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Lawyers in practice are generally judged by the final product they produce：the written，negotiated text．Clearly，in my firm，the first thing new lawyers will be judged upon is their writing．The fastest way to get ahead as a new lawyer is to be an able writer．The fastest way to fail is to be a poor writer．
——Bryn Vaaler，Compositional Practice：A Comment on“A Liberal Education in Law，”1 J．ALWD 148，149（2002）． ①
Legal writing is a special type of writing done by attorneys，judges，legislators and others in law．The purpose of this writing is to communicate various legal rights，analysis，and legal duties，etc．Unlike regular writing，legal writing is technical and involves continuous dependence on citations，gives importance to precedence and uses special legalese that sounds very formal．There has been a move to reduce such very formal style of writing and to make legal writing simple enough for the layman to understand．However，one must remember that the purpose of legal writing is to make a precise document and informal style may make a legal document's intentions hazy． ②
The use of articles（“a”“an”and“the”or no article）is an area of special significance for multilingual writers，since it is characterized by large variation across languages．In consequence，any error in this area will be very noticeable in an text as a mark of non‐native writing．Given this fact，it is important for multilingual writers to master the use and non‐use of articles and to learn the meaning their use/non‐use conveys in English．
e.g．THE complaint was dismissed．
A new witness changed the course of the trial．
AN accountant was called to testify．
[0]Justice was served．
This section covers the English articles THE，A，AN and their omission．We will also show you a method for deciding which article to use when you are not sure．
Two important concepts are linked to article usage：“countability”and“definiteness．”Understanding these concepts will help you decide whether to use an article or not and on which article to use．
Definiteness Articles in English have two types of reference：DEFINITE（referring to a specific member of a group，e.g．THE）and INDEFINITE（referring to any member of a group，e.g．A，AN）．A“definite”article is used to give specific reference to a noun and to refer to something known to both the writer/speaker and the reader/listener．
e.g．I welcomed THE visitor today．
（Definite reference：both the writer/speaker and the reader/listener know what visitor you are referring to）
vs．
I received A visitor today．
（Indefinite reference：you are not specifying what visitor you are referring to and you are the only one who knows that）
The definite article THE is used when BOTH the writer/speaker and the reader/listener know what is being referred to．If neither of them or only one of them knows what is being referred to，then the indefinite articles A/AN should be used．
（1）Indefinite Articles：A and AN
A and AN refer to any member of a group；you are not referring to any member in particular．
• a ＋singular noun beginning with a consonant： a reaction
• an ＋singular noun beginning with a vowel： an act
• a ＋singular noun beginning with a consonant sound（even though it may start with a vowel letter）： a uniform（same sound as in young or yesterday ）
When an adjective modifies the noun，the use of A or AN is determined by the initial sound of the adjective immediately following the article（and no longer by the noun）：
Unlike other languages，English requires the presence of indefinite articles to indicate membership：
（2）Definite Article：THE
English requires the use of the definite article THE before singular and plural nouns to indicate specific reference，reference to a particular member of a group．
Compare：A dog bit the plaintiff．（any dog；either you do not need to specify which dog you are referring to or you simply don't know）
vs．
The dog bit the plaintiff．（a specific dog；both you and your reader/listener know which dog you are referring to）
In general，the article THE is used：
• with noncountable nouns that are made more specific by using a modifying phrase or clause（underlined below）；
e.g． the defense presented at the trial was especially weak
the image he projects does not favor his case
the concept of diversity applies here
• and when a noun has a specific reference to something unique；
e.g． the 2001 CUNY budget
the Pentagon
the last State of the Union address
• and it is not used with noncountable nouns that refer to something in a general sense；
e.g．[0]Justice is a concept difficult to grasp sometimes．[0]＝No article
The use of THE（Definite Reference）is determined by the following specific instances：
• When something is mentioned for the second time in the text；
e.g．I wrote a letter of complaint[first mention，indefinite]．
Instead，
I wrote a letter of complaint．THE letter had an angry tone[second mention，definite]
• With the superlative（because it signals there is only one possible referent）；
e.g．THE son was THE most articulate witness in the case．
• When only one entity exists；
e.g．THE Moon is a satellite．[There is only one satellite we refer to as“the Moon．”]
• When a phrase modifying the noun provides more information that specifies the reference of the noun；
e.g．THE witness （that）you brought refused to testify．
THE witness from Connecticut refused to testify．
THE witness who refused to testify was arrested in a street incident yesterday．
Note
• I read a book about Criminal Law for the exam．（the phrase about Criminal Law is not specific enough to limit the reference of the noun；it could be ANY book about Criminal Law）
vs．
THE book about Criminal Law that was assigned by the professor was too complicated．（the phrase that was assigned by the professor limits the reference to only ONE entity；it's not ANY book：it's the book assigned by the professor）．
• When both the writer/speaker and the reader/listener know what is being referred to（maybe because they are in the same situation）；
e.g．Open THE window．
I'm going to THE library．
Countable vs．Uncountable Nouns It is important for multilingual writers to recognize crosslinguistic di fferences in this area．A noun considered uncountable in one language may be considered countable in another and，consequently，pluralized，e.g． soap is an uncountable noun in English and cannot be pluralized except by preposing the phrase a bar of to it（ I like to use scented soap vs． I bought two bars of soap but ： I bought two soaps is wrong）．However，in Spanish the same form can be pluralized，e.g． Me gustausarjabón （singular） desodorante vs． Comprédos jabones （plural）．
Countable nouns refer to people，places or things that can be counted（one contract/two contracts，one witness/two witnesses）．A countable noun can always be made plural—usually by adding‐s or‐es or some other plural marker（e.g． trial [ s ]， parti [ es ]， child [ ren ]）．
Some words do not show any variation in form between the singular and plural（e.g． The sheep is in the field / The sheep are in the field ）．
Uncountable nouns often refer to drinks and food，other general substances，or concepts（ meat ， tea ， steel ， information ， justice ）．
Examples of Uncountable Nouns in English：
• Food and Drink ：bacon，beef，beer，bread，butter，cabbage，candy，cauliflower，chicken，chocolate，coffee，corn，cream，fish，fruit，juice，lettuce，meat，milk，oil，pasta，rice，salt，spinach，sugar，tea，water，whiskey，wine，yogurt．
• General Substances ：air，cement，clay，coal，copper，dirt，dust，foam，gasoline，gold，ice，leather，paper，petroleum，plastic，rain，rubber，silver，soap，steel，wood，wool．
• Abstract Nouns ：abandonment，access，adultery，advice，alimony， anger，anguish，arson，authentication，beauty，capacity，conduct，confidence，courage，deprivation，desperation，discretion，employment，empowerment，evidence，extortion，fortune，fun，happiness，health，honesty，housing，information，insurance，intelligence，intent，knowledge，land，love，malice，negligence，poverty，privacy，real estate，sadness，satisfaction，strength，truth，wealth．
• Others ：biology，clothing，darkness，equipment，furniture，gossip，homework，jewelry，luggage，machinery，mail，money，music，news，poetry，pollution，research，scenery，traffic，transportation，violence，weather，weight，work．
