The Strong Close #10
Definition
Writing technique · Tier Informal
Ending the memorandum on its single most resonant point rather than on boilerplate or a relief recitation. The Anchor Paragraph (#6) gives the judge the best version of the case first; the Strong Close gives them the last thing they read before deciding. The two impressions bracket everything in between.
Example
A memorandum closes not with "the motion should be granted in all respects," but with the case's sharpest fact stated bare: "Movant served its demand eight months ago. Respondent has produced nothing. The discovery deadline is in three weeks."
Anti-pattern
"For all the foregoing reasons, and in the interests of justice, Plaintiff respectfully requests that this Court grant the within motion in its entirety, together with such other and further relief as the Court deems just and proper."
Requirements
- The closing sentence or paragraph is substantive, not a procedural "wherefore" clause
- It restates the theory of the case at full strength, in its most concrete form
- It introduces no new argument — it lands the one already made
- The relief recitation, if any, follows the close rather than ending the document
Why it's informal
Law school teaches the conclusion as a summary ("For the foregoing reasons, the motion should be granted"). Practice teaches that the last sentence is the one the judge carries into the decision. Argument order is bracketed by primacy and recency: the strongest material belongs first and last, the weakest in the middle.
How it differs
- Relationship to the Anchor Paragraph (#6)
Anchor and Close are the same discipline applied to the two positions the reader weights most. Deploy them together: the strongest fact opens, the theory closes.