Closing Arguments: Use Demonstrative and Trial Exhibits

Every good trial lawyer knows that a jury remembers best that which they both hear and see. Accordingly, demonstrative exhibits should always be used during closing argument. Sometimes demonstrative exhibits are necessary in order to emphasize a point about liability. Sometimes they are used to emphasize principles of law.
Effective demonstratives can also be used to discuss damages. A good closing argument might use demonstratives in all of these areas. In short, a well prepared demonstrative exhibit will assist counsel in making his point while at the same time assisting the jury in remembering it.
Of course, in addition to using demonstrative exhibits, actual trial exhibits should be shown to the jury just as a demonstrative exhibit would be shown. If a particular exhibit is important, the exhibit should be referred to by number and shown to the jury and its importance to the case should be discussed. An actual trial exhibit (blown up) can be used as a demonstrative exhibit in this fashion where counsel uses the exhibit to demonstrate to the jury why it is that the evidence supports his client’s contentions on any contested issue in the case.

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