Drafting the Summary of Argument, by Louis J. Sirico, Jr., Legal Skills Prof Blog
Although not all courts require a “Summary of the Argument” in major briefs, you might consider adding one nonetheless. It is the heart of your brief. It concisely sums up your argument – no fluff allowed.
Some busy judges will read your Table of Contents, Table of Authorities, the Summary of the Argument, and nothing else. It is why the Summary of the Argument is at the beginning of a brief, and why it should to get right to the point and stay there.
This is a particularly interesting article on writing by Judith Fischer, and well worth your time regardless of your brief writing skills. -CCE
[B]ecause the summary of the argument appears near the beginning of a brief, it allows the legal advocate to take advantage of both framing and priming to begin to convince the Court. Thus, it’s a mistake for an advocate to treat the section as an afterthought. . . .