Briefwriters are told to state the issue first, before the statement of facts. Why? Because knowing the issue the issue enables the reader to give meaning to the facts.
This isn’t a legal-writing thing; it’s a writing-for-humans thing. For elaboration, read this post by Roy Jacobsen, commenting on John Medina’s book, Brain Rules. Roy says that “there’s plenty in [this book] for writers to learn.” That grabs my interest.