Some uncountable nouns（except for concepts）can be turned into countable nouns by preposing a phrase to them（ two bottles of wine ， a bar of soap ， a piece of information ， an act of violence ， a burst of anger ， a piece of evidence ）．
e.g．The defendant's lawyer is sure the judge will accept new evidence in this case．
vs．The defendant's lawyer is sure the judge will accept three new pieces of evidence in this case．
Some uncountable nouns can be used in the plural form but their meaning changes．
experience/experiences：e.g．He had to rely on experience．/I lived unforgettable experiences in this house．
light/lights：e.g．The apartment didn't have much light．/The bus did not stop at the（traffic）lights．
paper/papers：e.g．This office is wasting too much paper．/I submitted all my papers yesterday．
How can I distinguish between using a definite or an indefinite article with a common noun when I am not sure which one is correct ？
I f you are unsure whether to use a definite（THE）or an indefinite article（A，AN）with a common noun，you should ask yourself the following questions：
Remember： If the Noun is definite（whether it is singular，plural or uncountable），it takes THE．
Some Common Errors to Avoid
• Sometimes non‐native speakers of English use“A”or“AN”with plural or uncountable nouns：
• Some multilingual writers use no article at all for a singular noun：
• Sometimes non‐native speakers use two determiners together when they are not supposed to：
• Another common error is to pluralize uncountable nouns：
• Sometimes，multilingual writers use the indefinite articles A/AN with count nouns in some prepositional phrases that are idiomatic expressions such as on vacation，by plane，by car，athome，at school，in school，tobed，inbed，to college，atnight，in court．
e.g．The witness testified that he had seen the defendant take the child to school[and NOT to THE school]himself．
The Use of Articles with Proper Nouns
Proper nouns refer to specific people，places and things（Martin Luther King，New York City，St．Patrick's Cathedral）．However，even though these nouns are inherently definite，the definite article THE is not used with most SINGULAR proper nouns．
e.g．The Susan Brown was considered a troubled woman．（Wrong）
Instead of
Susan Brown was considered a troubled woman．
（This is also a source of errors，since the use of the definite article with proper nouns is allowed in other languages）
In English，you use the article THE with proper nouns
• to emphasize the uniqueness of that entity；
e.g．It's THE Barbra Streisand．
• to specify what singular entity you were referring to；
e.g．THE Elvis I got to know was a defeated king．
• to accompany PLURAL proper nouns，including the plural form of a family name；
e.g．THE Johnsons will go to court today．
The United States
The United Nations
• with proper nouns containing the word OF or a political word like“kingdom”“union”or“republic”or organizational words like“institute”“foundation”or“corporation．”
e.g．The city of New Orleans
The Republic of Korea
the City University of New York
The Fulbright Foundation
the Chase Corporation
The Commonwealth of Virginia
But In phrases that have 2 proper noun names，use THE only if the form contains OF；
e.g．THE School of Law of the City University vs．CUNY Law School
THE University of Oxford vs．Oxford
THE city of New Orleans vs．New Orleans
THE Republic of Korea vs．Korea
• before the names of specific geographic regions of most bodies of water；
e.g．The Mississippi River
The Atlantic Ocean
the Middle East
In English you DO NOT use the definite article THE：
• before nouns in the possessive case（'s）if the noun does not take THE；
e.g．The plaintiff learned of THE Mary Brown's responsibility in the theft by reading the defendant's diary．（Wrong）
Instead of
The plaintiff learned ofMary Brown's responsibility in the theft by reading the defendant's diary．
• before most singular proper nouns，including names of most countries，cities，states，continents，streets，parks and persons；
e.g．The corpse was found in Yosemite National Park．
He was part of an expedition to Argentina，Brazil and Peru．
The Use of Articles with Proper Nouns
In a sentence using active voice，the subject of the sentence performs the action expressed in the verb．In a sentence using passive voice，the subject is acted upon．Here are some examples．
a． active voice ：The police officer arrested the man．
（ The police of ficer is the subject of the sentence and is performing the action of arresting． ）
b． passive voice ：The man was arrested by the police officer．
（ The man is the subject of the sentence but he is not performing the action of arresting． ）
A shortcut to try and identify passive construction in your writing is to look for an extra“be”verb（is，are，was，were）and the word“by．”
a． active voice ：The police officer arrested the man．
b． passive voice ：The man was arrested by the police officer．The man was arrested．
Why should I use the active voice ？
（1）The active voice is more concise．For example，
a．active voice：The dog chased the cat．（five words）
b．passive voice：The cat was chased by the dog．（seven words）
（2）The active voice is often stronger than the passive voice．For example，
a．active voice：Judges must explain the reasons behind their decisions．
b．passive voice：The reasons behind their decisions must be explained by judges．
（3）The passive voice tempts the writer to omit the identity of the actor，thus producing a fuzzy truncated passive．
truncatedpassive ：A copy of every Action Letter shall be sent to the Clerk of the Administrative Office for entry and filing，and a memorandum briefly describing the Action Letter shall be distributed to each Commissioner within three days thereafter．
（ Using passive voice here leaves a lot of questions ： Who is supposed to send the copy to the Clerk ？ Who is supposed to write the memorandum ？ Who is supposed to distribute the memorandum ？ We can't tell ， because the writer used the truncated passive to hide the actor． ）
Tip：In general，use the active voice in your writing．
Is there ever a good reason to use passive voice ？
Yes．Here are the four most common good reasons．
（1）Sometimes you may not want to name the actor because you want to play down the actor's role in the event．（For instance，maybe the actor is your client．） Example ：When the lights went out，several punches were thrown．
（2）Sometimes it's the action that's important，not who does it． Example ：This Act may be cited as the Unlawful Detention Act of 2002．
（3）Sometimes you may not know who did the acting． Example ：During the following six months，the fence wire was cut on nine separate occasions．
（4）Sometimes you need the passive in order to connect this sentence smoothly with the preceding sentence or sentences． Example ：The key question is，therefore，when did the defendant actually receive the summons and complaint？The summons and complaint were not served on the defendant in person until May 18th．
Tip：Be consistent．
Whether you are using active or passive voice，be consistent within a sentence．
a．He tried to act cool when he slipped in the puddle，but he was still laughed at by the other students．（ Uses active voice in the first clause ， passive voice in the second clause ）
b．He tried to act cool when he slipped in the puddle，but the other students still laughed at him．（ Uses active voice in both parts of the sentence． ）
Run‐on sentences are among the most common sentence‐level errors．Although many people think of run‐ons as sentences that are just“too long，”the problem has little to do with sentence length．
Simply put，run‐on sentences are created when two（or more）independent clauses are improperly joined．（An independent clause is a clause that contains a subject and a verb and can stand alone as a complete sentence．）
In a run‐on，independent clauses may be run together，with no punctuation or transitional words between them．
e.g．The attorney encouraged her client to settle the case out of court the client refused because he wanted to go to trial．
Or they may be insufficiently connected with just a comma．
e.g．The lawyer handed the judge a memo，it fell on the floor．
（This type of run‐on is often called a comma splice ．）
Once you've identified them，run‐ons can be easily corrected in several ways．
