I would suggest that he look at the California Rules of Court regarding the requirements for an appellate brief, located here:
The brief should be divided into subsections for each of the requirements of the rule. For example, it may look like:
I. Nature of the action
III. Judgment below
IV. Appeal from judgment
V. Statement of facts
VI. Argument (usually allegations of errors made by the trial
court--each argument usually has a heading as well under A., B., C. and so on).
VII. Conclusion (usually request for relief from the appellate court--ie what he wants the appellate court to do)
He should be concise, because as you can see from the Rule, there is a word limit. There are numerous other procedures he needs to follow that are outlined in the Rule, like the font, type of paper that must be used, etc., that he should take note of as well.