Since an appeal will be limited to the evidence that was presented in the lower court, all relevant evidence must be clearly presented in the lower court, in the motions as well as in the trial, if there is one.

Likewise, all available legal arguments should be made in the lower court, because generally a new argument may not be made for the first time in the appeal. (There is, however, an exception for a purely legal argument).

If there is a trial, every error must be “preserved,” or else the appellate court will generally not consider it.  Thus, care must be taken to make “a record” of every potentially significant issue.