MINNESOTA COURT RULES

APPELLATE PROCEDURE

Forms provided here are for reference purposes. To download forms to fill out please visit the Minnesota Courts website.

FORM 128 - APPELLANT'S FORMAL BRIEF AND APPENDIX

(Cover)

APPELLATE COURT CASE NUMBER

STATE OF MINNESOTA

IN COURT OF APPEALS

CASE TITLE:

Respondent,

vs.

Appellant.

APPELLANT'S BRIEF AND APPENDIX
JOHN BROWN	SMITH & JONES
Attorney for Respondent	By John Jones
(address, zip code, and telephone number)	Attorney for Appellant
	(address, zip code, telephone number, and attorney registration license number)

.
TABLE OF CONTENTS
	Page
Table of Authorities	2
Legal Issues	3
Statement of Facts	4
Argument
1. (Concise statement of each legal argument advanced)	7
2.	12
3.	15
Conclusion	19

APPENDIX AND ITS INDEX
Complaint	1
Answer	2
Jury Instructions (if applicable)	3
Verdict	7
Motion for New Trial	8
Order Denying Motion for New Trial and Memorandum	11
Notice of Appeal	12

.
TABLE OF AUTHORITIES
Statutes (list applicable statutes and page where argument found)
Minnesota Statutes, section 518.58 (1982)	8
Cases (list applicable authorities and page where argument found)
Jones v. Olson, __ N.W.2d __ (Minn. 1982)	9
Smith v. Brown, __ Minn. __, __ N.W.2d __ (1965)	14
Secondary Authorities
McCormick, Damages, section 83 (1935)	16

.

LEGAL ISSUES

I. (Precise statement of each legal issue)

Trial court held: _

II.

.

STATEMENT OF FACTS

(The facts should be stated in compliance with RCAP 128.02, subd. 1(c), accompanied by appropriate citations to the appendix and the transcript.)

.

ARGUMENT

I. (Each legal issue should be argued separately. RCAP 128.02, subd. 1(d).)

.

CONCLUSION

(The conclusion shall contain a statement of the precise relief sought.)

Respectfully submitted,

SMITH & JONES

By John Jones

Attorney for Appellant

(address, zip code, telephone number, and attorney registration license number)

.

APPENDIX AND INDEX

(The index should precede the appendix and the pages of the appendix should be separately numbered. RCAP 130.)

(Amended effective for appeals taken on or after January 1, 1992.)