In Garner on Language and Writing, Bryan Garner explains why buried verbs make legal writing inefficient: (a) Abstract
nouns are longer
than base verbs; (b) Writers
often wedge buried verbs in long prepositional phrases and passive constructions; (c) Abstract
nouns confuse readers because they don't directly say who is doing what; and (d) Buried verbs make writing stagnant and dull.