To produce a mighty book, you must choose a mighty theme. - Herman Melville
Take it from a pro. Theme: it's the glue that holds your arguments together. Without a theme, or an understandable theory of the case, your argument is little more than a mish mosh of statutes and cases. Themes excite the reader, and compel the judge to believe that an injustice has been done to your client. As I always say, a lawsuit, by definition, is a conflict, and conflict is the necessary ingredient for any drama. The issue may be dry, but there is a story to be told. Dig deep into the record and identify what the case is really about. Make that theme permeate your argument. Tell your client's story.