Use proper names or designations that will appropriately characterize the parties, e.g. , the grandparents, the school district, J.L., the Village, Jones. Try to use words that carry effective connotations. Make sure, also, to start from the beginning. Introduce the characters and clearly indicate any abbreviations you plan to use in parentheses. Do not let your statement of the facts leave the court with needless questions.
Reliability is essential.
Glaring omissions of adverse facts central to the other side's case will decrease your credibility with the court. The negative side of the case will appear less damaging if you cautiously disclose it first. You can dilute the force of adverse facts through the use of passive verbs or by placing the damaging material in a subordinate clause. Also, once you have mentioned the harmful fact, you do not need to emphasize it. Your desire to paint a persuasive factual picture, however, must not cross the boundary into argument.