Each lawyer has their own style.
This is true.
In a factum, headings and numbered paragraphs are your friend.
For example,
Overview - (<1 page)
The parties, the issues, what you want.
Statement of Facts - (<1 page)
Succinct. Brevity is important. If you aren't relying on a fact as a part of your argument then it does not need to be included.
Issues - (<1 page)
What is the motion about? Example,
[14] Where is the habitual residence of the children?
[15] If it is Ottawa, can it be changed unilaterally by the Respondent father?
[16] Which jurisdiction should decide the issues of custody and access?
[17] What custody and access is in the best interest of the children?
Arguments in Brief - (many pages, with sub headings for each section)
As an idea, each issue should have its own sub heading to argue why that issue should be decided in your favour.
Order Requested - (<1 page)
Example,
[38] For all the foregoing reasons, the Applicant respectfully requests that this Honourable Court decide that Ottawa is the habitual residence of the children and order that the issues of custody and access be decided there.
[39] The Applicant respectfully requests that she be granted custody of the children or, in the alternative, an order for joint custody.
[40] The Applicant respectfully requests that the Honourable Court order that the children reside with her or, in the alternative, the parties have equal access time.
[41] The Applicant requests that the court order the appointment of the Office of the Children’s Lawyer.
[42] The Applicant requests costs on a full indemnity basis.
Table of Authorities - (legislation, jurisprudence)
Appendices
