WRITTEN ARGUMENT TEMPLATE INSTRUCTIONS (please remove table when completed) Last Updated: December 20, 2023
Step	Action
1	Double click on REQUIRED grey text fields; delete text and then enter information or enter information where there are instructions.
2	Enter Court of Appeal case number example: CA12345 If more than one case is being heard together: enter only the case number applicable to the party, case and court record being filed.
3	Enter appellant and respondent’s names below.
4	Enter Sealing Order or Publication Ban (if any) referencing legislative provision (or inherent jurisdiction) that authorises the order or ban and the order or ban’s precise terms. If none exist, remove placeholder for publication ban or orders from template.
5	Part 1: Facts – A brief statement of facts Part 2: Issues – A statement of the issues for the application Part 3: Analysis – A brief argument setting out why the justice erred in making the decision under review Part 4: Order Sought – The nature of the order (or orders) requested Enter name of lawyer(s) or party(ies) who prepared the filing
6	Consecutive paragraph numbering begins after Part 1 Statement of Facts
7	To add to paragraph numbering: Enter text and press enter after each paragraph to maintain auto-numbering. (1.5 line spacing and single space between paragraphs required – pre-set in template)
8	To delete numbering use backspace key.
9	To remove instructions table: Right click mouse on (top lefthand corner of this table)
10	Select Delete Table.

COURT OF APPEAL FILE NO. [Enter CA case number: example CA12345]

[Enter Name of First Appellant vs. Name of First Respondent]

Memorandum of Argument

COURT OF APPEAL

BETWEEN:

Enter name(s) of appellant(s) here

APPELLANT(S)

Enter role in the lower court or tribunal e.g. (Plantiff)

AND:

Enter name(s) of respondent(s) here

RESPONDENT(S)

Enter role in the lower court or tribunal e.g. (Defendant)

Publication Ban or Anonymity Order (if any) : Enter legislative provision (or inherent jurisdiction) and terms.

Sealing Order (if any): Enter legislative provision (or inherent jurisdiction) and terms.

[Enter MEMORANDUM OF ARGUMENT ON AN APPLICATION FOR …]

[Enter Name of Filing Party]

Part 1: Facts

Example: The respondent …

Example: The respondent, contrary to its claim …

Part 2: Issues

Part 3: Analysis

Example Footnote: The s. 4(1)(a) requirements are met if, assuming the pleadings to be true, it is not clear and obvious that the claims have no chance of success.

Part 4: Order Sought

All of which is respectfully submitted.

Dated at the City of [Enter location], Province of British Columbia, this [Enter month] [Enter day] of [Enter year].

[Name of lawyer or party authorizing filing]

Hollick v. Toronto (City), 2001 SCC 68 at para. 25.