You are drafting your opposition memorandum or response brief. That means directly engaging arguments advanced by the opposing party, which requires you to cite where they made those arguments in their motion. That citation usually looks something like this:
Plaintiffs next argue that they were entitled to 30 days’ advance written notice and opportunity to cure under Section 3. See Plaintiffs’ Motion for Summary Judgment at pp. 11-13. That assertion is false and violates straightforward rules of contract interpretation.
There’s nothing wrong with this citation. We see it all the time in different forms. But notice how it slows down the read and clutters up the text. Now consider the same excerpt with a mid-sentence citation:
Plaintiffs next argue (at 11-13) that they were entitled to 30 days’ advance written notice and opportunity to cure under Section 3. That assertion is false and violates straightforward rules of contract interpretation.
This type of citation ensures a much smoother ride and accomplishes the same result. You can also use it to refer to your own filings, as in a reply:
As we argued in our motion (at 7), Utah case law mandates this result …
Read any sampling of briefs from the top flight appellate attorneys and you will see that this is how they do it. It’s also a preferred citation method in the Solicitor General’s Style Guide. There are, of course, times when a direct, old school citation is needed—such as when citing to multiple different court documents or in multi-party cases to avoid confusion. You’ll know it when you see it. But most of the time, this should be your go to. Smooth. Bold. Refreshing.