（1）Make the run‐on two separate sentences．This is often the best choice when the original sentence is very long．
e.g．The attorney encouraged her client to settle the case out of court．The client refused because he wanted to go to trial．
（2）Use a semicolon，or a semicolon plus a transitional word，to link the clauses．
e.g．The lawyer handed the judge a memo； however ，it fell on the floor．
（3）Use a conjunction（and a comma）to join the clauses．
e.g．The lawyer handed the judge a memo， but it fell on the floor．
（4）Reword the sentence to turn one of the independent clauses into a dependent clause using a subordinating conjunction．
e.g． When the lawyer handed the judge a memo，it fell on the floor．
Examples of common subordinating conjunctions are when ， because ， before ， after ， whereas ， while ，and unless ．
Sentence fragments，along with run‐on sentences，are among the most frequently made sentence errors．A fragment can be defined as a sentence that does not express a complete thought—most often because it is missing a key element，such as a subject or verb，or begins with a subordinating word．
The following examples are all fragments，for different reasons．
Example 1： The attorney objecting to the line of questioning．
The problem with this so‐called sentence is that it's missing a verb．Although“objecting”looks like a verb，in this case it's not．Look closely：The phrase“objecting to the line of questioning”is really being used as an adjective to describe“attorney．”Which attorney is being discussed？The one who's objecting to the line of questioning．
To make this into a complete sentence，you need to add a verb．If you want to relate a simple，straightforward action，try：
The attorney objected to the line of questioning．
If，however，you wanted to say something more about that attorney，you could write：
The attorney objecting to the line of questioning rose to her feet．
Here，the word“rose”functions as a verb，making this a complete sentence．
Example 2 ：The jurors remained in the hotel for three days．Bickering the whole time．
While the first sentence here is complete，the second is not—it is missing a subject．The second sentence seems to be an afterthought to the first，so you could link them together：
The jurors remained in the hotel for three days，bickering the whole time．
Or you could add a subject to the second sentence to make it complete：
The jurors remained in the hotel for three days．They were bickering the whole time．
Example 3 ：Unless the witness testifies．
This sentence is really a dependent（or subordinate）clause that can't stand on its own．Ifyou read it aloud，you're probably thinking，“Unless the witness testifies—WHAT？”The writer here probably meant to attach this clause to the sentence before or after it．The problem could be corrected either way：
This case will be dismissed unless the witness testifies；
or
Unless the witness testifies，we will surely lose this case．
You can prevent fragments of this sort by making sure that whenever you begin with a subordinating word（such as unless ， because ， when ， if ，etc．），you include enough information in the sentence to create a complete thought．
As a general rule，the best way to avoid creating sentence fragments is to ask yourself，when writing a sentence：“Does this sentence，standing on its own，express a complete thought？”If not，check to see what elements are missing．
Subject/Verb Agreement
Subject/verb agreement can seem straightforward for native speakers and others comfortable with English；we know to write“the attorney argues”and“the attorneys argue．”However，some special circumstances can make it more difficult to tell whether a subject and verb really do agree．These complications can arise from the words themselves，or from their order in a particular sentence．
Recognizing Plural and Singular Nouns
Again，the basics are straightforward—we usually add an“s”to the end of a noun to form a plural（a group of more than one“defendant”constitutes“defendants”）and know the most common irregular plurals（a group of more than one“child”is a group of“children”）．But here are a few to watch out for．
Some words you might not realize are singular
（1）Words that seem to refer to a group but must be treated like individuals because they are grammatically singular．They are：
For some words，it may help to think of the word split into its parts，so that“everyone”becomes“every one，”“none”becomes“not one，”and so on．This strategy emphasizes that the subject is“one”（“every”indicates which“one”is under consideration）and“one”is obviously singular．
Wrong：“Of all the students in the class，none have taken Latin．”
Right：“Of all the students in the class，none has taken Latin．”
（2）Words that end in“s”but represent a concept as a whole．Some examples：news，politics，statistics，economics．
Wrong：“Gymnastics are more dangerous than football．”
Right：“Gymnastics is more dangerous than football．”
（3）Collective nouns that represent a group of individuals acting as a body．Consider the following．
Right：“The Sons of the Revolution has an intertwined relationship with the state．”
Although under ordinary circumstances，“sons”would take a plural verb，in this case the writer has correctly understood that“Sons of the Revolution”is a proper noun referring to one organization as a whole，rather than several particular sons．
Similarly，some common nouns that may represent a group of people acting as one are：
Note that some of these words should be handled differently if they are used to represent a group of individuals acting separately（see“Some words you might not realize are plural，”below），but that some are always singular；for example，whether it consists of one individual，as in a trial court，or of a body of people，“the court”is regarded as an institution，and therefore takes a singular verb．
Wrong：“The court stated that they were ill‐equipped to second‐guess the trial court judge's determination．”
Right：“The court stated that it was ill‐equipped to second‐guess the trial court judge's determination．”
This is also true of expressions dealing with time，money，and weight．
Wrong：“Five thousand dollars were awarded to the plaintiff．”
Right：“Five thousand dollars was awarded to the plaintiff．”
Consider such amounts as lump sums rather than individual dollars（pounds，hours，etc．）．
Some words you might not realize are plural
（1）Words that come from Latin．“Data”and“agenda”are both plural；although they are often treated as singular in informal conversation，for the purpose of professional writing they should be treated with technical accuracy as plural．
Wrong：“The data does not support this conclusion．”
Right：“The data do not support this conclusion．”
Or，
Right：“The datum does not support this conclusion．”
Some singular/plural pairs that follow this model：agendum/agenda，criterion/criteria，datum/data，dictum/dicta．
（2）Collective nouns that represent a group of individuals who are acting independently．Whereas，for example，the word“jury”would take a singular verb when the jurors act in concert（“the jury decided that ．．．”），it would take a plural verb when differences between the group are emphasized．
Wrong：“The jury disagrees[among themselves]on this issue．”
Right：“The jury disagree on this issue．”
If this construction sounds awkward to you，you might rebuild the sentence with a different subject．
Right：“The members of the jury disagree on this issue．”
Note that some collective nouns always take plural verbs．Some examples：
Elderly，police，poor，young．
Right：“The elderly receive special protection under the law．”
Recognizing Subjects and Verbs in Unusual Places
In many sentences，the verb immediately follows the subject：“The police officer frisked the suspect．”This form is both common and effective because the close proximity of subject and verb allows the whole sentence to be comprehended quickly．However，variations occur and you cannot necessarily depend on the subject of the sentence to be the noun just left of the verb．Here are some instances of slightly less common structures．
Intervening Words
Sometimes a group of words that modify the subject will come before the verb．This situation can be tricky，because it will put a noun closely related to the subject right next to the verb．Here's an example．
Wrong：“The criminal nature of these incidents do not divest Family Court of jurisdiction．”
