Motion Preparation from the Paralegal’s Chair (Part 1 of 4)
By Molly Gulbrandson, ParaOne Legal Services
If you’ve ever helped prep a motion, you know it’s more than the attorney building the argument. It’s also all the preparation that makes that argument stand strong.
A paralegal’s role in the preparation is what helps gives that argument its backbone. By organizing the record, checking citations, and managing exhibits, we assist in transforming the draft into something solid and credible. When the attorney hands it off for final preparation, it’s “go time,” and that’s where a paralegal shines.
Why Paralegal Prep Matters
When we do our jobs well, attorneys don’t just get “cleaner drafts.” They get time back, peace of mind, and the confidence that their motion rests on a rock-solid foundation. We’re the ones who:
Spot missing exhibits before any scramble.
Catch incorrect or outdated case citations before opposing counsel does.
Ensure every factual statement is backed by the record.
That’s not just support. It’s strategy.
The Three Core Pillars of Motion Prep
Over the next three posts, I’ll share paralegal-focused tips and tricks in each of these areas:
Exhibit Preparation – Think of exhibits as the spine of a motion. I’ll share practical systems for naming, indexing, and cross-referencing so attorneys (and judges) can move through the facts seamlessly.
Legal Citation Check – Nothing undercuts credibility faster than a bad cite. I’ll cover how paralegals can use tools and habits to ensure every authority truly supports its premise and is properly formatted.
Fact Citation Check – Accuracy here is everything. I’ll show how paralegals can streamline record review and fact-checking so every point in the motion stands tall.
Setting the Stage
This series is about more than process. It’s about how paralegals add real strategic value in litigation. The attorney may be the voice of the motion, but paralegals are the ones who make sure that voice is backed by clear, reliable, and organized support.