Brief
Findings of Fact/Conclusions of Law
Statement of Issues or Position
This is an argument of law prepared and submitted by counsel for a party to a proceeding in litigation, setting the issues in controversy, identifying facts relevant to the issues, identifying case law germane to the issues with argument distinguishing controlling precedent and statutes from dicta, and proposing remedy. Briefs are both initial and responsive (rebuttal, etc.). Briefs may be submitted by other parties other than the adverse litigants (amicus curiae).
This is a pleading or argument of law, usually submitted in response to a request from the presiding ALJ or Commission, in which a party defines or clarifies its position as to the specific nature of the issues in controversy, or states its position with respect to issues or procedural matters. Usually, such statements are solicited to narrow the scope or sharpen the focus of the matter in litigation.
This is an argument of law recommending to the presiding ALJ or the Commission what should be the findings as to the facts of the case or controversy and what conclusions as to controlling law should be reached from the application of law to those facts.