The writer has tried to create agreement，matching a plural noun，“incidents，”with a plural verb，“do not divest．”This mistake is natural because“incidents”appears where we often expect the subject，right before the verb．However，“incidents”actually belongs to a prepositional phrase that modifies an earlier word，“nature，”and the word should agree with that verb．
Right：“The criminal nature of these incidents does not divest Family Court of jurisdiction．”
A test：Try saying the sentence without the intervening words—“The criminal nature do not，”or“The criminal nature does not”？
Verbs Preceding Subjects
While verbs usually come after subjects，in a few instances you will find them reversed．This is most common in questions（“What is the standard governing municipal tort liability，and which elements must be met to satisfy the special relationship exception to that rule？”）and in sentences beginning with“there．”
Right：“There is a long history of judicial intervention in public schools since Brown v．Board of Education ．”
Right：“There are several criteria that courts use in deciding whether or not to intervene in public schools．”
Note that“there”is not the subject of the sentence；look after the verb to find the subject and check for agreement．In the first example，the subject，“history，”is singular，and should be paired with“is．”In the second，the subject，“criteria，”is plural，and should be paired with“are．”
Compound Subjects
Subjects made up of several individual components joined with“and”take plural verbs：“Both New Horizons and Queens Rising have contracts with the state to provide twenty‐four‐hour care for youth．”However，a couple of special cases exist．Keep an eye out for introductory words such as“each”“every”“either”and“neither．”
Subjects joined with“and”are plural，but subjects joined with“or”or“nor”are not（necessarily）．Consider the following．
Right：“Neither the Office for Civil Rights nor the Human Rights Commission in Vermont is likely to file a court claim against Bennington．”
Although the subject has two elements，“Office for Civil Rights”and“Human Rights Commission，”they do not have an additive quality；see“some words you might not realize are singular，”above，for a discussion of words like“neither．”However，a plural verb is appropriate if the part of the compound subject nearest to the verb is plural．A pair of examples will clarify this．
Right：“Neither the plaintiffs nor the defendant wants to suggest settlement first．”
Right：“Neither the plaintiff nor the defendants want to suggest settlement first．”
The verb in such cases may be singular or plural，but should agree with the nearest part of the subject．Your ear can guide you here；both“defendant want”and“defendants wants”sound wrong，regardless of any subjects they might be paired with．
Finally，when a compound subject involves the word“each”or“every，”use a singular verb．（See“some words you might not realize are singular，”above．）
Right：“Every pleading，written motion，and other paper is required to bear the signature of at least one attorney of record．”
Pronouns are words such as“I”“it”“they”“who”and“this”that stand in for nouns，noun phrases，and other pronouns．This is not a comprehensive introduction to pronouns，but a guide to some of the stickier pronoun situations you might encounter，with examples from legal writing．
（1）Subject vs．Object
Personal pronouns come in pairs，one for use as a subject and one for use as an object．Most of the time，fluent speakers can hear the difference between“I”and“me，”“we”and“us，”“he”and“him，”“she”and“her，”“they”and“them”when used in a sentence；“I went to the movies with them．”；“He bought her a present．”；Here are some instances that are more likely to be confusing．
In compounds
Wrong：“Her concern for Jeffries increased when John Jeffries threw a glass bottle from the top of the stairs at Mr．Jeffries and she．”
Pronouns that are part of compounds should be used in the same form that would be used if the pronouns stood alone．One way to test this is to take out every part of the compound but the pronoun．Which sounds better，“threw a glass bottle．．．at she”or“threw a glass bottle．．．at her”？
Right：“Her concern for Jeffries increased when John Jeffries threw a glass bottle from the top of the stairs at Mr．Jeffries and her．”
A fter a linking verb
Although pronouns toward the ends of sentences will tend to be objects（“We went with them”“He gave it to me，”etc．），those following forms of the verb“to be”；—am，is，are，was，were—are technically restatements of the subject，and therefore require subject form．
Wrong：“It was him who initiated the phone call．”
Right：“It was he who initiated the phone call．”
Although this phrasing is correct，it may sound archaic to you．If so，you might rewrite the sentence．
Right：“He was the one who initiated the phone call．”
Who vs．Whom
Contrary to common usage，“whom”is not just a fancy word for“who”that you should use when you want to sound important．The difference between“who”and“whom”is the same as the difference between“I”and“me”；“I”and“who”are subjects，while“me”and“whom”are objects．Look at the following sentence：
Wrong：“As long as parties are voluntarily participating in mediation and given a choice as to whom their mediator will be，they should be allowed to choose anyone they see fit．”
This writer does have a right idea，that“whom”follows a preposition，which generally is followed by an object form．However，the phrase“given a choice as to”introduces a clause，or a dependent part of the sentence that has both a subject and a verb，that might be rewritten to stand alone：“Who will be their mediator？”Here，the clause involves a linking verb，so the subject form of the pronoun is necessary．
Right：“As long as parties are voluntarily participating in mediation and given a choice as to who their mediator will be，they should be allowed to choose anyone they see fit．”
Here's a sentence where“whom”is correct．
Right：“The claimed constitutional deprivation must result from the exercise of a right or privilege created either by the state，by a rule of conduct imposed by the state，or by a person for whom the state is responsible．”
In this instance，the clause would read：“the state is responsible for．．．”Clearly，the object form is called for．
If，in correcting for who/whom and similar pronouns，you find that the technically correct version sounds strange to you，you might want to try rewriting the sentence so that it is both correct and appealing．
Right：“As long as parties are voluntarily participating in mediation and given a choice of mediators，they should be allowed to choose anyone that they see fit．”
（2）Singular/Plural Agreement
Pronouns should agree in number with the nouns they refer to（“The students agreed that they would form a study group”）．Writers are probably most likely to slip up in agreement when they are unsure whether the pronoun antecedent is singular or plural，or when they are trying to avoid gender bias by using“they．”
Some singulars and plurals to watch for
Some nouns，such as collective nouns and words from Latin，may not be instantly recognizable as singular or plural．For example，a court is considered to be an institution，and requires a singular pronoun regardless of whether the court you are writing about consists of one individual or a group of people．
Wrong：“The court stated that they were ill‐equipped to second‐guess the trial court judge's determination．”
Right：“The court stated that it was ill‐equipped to second‐guess the trial court judge's determination．”
Noun/pronoun disagreement and gender bias
You have probably read（or even written）many sentences like this one．
Wrong：“Given that New York State does not currently have a single set of court rules for all non‐adjudicative mediators，a private practitioner interested in implementing mediation services in their solo practice may be unsure about what standards to aspire to．”
The sentence first discusses“a private practitioner，”then refers to“their solo practice．”But since there is only one practitioner in the subject，any pronouns referring to that practitioner should be singular：“her solo practice”“his solo practice．”
