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Opening with a story to complete, and a stage to set

Feb 15, 2011 Opening with a story to complete, and a stage to set

Photo from website of U.S. District Court (W.D. Mi.).

Recently, some fellow lawyers discussed what they do to make trial opening statements more persuasive. I do my best in opening to continue telling my client’s persuasive story and to connect with the jurors. The following two lawyers gave me the greenlight to post their views:

Jules Cherie of Chicago says: "Tell the client’s unfinished story in a way that demands a just ending that only the jury can provide."

Marj Russell of Michigan says: "Try to find a critical moment to show in action. Jurors believe what they see, even in a mini re-enactment And reject testimony that is inconsistent. If you can psychodramatically also put a piece of furniture in opponent’s path, Jury will get upset when they walk through it (you must remember to respect it yourself – walk around that invisible couch every time, and have witnesses put it in same spot). Whatever comes to life soonest is believed."

What do you focus on for a persuasive opening statement? As a juror, what do you look for in an opening statement?

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