A written submission is your argument in a form the judge can read after the hearing is over. It is tempting to put everything in. The most effective submissions do the opposite. They are selective, ordered, and easy to follow.
Lead with the issues
Frame the document around the questions the court has to decide, not around the chronology of your file. Under each issue, state your position in one clear sentence, then support it. A judge reading a clean issue-wise structure can follow your logic without hunting for it.
Use the record, not adjectives
Calling the other side's conduct outrageous adds nothing. Pointing to the exact document, page, and line that proves your point adds a great deal. Every important assertion should carry a reference to the evidence on record.
Deal with your weak points
Ignoring the difficult part of your case does not make it disappear. It simply lets your opponent frame it first. Address the weakness on your own terms, explain why it does not change the outcome, and move on. Courts trust an argument more when it does not pretend the inconvenient facts are not there.
Keep it tight. A submission that respects the reader's time tends to be the one that gets read closely.