A problem arises when this hypothetical practitioner is potentially either male or female．Thus，“their”has become a common dodge for escaping gender bias，because it does not indicate gender．
Not Really Right：“In order for a child to be classified as requiring special education，he needs to be provided with the necessary evaluations．”
Formerly，“he”was assumed to include both male and female individuals，but this practice is no longer widely accepted．
Right but Cumbersome：“In order for a child to be classified as requiring special education，he or she needs to be provided with the necessary evaluations．”
No wonder people have reached for“they．”The trick for making the technique work is to change the initial noun from singular to plural，so that it matches“they．”
Right：“In order for children to be classified as requiring special education，they need to be provided with the necessary evaluations．”
（3）Unclear Reference
When they are not handled carefully，pronouns can introduce ambiguity into your writing．When several male persons have been named，which one does“he”indicate？Will your reader see immediately which previously described concept or situation your use of“this”refers to？
With Personal Pronouns
Wrong：“When Rodriguez entered the precinct，she told the officer at the front desk about Jeffries's condition，but rather than taking her report，she was asked to speak directly with Officer Frazier．”
Does the second“she”in this sentence refer to Rodriguez，to the officer at the front desk，or even possibly to Jeffries？The phrase“rather than taking her report”leads the reader to expect the next pronoun to refer to the officer at the desk，but“was asked to speak directly with Officer Frazier”sounds like advice to Rodriguez．This sentence could be rewritten in a number of ways；here are two options．
Right：“When Rodriguez entered the precinct，she told the officer at the front desk about Jeffries's condition，but her report was not taken and she was asked instead to speak directly with Officer Frazier．”
Right：“When Rodriguez entered the precinct，she told the officer at the front desk about Jeffries's condition，but rather than taking her report，the officer asked her to speak directly with Officer Frazier．”
With“This”“That”and“Which”
Wrong：“Mediation may resolve an issue quickly and not allow for parties to heal which may be accomplished by delays in the court system．”
What may be accomplished here，resolution or healing？
Wrong：“Perhaps if Tuparo decided that he would not sign the contract until these matters were cleared up or his propositions were considered an argument could be made that this was a counteroffer．Yet this was not the circumstances of this case．”
These two sentences use three“this”es and a“these．”The agreement problem in the second sentence also makes comprehension more difficult．When instances of the word“this”create a problem in your writing，replace them with something concrete．Here's a way to replace one here：
Right：“．．．an argument could be made that the additional writing he appended to the contract was a counteroffer．”
（4）Other Potential Problems
Here are a few more pronoun issues to look out for．
Who vs．That
Wrong：“Whether a relationship between the mediator and non‐English speaking parties can be established when a translator is present that is not part of the procedure．”
Right：“Whether a relationship between the mediator and non‐English speaking parties can be established when a translator is present who is not part of the procedure．”
“Who”is used for people；“that”is used for other nouns．
Consistency
Wrong：“Prison life requires that one give up their liberty and other rights，but not his fundamental right of due process．”
In this sentence，“one”“their”and“his”are all meant to refer to the same person，but do so in varying ways．It is better to be consistent；choose one way of referring to the subject and use it throughout the sentence．Here's one option．
Right：“Prison life requires that people give up their liberty and other rights，but not their fundamental right of due process．”
Personal Pronouns
Wrong：“We urge the court to deny the motion to dismiss．”
In formal legal writing，it is not customary to identify yourself，the writer．In the conventions of this discourse，words like“I”“we”and“our”are avoided．
Punctuation is one component of writing that people seldom think about or notice—except when it is wrong．At their worst，misused punctuation marks—commas，semicolons，quotation marks，and the rest—may muddle the meaning of your sentences，leaving your reader confused and frustrated．Even less egregious errors—say，a missing or misplaced apostrophe—can give your written work an appearance of carelessness and lack of attention．
（1）Quotation Marks
Quotation marks are required whenever you are giving the exact words spoken or written by another person．In American English，double quotation marks are used for indicating quotations．Single quotation marks indicate a quote within a quote．
e.g．Prof．McArdle said，“The briefs will be due on Tuesday．”
Loucas said，“Prof．McArdle said，‘The briefs will be due on Tuesday．’”
（For those of you familiar with British English conventions，this is a change in style．）
The rules for using other punctuation with quotation marks are fairly straightforward．If you are introducing a quote with a phrase such as“He said”“The record states”or“As Justice Scalia wrote，”you must use a comma before the quotation marks．
e.g．The defense attorney shouted，“I object to that question！”
If you want to introduce a quote with an independent clause（a phrase that could stand alone as its own sentence），you must use a colon before the quotation marks．
e.g．The defense attorney raised an objection：“That question is not relevant！”
If，however，you are integrating quoted material within your own sentence，you do not need any introductory punctuation．
e.g．Evelyn described her father as a“stubborn old man．”
You must also be careful about the placement of other punctuation marks at the end of quotations．Commas and periods always go inside quotation marks．
e.g．Lou said，“This class is way too noisy．”
“This class is way too noisy，”said Lou．
Question marks and exclamation points go inside the quotation marks if they are part of the original quotation．
e.g．The security guard asked，“Whose car is this？”
but remain outside the quotation marks if they are part ofyour own sentence．
e.g．Did the nurse say，“Dr．Adler will be coming soon？”
（In this case，the nurse is not asking the question；the writer of the sentence is．）
Semicolons and colons at the end of a quotation should be placed outside the quotation marks．
e.g．A certain novel begins with the words，“Call me Ishmael”：do you know which novel it is？
（2）Apostrophes
The two main functions of the apostrophe are to form the possessive case of nouns（indicating ownership）and to indicate a missing letter or letters in a contraction．
Possessives
When forming the possessive of a singular subject， 's is generally needed．
e.g．The student's locker was filled with textbooks．
Margie's bagels are delicious．
If a singular noun ends in s ，you should still use 's to form the possessive．
e.g．Luis's car is parked on Main Street．
Her boss's office is very large．
However，some writers use an apostrophe alone when the noun is long and contains multiple s sounds．This is not incorrect．
e.g．Officer Gonzales'gun was stolen．
When forming the possessive of plural nouns，you should add only an apostrophe if the noun ends in s ．
e.g．The students'grades were posted on the board．
But the occasional plural nouns that don't end in s need 's to form the possessive．
e.g．The children's center opens at 9 a．m．
In two unusual cases， 's is used to form a plural noun．This occurs when you want the plural form of a single letter or of a word referred to as the word itself，as in the following examples．
e.g．Patrick got straight A's throughout four years of college．
This brief contains too many whether's．
Never use an apostrophe to form the plural of a proper name．
e.g．The Blochs came over for dinner．
（3）Contractions
The apostrophe is also used to replace missing letters in a contraction．For example，in the following sentence：
The clerk said the office wouldn't be open on Saturday．
“wouldn't”is a contraction for“would not”—the apostrophe replaces the missing o ．
