When I entered the private practice of law in 1991 following a two-year clerkship for a judge serving on the U.S. Court of Appeals for the Third Circuit, I remember being told by someone far more experienced that someday it will seem like second nature to dictate the contents of a brief into a Dictaphone or mini tape recorder. At that time, I was part of a new generation of lawyers who grew up with computers and learned to write by typing the contents of a document right onto an empty page in a computer’s word processing program.

“Lawyers aren’t paid to type” was the adage of that time. Instead, lawyers were paid to write lengthy documents by speaking into a microphone, producing an audiotape that a secretary would then type into a document, which the attorney thereafter would spend hours rewriting, editing, and returning again and again to the secretary until the final product was perfect or as close as it could ever get as a result of that process. That was not how I wrote an appellate brief in 1991, nor at any time thereafter.