Three turns and a check. Keep this open next to your chat: each step is the thing to paste next, with what you typed already carried across. Nothing is sent from here, and nothing on this page is a transcript. The conversation stays where you are having it.
Every issue you are considering, with the record cite for where each was preserved.
What was entered, against whom, for how much, and where the appeal sits.
The court, since its rules on issue presentation and page limits shape the answer.
The outcome the client is actually buying.
Anything you would rather the panel not read closely.
Watch for, the whole way through
Preservation and waiver rules are forum-specific and unforgiving. Nothing here establishes that an issue was preserved; the record and the rule do.
The standard of review often decides the appeal, and the model will state it confidently and wrongly. Confirm it for each issue in the actual court.
Dropping an issue can waive it for any further review. Before you cut, confirm what the drop forecloses.
A client who insisted on an issue and then loses will remember that you dropped it. Get the decision in writing, with the reason.
An issue that drags the panel through a bad stretch of record can cost you the appeal you were winning. Weigh that before raising it for completeness.