Follow standard practice for placing references in your writing. If you are writing a legal memorandum or appellate brief, cite the memo within the text. Use footnotes in other forms such as law review articles.
Begin the citation with the standard citation for the case to which the memo is attached. For example, when citing a memo from the Supreme Court case of Community for Creative Non-Violence Et Al., v. Reid, start with "Cmty. For Creative Nonviolence v. Reid, 490 U.S. 730 (1989)." Give the title of the case, the case reporter location and the year of the case.
Insert an opening parenthesis "(" after the year of the case. Type the abbreviation "Mem." to indicate that you are referring to a legal memo.
Type "at" followed by the page number within the memorandum to provide the reader with an exact location, but do not include the word "page."
Include the court case management system document number, such as the federal courts' CM/ECF, if available. For example: ECF No. 21.
Add a closing parenthesis to end the citation: (Mem. at 30, ECF No. 21.)