Appeals are very technical. There are rules about what to include, font size and style, page limits, color coding, numbers of copies, tabbing, etc... An attorney who specializes in or has experience in appeals is well worth a diligent search.
Aside from the technical issues listed above the content of a brief takes a special skill set. The brief must be well organized and compliant with the rules with an eye toward bringing technical errors of the trial court to light.
Two major rules that can cause great difficulty on appeal are the ore tenus rule and Rule 28. The ore tenus rule presumes that the findings of fact made by a trial court should generally not be disturbed on appeal because the trial judge is there at trial to review the demeanor of witnesses and judge their credibility. The idea is that the judge is there and scrutinizing the witnesses to determine who is telling the truth and who is not. However, this assumption is not always justified. Judges are human just like you and me. Sometimes they are distracted, their mind wanders or they are just otherwise inattentive or disinterested. Sometimes judges miss things or just don't appreciate what is being presented for whatever reason. The ore tenus rule acts as an obstacle to any reconsideration of the evidence. Sometimes the appellate court has so much respect for the trial court that it ignores the facts of a case and uses the ore tenus rule to justify turning a blind eye to the facts. I have seen a custody case where a mother moved her children 1000 from a comfortable home to pursue her own romantic interests. Not only did she mover her children from their home and extended family, she moved them into a tent, then into a barn. The state then had to inform her that a barn was not appropriate accommodations for children. These facts were undisputed at the trial court but were ignored by the appeals court for the sake of the ore tenus rule. Sadly if you were to read the decision in this case you would never know what the mother had done because none of the facts were included in the opinion. I have often thought that litigants and truth would be better served by video recording all family and custody cases for review on appeal. In these cases there are no juries or audiences to protect truth. We use instant replay in football games because we want to get it right. For the same reason instant replay is needed in family and divorce court.
Rule 28 dictates that all arguments on appeal must be supported by facts and law. This is a sound premise. However, sometimes this rule can be stretched to absurd lengths. Abraham Lincoln once quipped some judges "would hang a man for blowing his nose in the street , but ... would quash the indictment if it failed to specify what hand he blew it with." Some judges have been seen to use this rule to the extent that absent a definition being provided for each word of a brief the argument would be inadequate. While Bill Clinton may have stated that his answers must be conditioned on what your definition of the word "is" is; the rest of us are able use a little common sense. I have seen cases where the opinion indicates that this rule has not been satisfied but a review of the brief will show dozens of cases cited on the subject matter. perhaps the attorney should have provided a footnote to define the word "is" for the court. The rules have a purpose - to make sure justice is served. However, when they are stretched justice is never served.
Special note should be taken of these rules to make sure your appeal is not dismissed before the facts of your case are even considered.