I don't know anything about KY state appellate court, but for educational purposes this is what appellant brief looks like in my state;
A) COVER SHEET
1) POINTS AND AUTHORITIES (Case laws by page number)
2) NATURE OF THE CASE : This appeal involves an action arising from Plaintiff’s refusal to comply with contractual arbitration per terms and condition of the credit card agreement (synopsis of the case)
3) JURISDICTIONAL STATEMENT :This is an appeal under Court Rule XYZW, from an order denying (WHATEVER ).The Circuit Court denied defendant’s motion to dismiss or, in alternative, to stay the action, etc.
This appeal was filed (X) days thereafter on (Date of filing ) (this is important because it gives higher court jurisdiction to review the case)
4) ISSUE PRESENTED FOR REVIEW: Did the court err in ruling, as a matter of law, that denied defendant’s motion to dismiss /compel arbitration and granted plaintiff's motion for SJ? ( the question is now before the court)
5) STATEMENT OF FACTS : Where one starts from service day all the way to last hearing. (Case laws)
6) STANDARD OF REVIEW: The Federal Arbitration Act (FAA) section 2-3 and how it is intended for agreements to be enforced.
Here sections of ATT vs Concepcion are cited.
7) ARGUMENT: Here one argues why court erred and how one was prejudiced by this error. (Case laws are very important here to establish authority, citing other courts/ rulings who had previously agreed with your points make the case for you.)
8)CONCLUSION: WHEREFORE, for the forgoing reasons..... (It's a wrap)
