“The most important sentence in any article is the first one. If it doesn’t induce the reader to proceed to the next sentence, your article is dead.” Although William Zinsser was referring to writing in general, his statement applies with equal force to legal writing. You don’t want a “dead” motion (unless you represent a funeral home). Here is a typical Introduction in motions:
Defendants John T. Boring (hereinafter, “Boring”), Suzie K. Rote (hereinafter, “Rote”), and Paul J. Muddle (hereinafter, “Muddle”) (collectively referred to herein as the “Individual Defendants”), by and through their undersigned counsel, Long, Winded, and Writing, PLLP, collectively and jointly bring this motion to dismiss the First Amended and Consolidated Complaint (hereinafter, “Complaint”) of the Plaintiffs ABC Corporation, Inc. (hereinafter, “ABC”), MNO Corporation, Inc. (hereinafter, “MNO”), and XYZ Corporation, Inc. (hereinafter, “XYZ”) (collectively herein as ”Plaintiffs Corporations”) under Federal Rules of Civil Procedure 12(b)(6) and 9(b) . . . .
If your Introductions are anything like the one above, you should read the article, Striking Introductions Make Memorable Legal Writing. In that article on the Lawyerist, Matthew Salzwedel explains how to write the beginning, middle, and end of an Introduction.