A good way to teach (and to learn) good writing is by demonstration. So, in an attempt to demonstrate how to improve the first two paragraphs of a motion, I’m just going to show you what the two paragraphs looked like before and after the revision.
COMES NOW, Joe Strummer, by and through his attorneys of record, Penny Rimbaud and Poly Styrene, and respectfully moves this Honorable Court to reconsider its December 21, 2016 order detaining Strummer pending trial. Due to changed circumstances discussed below, it is not only appropriate to consider the imposition of additional conditions of release that will serve to reasonable assure Strummer’s appearance at trial, but is also essential that Strummer be released from custody subject to strict conditions of release in order that he be able to meaningfully participate in his defense and receive effective assistance of counsel.
PROCEDURAL HISTORY OF DETENTION PROCEEDINGS
On December 21, 2016, United States Magistrate Judge John Lydon conducted a detention hearing at the government’s request and, after hearing testimony and considering exhibits proffered by both sides, determined that Strummer should be detained pending trial. Transcript of Detention Hearing, p. 90–1 (“While it pains me to do this, I must detain Mr. Strummer for the period pending trial.”).
On December 21, 2016, the Court held a detention hearing and reluctantly ordered the detention of Defendant Joe Strummer pending trial. See Tr. 90–91 (“While it pains me to do this, I must detain Mr. Strummer for the period pending trial.”). Strummer now moves the Court to reconsider that ruling because (1) Strummer does not pose an actual flight risk and, even if he did, (2) there are other ways to assure his appearance at trial, short of detention, that should have been considered.
Factual & Procedural Background
Strummer is the son of a Holocaust survivor who evaded capture by the Nazis, left Europe, and started over with nothing in South Africa. Strummer grew up and became a doctor, and immigrated to the U.S. in the 1980s to escape apartheid. Now 70 years old and in declining health, Strummer suffers from esophageal stricture and a heart condition, both of which require regular medical attention.
I think the second version is better, but it’s important (as a writer) to think about why the second version is better. Note: all the juicy details in the second version were in the first version of the motion—they just weren’t in the first two paragraphs. I’ll let the other revisions speak for themselves.
To use this demonstration as a tool for improving your own writing, study every change from version one to version two—sentence by sentence, even word by word. And think about not only what was changed, but also why it was changed, how it was changed—and why it was changed the way it was changed. These decisions (what to change, and why and how to change it) are the decisions good writers make all the time. So to become better writers we need to figure out how to make these decisions.