Some little stylistic things, if you are looking for polish

Punctuation matters

Commas in lists and series: The BB is silent on this issue (at least BNL can't find the rule). According to The Chicago Manual of Style, in a series of three or more items, you should set the last item off with a comma before the conjunction. This is tricky when two items together form one item in a series. Where the elements in a series are long phrases, especially ones that have commas within them, it is better to set the elements off with semi-colons.

Good:    I read the complaint, the answer, and the motion.

    I brought the rope and the block and tackle.

Not:    I read the complaint, the answer and the motion.

OK:    Defendant offered plaintiff the car, which had previously been totaled, $1000 in cash, payable in $200 payments over five months, and a release of liability, which defendant had downloaded from the Internet.

Better:    Defendant offered plaintiff the car, which had previously been totaled; $1000 in cash, payable in $200 payments over five months; and a release of liability, which defendant had downloaded from the Internet.

Apostrophes: You should not use contractions in your memoranda, unless you are quoting evidence or an authority that did. "Cannot" is one word.

Good:    Defendant did not justify its fees to plaintiff as required by the Act.

Defendant cannot justify its fees.

Not:    Defendant did not justify its fees to plaintiff as required by the Act.

Defendant can not justify its fees.

Defendant can't justify its fees.

When indicating a possessive, you should add an apostrophe and a lower-case 's,' unless the possessive is pronounced without an additional syllable.

Good:    SDS's initial capitalization was $3,000,000.

The Snyders' ownership interests in Snyder Corp. exceed ninety percent.

Not:    SDS' initial capitalization was $3,000,000.

The Snyders's ownership interests in Snyder Corp. exceed ninety percent.

Colons. Generally, use a colon only to end a complete sentence that introduces a list or that describes the clause that follows it. Do not use it to introduce a list that is necessary for the completion of the sentence.

Good:    To invoice this equitable claim, the plaintiff must show two elements: (1) the sole or dominant shareholder had control . . .; and (2) . . . .

To invoke this equitable claim, a plaintiff must show that (1) the sole or dominant shareholder had control . . .; and (2) . . . .

Defendant incorporated SDS for one purpose: to avoid liability.

Not:    To invoke this equitable claim, a plaintiff must show that: (1) the sole or dominant shareholder had control . . .; and (2) . . . .

Stringing sentences and clauses together: If you have two adjacent complete sentences that are closely related in subject, you may string them together either with a comma and a conjunction or with a semi-colon. If you have two verb clauses with the same subject, you should join them with a conjunction and no comma. (But if you have three or more such clauses, then you have a series and should join them according to the "comma" rules above.) Stringing two complete sentences together with a comma only is an error, called a "comma splice" by some.

Good:    Defendant is a subsidiary of Snyder Corp., and Mr. Snyder owns sixty-five percent of the shares of Snyder Corp.

Not:    Defendant is a subsidiary of Snyder Corp. and Mr. Snyder owns sixty-five percent of the shares of Snyder Corp.

Defendant is a subsidiary of Snyder Corp. Mr. Snyder owns sixty-five percent of the shares of Snyder Corp. (Comma splice.)

Good:    Defendant is a subsidiary of Snyder Corp.; Snyder Corp. owns seventy-five percent of the shares of defendant.

Not:    Defendant is a subsidiary of Snyder Corp., Snyder Corp. owns seventy-five percent of the shares of defendant. (Comma splice again.)

Good:     Mr. Snyder is president of Snyder Corp. and owns sixty-five percent of its shares.

Not:     Mr. Snyder is president of Snyder Corp., and owns sixty-five percent of its shares.

Good:     Mr. Snyder is president of Snyder Corp., is a member of its board of directors, and owns 100% of its shares.

Not:     Mr. Snyder is president of Snyder Corp. is a member of its board of directors and owns 100% of its shares.

Other style matters

It is not necessary to announce an abbreviation of a common name or term in your memorandum if the abbreviation is obvious.

Good:    Snyder Corporation is the parent corporation of Snyder Distribution Systems ("SDS"). Chris Walker and Walker Company have sued SDS and Snyder Corp. Mr. Walker and Walker Co. allege that SDS and Snyder Corp. interfered with a contract.

Not:    Snyder Corporation ("Snyder Corp.") is the parent corporation of Snyder Distribution Systems ("SDS"). Chris Walker ("Mr. Walker") and Walker Company ("Walker Co.") have sued SDS. Mr. Walker and Walker Co. allege that SDS interfered with a contract.

Do not capitalize job titles unless they immediately precede a person's name.

Good:    Daniel Snyder is chief executive officer and president of SDS.

Not:    Daniel Snyder is Chief Executive Officer and President of SDS.

Avoid words that redundantly identify the present time in sentences using the present tense, except when contrasting the current time to another time.

Good:    Daniel Snyder is chief executive officer and president of SDS.

Not:    Daniel Snyder is currently chief executive officer and president of SDS.

    Daniel Snyder is president of SDS at this time.

    Daniel Snyder is president of SDS at this point in time.

    Daniel Snyder is now president of SDS.

OK:    Daniel Snyder is currently president of SDS; if SDS uses this suit, he may soon be unemployed.

Because your memorandum relates to an ongoing suit, your memo subject line should probably include the caption of the case. E.g., "Walker Co. v. Snyder Distribution Systems: piercing the corporate veil to hold Snyder Corp. or Steven Snyder liable." If I happen on this memo later, I'll have a better chance of understanding what it is about.

Watch out for initial dependent clauses where it is unclear what they modify. These phrases are often called "dangling modifiers."

Not:    To examine this issue more clearly, the factors are separable into three broad categories. (Are the factors going to examine the issue?)

Better:    Examining the issue clearly requires separation of the factors into three broad categories.

Not:    After reading the underlying data, the article remains unconvincing. (Did the article read the underlying data?)

Better:    After reading the underlying data, I remain unconvinced.