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The task memo asks for a complete objective memorandum, including a Statement of Facts. The File contains favorable facts, unfavorable facts, and several irrelevant background details.
Which approach is best?

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Include every fact in the File in the order received. Select material facts, present them neutrally, include important unfavorable facts, and avoid irrelevant background. Write the facts as if arguing to a jury. Include only the facts that help the client.

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