It all comes down to the closing argument, says Attorney Jessica Dean. The summation of every piece of evidence and testimony, plus the opinion of the attorney can sway the jury and win the trial.
According to Dean, the lawyer must avoid seeming “pleading, manipulative, or overbearing.” She likens it to walking a legal tightrope. In her more than two decades as a personal injury attorney specializing in corporate malpractice, the courts have come to know her as a passionate and effective closer. This founding partner at the Dallas, TX firm Dean Omar Branham Shirley, LLP offers insight into preparing for the closing argument.
- Highlight key areas of the verdict form and jury charge with any information you want to include in your closing as soon as you receive the form. This keeps your argument on track and helps build impartiality by using the judge’s words from the jury charge.
- Keep the opening and closing consistent. The opening statement can become a blueprint for the closing statement. Jessica Dean deletes everything from a copy of her opening statement that she won’t place in the closing. This helps her create a closing that reinforces her opening while encapsulating all that the trial uncovered that bears repeating.
- Create simple, straightforward slides without large blocks of text or complex diagrams. Keep the text on each slide to 15 words or less.
- Form one complete idea per slide. Let each idea flow to the next.
- Each slide also needs to contain evidence using exhibit stickers. This helps link the slide to the evidence.
- Consider the closing argument a work in progress. Sometimes the judge delivers the jury charge and instructions just prior to the closings. Dean has an assistant or her second chair work on the slides as she presents using the introductory ones that she already made.
- Cover every opportunity to restate your case, frame evidence, and legally deconstruct each of the judge’s instructions so the jury forms an idea of how to take action based on your instructions that repeat the judge’s instructions.
These seven tips from Jessica Dean attorney can help even an experienced lawyer write a stronger closing argument. They work for corporate cases and other types of legal cases.