Fact Cite Checks: Credibility in Motion Prep (Part 2 of 4)

By Molly Gulbrandson, ParaOne Legal Services

In Part 1 of this series, I shared how motion preparation is the framework that strengthens an attorney’s argument. Today, let’s look at one of the most powerful steps: fact cite checking.

Fact cite checks aren’t just about lining up page and line numbers. They are where the motion earns its credibility. Every fact tells a piece of the story, and when those facts are precise and supported, the story holds together. When they’re not, the cracks show quickly.

The Story Beneath the Surface

Each cite is a promise to the court: this is what the record shows. That promise has to be kept.

If a date doesn’t match the exhibit, if a deposition line is off, or if the cited testimony doesn’t say what it claims, the whole narrative loses momentum. Judges and opposing counsel notice.

Paralegals play a central role by:

• Double-checking the record so every reference is tied to the source.

• Catching inconsistencies that could unravel the timeline of events.

• Confirming that every exhibit connects to the fact it’s meant to prove.

It’s meticulous work but it’s also what transforms a draft motion into something that reads with clarity and authority.

Practical Tips

When I’m presented with a motion, I use four steps to stay organized:

1.      Highlight fact citations: I highlight them in yellow (and legal cites in a different color, which I’ll cover in the next blog). This lets me quickly see what needs to be checked. Once confirmed, I unhighlight.

2.      Use track changes. Instead of drafting a long email, I make notes and ask questions directly in the motion. This keeps everything in context for the attorney.

3.      Pull exhibits as I go. Since I need to review exhibits while fact-checking anyway, I save them to a folder for efficiency. Those same documents will be used again in exhibit preparation.

4.      Build an exhibit chart. For consistency, I create a chart that captures the long and short cite for each source, plus every page:line reference. For example, if a deposition is cited multiple times, the chart ensures the citations are uniform across the brief. (I’ll share more about this step in the upcoming exhibit blog.)

Systems matter because they anticipate the places where things can go wrong. That foresight is what shifts fact-checking from clerical support into a strategic step of motion practice.

The Strategic Value of Fact Cite Checks

When fact cite checks are done thoroughly, attorneys can focus on their arguments knowing the story underneath won’t fall apart. That confidence shows in the writing, in the hearing, and in the impression the court carries forward.

More than clerical review fact cite checking is strategic storytelling. It ensures that when a motion is read, the record itself speaks clearly, page by page, fact by fact.

Outro

Stay tuned: Part 3 of this series will look at Legal Cite Checks.