Similarly，in the sentence：
We're tired from studying too much．
“we're”stands for“we are，”so the apostrophe replaces the missing a ．
Your/You're&Its/It's
The two instances that cause the most confusion—and the most mistakes—in apostrophe usage are your / you're and its / it's ．
Remember the contraction rule，and your choice should be clear．“You're”stands for“you are，”while“your”is the possessive form of“you”．
e.g．“ You're the top student in your class，”said the dean．
Likewise，“it's”stands for“it is”or“it has，”while“its”is the possessive form of“it”．
e.g． It's time for the orchestra to begin its rehearsal．
If you are confused about which word to use in a sentence，pause and ask yourself which meaning you want—a contraction or a possessive noun．
（4）Semicolons
A semicolon can be used to connect two independent clauses that are closely linked in meaning．
e.g．The professor began class at exactly 10 o'clock；students who arrived late missed some of the lecture．
In this example，the two clauses could stand alone as separate sentences，but joining them with a semicolon stresses the relationship between them．Using a comma alone to connect these clauses would not be sufficient and would create a run‐on sentence．
A semicolon would also be used to connect independent clauses when a transitional word or phrase is used．
e.g．The small airplane had a smooth flight； however ，a sudden gust of wind made its landing a little rough．
（5）Commas
Comma placement can dramatically alter the meaning of a sentence．Comma placement determines the grammatical，and therefore logical，structure of the sentence．
When should I use commas ？
a）Use commas to separate independent clauses when they are joined by coordinating conjunctions：and，but，for，or，nor，yet．
Example ：Tuparo began his new job， and Burstyn made changes to the personnel policy．（ Note that this could have been expressed in two sentences ： Tuparo began his new job．Burstyn made changes to the personnel policy． ）
b）Introductory expressions should be followed by a comma．
e.g． After leaving Weber and Orange ，Tuparo took a job at LSRA．
Therefore ，he did not make a counteroffer．
c）Use commas to separate three or more words，phrases，or clauses written in a series．
e.g．I bought eggs，milk，and cheese at the store．
Yesterday I read a book，took a walk，and wrote a paper．
d）Use a pair of commas in the middle of a sentence to set off clauses，phrases，and words that are not essential to the meaning of the sentence．
Example ：His neighbor， with whom he had had several serious disagreements ，removed a section of the fence．（ Note that the clause “ with whom he had had several serious disagreements ” is not essential to the meaning of the sentence．One way to check this is to see if we could rewrite the sentence to make two complete sentences．Example ： His neighbor removed a section of the fence．They had had several serious disagreements． ）
When should I not use commas ？
a）Don't use commas to set off parts of the sentence that are essential to the meaning，such as clauses beginning with“that．”
e.g．The book that I borrowed from you is excellent．
The last person who saw the victim alive claimed to have seen nothing unusual．
b）Tip：“Which”is generally used with a comma，“that”without．
e.g．Mr．O'Malley's apartment，which is on the seventh floor，is unsuitable for someone with mobility problems．（ Non‐essential to the meaning ）
The bill that Ms．Perez received contained several errors．（ Essentialto the meaning ）
c）Commas should not separate subjects from their corresponding verbs．
e.g．The new chief operating officer，changed the company's personnel and benefits policies．（ incorrect ）
d）Commas should not separate verbs from their objects．
e.g．The new chief operating officer changed，the company's personnel and benefits policies．（ incorrect ）
e）Commas should not split a double（or compound）predicate．
e.g．Tuparo finished his Masters，and got a new job．（ incorrect ）
（6）Dash Versus Hyphen
Rule of thumb，dashes separate，hyphens connect．When typing on word，a dash is made up of two hyphens（—）．Newer versions of word will generally connect them into one dash（—）．
a） Dashes offer separation but with added drama．
e.g．Everyone in the group left the scene‐even her brother．（ correct ）
b）Dashes can also be used to set off a clause，parenthetical expression，or list．
e.g．His neighbor—with whom he had had several serious disagreements—removed a section of the fence．（ you could use commas here instead ， but dashes change the emphasis ）
Our clients—Singh，Lafrance，and Ivanoff—have sent us the documents we requested．（ you could use commas here but it would be more confusing to the reader ）
c）Use a hyphen to connect two parts of a compound noun．e.g．U‐turn，stand‐in．
d）A hyphen is used to join two parts of a hyphenated adjective． Examples ：once‐in‐a‐lifetime opportunity，state‐run clinic．（ This often makes the meaning clearer．Consider the possible meaning of the following ： working class president ， dirty blonde hair ， versus working‐class president ， dirty‐blonde hair． ）
e）Many prefixes are hyphenated，especially if there may be awkwardness or confusion with the spelling．e.g．ex‐husband，pre‐1968，semi‐integrated，non‐nuclear．（ Some works are acceptable hyphenated and not．Example ： pre‐ war ， prewar． ）
（7）Punctuation with Citations
Here are a few basic rules regarding punctuation placement with citations．A citation that appears after a complete sentence should be treated as a complete sentence itself，beginning with a capital letter and ending with a period．This holds true whether the citation is a long or short form．If a cite is given in the middle of a sentence，it must be set off by commas．Notice the punctuation of the citations in the following example：
In New York，the rule is well settled that an advertisement is merely an invitation to enter into negotiations，and is not an offer that may be turned into a contract by a person who communicates an intention to purchase the advertised item． Geismar v．Abraham & Strauss ，439 N．Y．S．2d 1005（Dist．Ct．Suffolk Co．1981）； Lovett v．Frederick Loeser& Co． ，207 N．Y．S．753（Manhattan Mun．Ct．1924）．The only general test is the inquiry whether the facts show that some performance was promised in positive terms in return for something requested． Lovett ，207 N．Y．S．2d at 755．However，a purchaser may not make a valid contract by mere acceptance of a“proposition，” Schenectady Stove Co． ，101 N．Y．at 48，nor does the purchaser have the right to select an item which the seller does not have in stock or is not willing to sell at a reduced price． Lovett ，207 N．Y．S．at 757．
As illustrated in the first citation，when two or more cases are named，they must be separated by a semicolon．Also，be careful not to italicize the comma following the name of the case．
Now you've finished your draft and it's time to edit and proofread your paper．You need to review your work for organization and connection of ideas，and for clarity，including correcting errors in grammar and vocabulary．You also need to correct any errors related to punctuation，or mechanics，such as spelling or capitalization．
What Is“Editing” ？
Very often we are advised to edit our papers before submitting them，but what does“editing”mean？What do we need to do during that stage of the writing process to improve the quality of our written work？
D．Ferris（2002）describes“editing”as“looking over a paper you have already written to find and correct any errors in grammar，vocabulary，punctuation，or mechanics（spelling or capitalization）．”Some other scholars consider“editing”a much broader activity that also refers to issues of organization and coherence．
In this section we offer some strategies that will help you develop self‐editing skills．
Self‐Editing Strategies
We suggest the following tips to help you edit and proofread your work．
（1）Search for the occurrence of similar errors．
Ask yourself these questions：
• What problems appear repeatedly in my writing？
• What generalizations can I draw about my writing from these errors？
• Do my ideas frequently appear disorganized in the text？
• Do my paragraphs lack a topic sentence？
• Do I tend to repeat the same idea throughout the text，unnecessarily？
• Do I always write the same kind of sentence structure，e.g．subject‐verb‐object？
