The title of a Action Motions 2K10  should catch the attention of the reader and immediately begin to play a part in the basis system of advocacy being used. It should sell some aspect of the case. It is archaic to entitle every motion "Motion to . . ." . Get with it! Catch the reader’s eye; pique interest in the motion.
  Primacy is important. The headline comes first. Don't waste words in the important areas, the beginning and the end. Primacy and Recency -- people best remember the first and last things they hear and read.
 Headlines sell -- they must.
  A headline is not limited to the title of the motion. It is important that each section of the motion begin with a new headline. The headlines for the beginning section of each can also be effective lead sentences.
  When the motion is complete a scan reader should be able to read only the titles of each section and have a good understanding of the motion. Each section headline should invite the reader to read the motion line for line. If the people working at the filing desk do not read your motions, most likely you should employ more forceful, direct language and consider changing the content of the motions. When your Action Motions Plus 2K10 are filed, they should cause a whisper storm in the courthouse.

Examples of the Headline or Title

AMENDED AND CONSOLIDATED MOTION SEEKING RELIEF CAUSED BY THE DECEPTION, INCOMPETENCE, CORRUPTION, CONCEALMENT OF FRAUD AND OTHER MISDEEDS BY THE STATE OF TEXAS

GASP, GASP, GASP, THE DISTRICT ATTORNEY RANDY SHERROD IS REACHING FOR THE LAST SAND BAG TO DELAY THE FLOOD OF INFORMATION ABOUT DR. ERDMANN'S WRONGDOING AND THE COVER-UP OF THESE WRONG-DOINGS BY SOME DISTRICT ATTORNEYS INCLUDING RANDALL SHERROD HIMSELF - a/k/a, The lesson politicians did not learn from the Nixon-Watergate era

RANDALL SHERROD'S LEGAL AND MORAL MISCONDUCT HAS BROKEN JUDGE PATRICK A. PIRTLE'S  SWORD AND SCALES OF JUSTICE -- HELP IS REQUESTED