancements--but how quickly we'll get there is unknown
- Per John Speranza--make a story out of your briefs--use creativity--make it interesting
- Judge Pigott referenced a case out of Oneida County-People v. Pepe as an example of a great prosecution brief that told a great story
- Per Judge Jones-avoid sequential date story telling--tell a story in the Statement of Facts and try to phrase it in away that more closely reflects the main issues in the case
- Per John Speranza-flamboyant language/descriptions can liven up a brief
- Question re: depraved indifference standards/decisions. Per Judge Pigott, hard to predict where it's going. Difficult and evolving area of law-new cases with new factual scenarios come down and are increasingly difficult interpret. Per Judge Jones-part of the problem with the analysis is the inability to determine whether "depraved indifference" describes a mens rea or a set of circumstances.
- How to make leave applications compelling. Put main issue up front and be concise and persuasive per Judge Jones. Don't clutter up strongest argument. PerJudge Pigot-use a rifle not a shotgun and request phone conference in letter accompanying leave application if feel like it would help.
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