
Opening is NOT your opportunity to spew all your facts. Not even all your good facts. Jurors (humans) can only absorb so much at once. If you turn on the firehose, they will drown.
In your opening, aim to (1) capture their attention, (2) keep their attention, (3) tell them only what they need to know to decide the case in your favor (all other good facts that do not relate to your claims should be presented later or, gasp, not at all!), (4) tell a story in a sequence which allows jurors to know what they are looking for before you feed them important facts. Within the opening, you also need to counter defense points, but in a subtle manner that does not cause jurors to feel that you are playing defense or putting too much emphasis on the issues in your case. Otherwise, you may give jurors important facts and they will miss them because they had no groundwork to recognize they were importantly. Remember, you have lived the case. They know nothing.
The opening I crafted two nights ago was for a medical malpractice case and took no longer than 10-15 minutes to deliver. We cut over 45 minutes worth of information and I guarantee it will be multitudes more impactful.
If you need help with opening, framing, jury research, jury selection, or voir dire prep, reach out.