POINTS RELIED ON
1: RULING OF THE COURT
What specific action or ruling of the court is alleged to be error? What is it that the trial judge did wrong (should have done differently)?
2: WHY WAS THE RULING WRONG?
Specifically, what was wrong with the ruling of the judge? What is the legal basis for concluding that the judge's ruling was erroneous?
3: WHEREIN WAS THE ERROR MADE?
What facts (testimony/evidence/material in the record) give rise to the conclusion that the court erred? How do these facts, when viewed in context of the legal basis for the party's argument (the why), support the conclusion that the judge erred?
THE SUGGESTED WORDING:
The trial court erred in
Because
In that