• Multilingual students： in what grammar areas do I make most of my errors？e.g．，are my errors related to the use of prepositions，verb tenses，articles，connectors，etc．？
（2）Build up a personalized editing checklist．
Once you've identified your patterns of errors，then you should create a checklist for yourself．The next time you edit a paper，you may want to focus exclusively on those errors，or pay more attention to them，and perhaps tackle them first．
（3）Make time for the editing phase．
Remember writing is not over when you have finished your first draft，but after you have revised and edited it．Setting aside time for editing is essential for all of your writing，including in‐class exams．
（4）Work on a hard copy．
This creates some distance between you and the final product and allows you to manipulate the paper copy in a more controlled way（you can go back or move forward to previous portions of the text as many times as you want）．It also allows you to take down notes directly on the text in an easy way．
（5）Make focused passes through a text to look at a specific issue．
For example，search the text for errors in subject/verb agreement（‐s missing from a 3rd person singular verb）．Don't try to look at everything at the same time，because you will miss a lot！
Self‐editing looks impossible when you think of it in general．However，when you break down the task in pieces and prioritize types of errors，then self‐editing becomes more manageable．If you have difficulties with the use of prepositions，but do not have much problem with verb tenses，then，focus on prepositions exclusively．One or two errors in verbs in your paper will not be as problematic as multiple errors in preposition usage．Then use the same procedure with different editing categories，one pass through for each one．
（6）When proofreading，read the paper from back to front．
Breaking the flow of ideas sometimes helps to focus on language issues rather than on the content itself．
（7）Use the dictionary（a lexicon or a thesaurus）in order to make an accurate and varied choice of words．
This way you will have access not only to meanings but also to synonyms，antonyms，shades of meaning，etc．A dictionary is a useful tool both for multilingual students and native speakers．
Editing Under Time Pressure
If you haven't set aside enough time to edit your paper carefully，you can take a shortcut（but never skip this phase！）．
（1）Read the question in the assignment and highlight key words and instructions．
（2）Plan your essay．
• Preferably，do so in a loud voice，by asking questions to yourself．
• Write down what you say（main points and points derived from that one）．
• Assign paragraphs to your text．Remember：one paragraph＝one idea．
（3）Write your paper and check your outline as you go along．
（4）Read the paper nonstop from the beginning to the end at least once．
When you work on different sections separately and then paste them to the general text，there may be problems of connection between those sections that you'll fail to detect unless you read the whole text．
（5）Proofread and edit your paper．
• Are there any spelling errors？
• Are there any words missing from the sentences？
• Are there any words used incorrectly？
• Can you suggest a better word or word form？
• Look at the nouns．Do they have the appropriate singular or plural endings？Is an article needed？Has the appropriate article been used？
• Look at the verbs．Do the verb endings agree（in person‐first，second，third‐，or in number‐singular or plural）with the subjects？Are the verbs in the appropriate tense？
• Look at punctuation．Do you see any problems with commas，periods，semicolons，quotation marks，etc．？
• Are there words that occur repeatedly but unnecessarily in the text？
Checklist
Here's a short general checklist that you may use when editing your papers（but remember：it is better to customize this list so that it considers the characteristics of your own writing．）．We provide an example of a problem，and its edited version．
（1）Search for phrase and sentence fragments．
Phrase Fragment：
e.g． The Court dismissed the charges of aggravated harassment．The charges of aggravated harassment in the second and in the third degree．
↓
e.g． The Court dismissed the charges of aggravated harassment in the second and in the third degrees．
Clause Fragment：
e.g． The Court dismissed the charge of aggravated harassment．Because the defendant did not initiate the telephone call．
↓
e.g． The Court dismissed the charge of aggravated harassment because the defendant did not initiate the telephone call．
（2）Search for run‐on sentences and comma splices．
e.g． Mary mentioned two previous incidents when John Meyers abused her ， she should include those in the petition for the order of protection as well．
↓
Mary mentioned two previous incidents when John Meyers abused her；she should include those in the petition for the order of protection as well．
Or use two separate sentences，as in：
Mary mentioned two previous incidents when John Meyers abused her．She should include those in the petition for the order of protection as well．
（3）Use the passive voice only when you want to subordinate the subject or source of agency．
e.g． Joseph was assaulted brutally （ by John ）．（Passive）
↓
John assaulted Joseph brutally． （Active）
It is appropriate to use the active version if you are prosecuting John for assault．However，the passive version is appropriate for his defense，because John appears less prominently portrayed as the source of the assault．As you can see，syntax is also a tool for persuasion．
（4）Do not overuse the verb“to be”and its conjugated forms．
e.g． Nora Clements IS a prospective client who IS seeking an order of protection in Family Court against John Meyers ， who IS her former boyfriend．To determine if Mary can get the order that she IS seeking ， we must address both procedural and substantive issues．
↓
Nora Clements is a prospective client seeking an order of protection in Family Court against John Meyers，her former boyfriend．To determine if Mary can get this order，we must address both procedural and substantive issues．
（5）Use nominalization．（But careful：do not overuse it．）
Nominalization is the transformation of verbs or adjectives into nouns， as in
John is exhausted． （adjective to noun）
↓
John's exhaustion
John's generous behavior （adjective to noun）
↓
John's generosity
John apologized to his friend． （verb to noun）
↓
John's apology to his friend
John published the novel without authorization ．（verb to noun）
↓
John's unauthorized publication of the novel．
[The highlighted words have undergone nominalization．]
Though nominalization is useful sometimes，its overuse can really make your writing dense，monotonous，or incomprehensible．This is what happens in：
e.g． The suggestion was that an immediate intervention to solve the uncomfortable situation would ensure the protection of the members of the organization．
See how much clearer this sounds when we do not overuse nominalization：
e.g． They [ or somebody ] suggested that an immediate intervention to solve the uncomfortable situation would protect the members of the organization．
e.g． They [ or somebody ] suggested that the members of the organization would be more protected if there were an immediate intervention to solve the uncomfortable problem [ or conflict ， etc． ]．
（6）Avoid overly embedded sentences．
Embedded sentences contain many clauses introduced by elements such as who ， that ， which ．A sentence with multiple clauses inside or the succession of many sentences containing one embedded clause each makes the text more difficult to read and more confusing．
e.g． Nora Clements ， who is a prospective client who seeks an order of protection in Family Court against John Meyers， who is her former boyfriend，is requesting our legal advice．To determine if Mary can get the order that she seeks ，we must address issues that are both procedural and substantive ．
↓
Nora Clements is a prospective client seeking an order of protection in Family Court against John Meyers，her former boyfriend．To determine if Mary can get the order she seeks，we must address both procedural and substantive issues．
