Dates and topic sentences
I was reading a facts statement in a brief, and I came to a series of paragraphs that each began with a date. I know that many judges say over-use of dates is weak, and my reaction was the same: "this is bad, unpersuasive, tedious." So I told the author not to put all these dates in there. But the author responded that these dates were crucial. They showed a timeline and brought the factual scenario within time limits that were relevant under the governing law. I thought about it overnight. Finally, I came to a realization.
Dates are not topic sentences.
So I told the author to keep the dates, but to stop using them as topic sentences. Instead, begin each paragraph with a topic sentence that introduces what will be discussed in the paragraph. The date, if it is relevant, can appear somewhere in the paragraph. But the date is not the topic, so don't use the date as the topic sentence.