They can focus on a problem in a way a practicing attorney beset by distractions cannot. A judge forms an opinion about an attorney based on the quality of his or her writing, quite apart from the points raised in the argument and the aptness of the cases cited. That kind of writing skill is partly innate, partly learned. Legal writing is a particular kind of skill. Judge Brown emphasized the importance of a statement of facts.
Every brief needs it to provide a frame within which to understand the argument.
Any story teller has a point of view, and a writer telling the plaintiff's story must always keep that in mind. The professional writer knows that the plaintiff's brief needs to let the judge see what happened through the plaintiff's eyes, and the same is true, of course, for the defendant's brief. For example, consider a case where the plaintiff, on the way to his graduation, is hit and seriously injured by an automobile while crossing a busy urban thoroughfare around which dense vegetation had been allowed to proliferate. The writer of the defendant city's brief wants to begin his or her points and authorities on a motion for summary judgment with a sentence that states the facts through the client's prism. Same event, two different pictures.