Your opening submissions should: include a brief outline or "roadmap" of your argument clearly set out the central legal issues clearly state the conclusion that you want the IAD Member to reach enumerate the reasons (law and facts) as to why the IAD should allow the appeal (i.e. the H&C grounds that your submissions will be based on) Keep the CREAC structure in mind as you draft your opening statement. Recall that the most persuasive argument is structured as a clear legal conclusion that is supported by reference to the relevant legal authority - legislation, case law and government policy where relevant - as applied to your client's specific facts