Or： Nora Clements ， a prospective client ， seeks an order of protection in Family Court against her former boyfriend John Meyers．To determine if Mary can get this order ， we must address both procedural and substantive issues．
Or： Nora Clements seeks an order of protection in Family Court against her former boyfriend John Meyers．To determine if Mary can get this order ， we must address both procedural and substantive issues．
（7）Avoid repetition in sentence structure．
A text that repeats the same sentence structure（e.g．subject‐verb‐object‐rest）over and over again may sound extremely tedious to the reader．Whenever possible，vary the internal structure of your sentences．
e.g． Clements and Meyers were not married． They both had children outside of their relationship． Meyers has lived apart from Clements for approximately a year． Meyers punched Clements in the face repeatedly seven months ago and badly bruised her． Meyers was arrested but Clements refrained from pressing charges．Then Meyers cursed at Clements and attacked her one week ago．
[We have underlined the subjects in this text in order to show that all the sentences and clauses in this text keep the same structure，namely Subject‐Verb‐Object‐Rest．]
Now observe how the text improves when we just change the position of some adverbials（e.g．“Seven months ago”“One week ago”）in the sentence，and by using the active voice（ Meyers was arrested by the police． → The police arrested Meyers． ）．
↓
e.g． Clements and Meyers ， who were not married and had children outside of their relationship ， have lived apart from each other for approximately a year．Seven months ago Meyers badly bruised Clements by punching her in the face repeatedly． The police arrested Meyers，but Clements refrained from pressing charges．One week ago Meyers cursed at Clements and attacked her ．
[The underlined subjects in this sentence show that subjects no longer occupy the initial position in the sentence；that position varies．]
（8）Avoid tautological definitions．（i．e．avoid defining a term by using it in the definition itself．）
e.g． John's harassment constitutes harassment in the second degree．
↓
John's behavior constitutes harassment in the second degree． [Edited version]
1．Fill in the blanks with the correct article：THE，A，AN，or 0（“zero”）（if no article applies）．
Just to confirm （1）__________rushed phone conversation we had today，I've been served with （2）__________complaint from（3）__________Small Claims Part of （4）__________Civil Court brought by （5）__________shopper against Loman's for （6）__________breach of （7）__________contract on （8） __________theory that she came to our main branch last month in （9）__________response to （10）__________ad for （11）__________leather coats and that we“failed to have （12）__________merchandise to sell at （13）__________advertised price．”We had advertised these coats in one of our recent circulars．（14）__________text of （15）__________advertisement is part of （16）__________FAX I sent previously to your office．
2．Break each of the following long sentences into at least three separate sentences．
• Appellee Allied Indemnity of New York respectfully suggests that oral argument would be of little benefit because the dispositive issue has been recently authoritatively decided by the Texas Supreme Court in National Union Fire Insurance Co．v．CBI Industries ， Inc． ，907 S．W．2d 517（Tex．1995）， and by this Court in Constitution State Insurance Co．v．Iso‐Tex ， Inc． ，61 F．3d 405（5th Cir．1995），because the facts and legal arguments are adequately presented in the briefs and record，and because the decisional process would not be significantly aided by oral argument．[91 words]
• Although no Kansas cases were found that explicitly hold that Kansas requires a corporation to have a valid business purpose in order to engage in certain specified corporate transactions，either for mergers or consolidations，or for a sale of assets followed by a dissolution and liquidation，in a 1994 Supreme Court of Kansas case involving a cash‐out merger where the dissenters claimed the defendant's board of directors breached its fiduciary duties to the dissenters，the court cited as one of the trial court's pertinent conclusions of law that it is not necessary for a corporation to show a valid corporate purpose for eliminating stockholders．[105 words]
• The court of appeals noted that the Environmental Protection Agency（EPA）had already issued the applicant a National Pollution Elimination System permit for the actual discharge of wastewater，which would occur from the outfall pipe，and that the issuance and conditions of such permits were generally exempt under the Clean Water Act from compliance with the Environmental Impact Statement（EIS）requirement，and accordingly the court concluded that the Corps had properly excluded the environmental implications of the discharges from the outfall pipe from its analysis and instead considered only the construction and maintenance of the pipeline itself in determining that the issuance of the permit did not constitute a major federal action．[112 words]
3．Edit the following sentences to eliminate the passive voice．
• Testimony was heard from the plaintiff and from three witnesses on behalf of the corporation．
• This is a purely legal question to be determined by the court．
• McCormick's motion for partial summary judgment on the duty to defend should be denied．
• Plaintiff's opposition violates Rule 313 of the California Rules of Court and may be disregarded by the court．
4．Delete at least four consecutive words in the following sentences，replace those words with just one word．You may rephrase ideas and rearrange sentences，but don't change the meaning．
• Even assuming that the fog caused injury to Roelke，Amskills had no duty to prevent that injury because it was idiosyncratic and Amskills could not have been expected to foresee such injury．
• At no time prior to the initial public offering did the underwriters or any officers，directors，or employees have knowledge of any facts that would suggest that“Palm Harbor”could not be completed on schedule and in accordance with specifications．
• Beale has wholly failed to allege facts that，if true，would establish that competition among the nation's law schools would be reduced or that the public has been in any way injured，and this failure to allege facts that would establish an injury to competition warrants the dismissal of her restraint‐of‐trade claim．
• The Business Corporation Law does not address the ability of a New York corporation to indemnify individuals who are not its employees．
• The court examined a number of cases and stated that there appeared to be only a limited number of instances in which there would exist a duty to disclose the illegal conduct of persons who，through political campaigns，seek election to a public office．
5．Correct the usage errors in the following sentences．
• When Margot arrived，Rodney told her that David had laid down because of his pain．
• Mrs．Clements testified that Kenneth was waving the gun wildly and pointing it at Bill．
• Counsel testified that because the testimony would have harmed her case，she opted to forego it for reasons of trial strategy．
• Since the Oneida line of cases are now binding federal law in California，this Court is bound to follow them．
• The cost of any arbitration proceedings will be born by the party designated by the arbitrators．
• The gas would likely be inventory under the Idaho statutes defining the term，but these provisions might not apply since they do not effect Idaho taxable income．
• Texas law prohibits the unjustified interference with a parties'existing or prospective contractual relations．
• For the reasons stated in Jones's initial motion，Jones maintains that the Court's August 27 order precludes Fillmore from preceding on count six in this action．
• The laws of the State of Massachusetts（irrespective of its choice‐of‐law principals）govern the validity of this Agreement，the construction of its terms，and the interpretation and enforcement of the parties'rights and duties．
• Neither Mr．Robinson's affidavit nor Plaintiffs'deposition testimony carry the force of law．
① http://raymondpward．typepad．com/rainman2/2004/12/the_importance_．html
② http://ezinearticles．com/？What‐is‐Legal‐Writing？&id＝1223274