1. CLOSING ARGUMENTS Introduction Issues Theory/Story
Basis of Guilt/Innocence
Jury Instructions
Refuting the other side
Conclustion

2. Introduction Get right to the point
Jurors want to hear what you want and why you are entitled to what you want
Keep their attention
Start with your theme

3. Jury Instructions What are the elements of the law?
How did you prove/case doubt on those elements?
Example:
Ladies and Gentlemen, we had to prove the defendant is guilty of trafficking marijuana and was predisposed to do so. This is not a case of entrapement.

4. Example
“The case is about a tragedy. That’s because when the police fail to do their job, when they fail to do a thorough investigation, when they take shortcuts, the wrong person can stand accused of a crime he didn’t commit. That’s a tragedy, and it’s a tragedy that started for Bobby Abrams at 8pm that August night.”

5. Issues What is in dispute between each side?
State it in a way that the answer should be obvious and then answer it anyway
Example
Folks, there’s only one issue in this case. Its simply this: Was the defendant negiligent when he drove his car and crashed into Mrs. Smith’s car? The answer is obvious, the defendant was negligent.

6. Example
“The prosecution would like you to believe that the only issue is whether Frank shot and killed Jackson. But that’s not the issue here. The real issue is this: Did the prosecution disprove, beyond a reasonable doubt, that Frank was not entitled to defend himself against Jackson’s assault? They haven't been able to disprove this, because its simply true

7. What really happened? Story/Theory
Don’t spend any time on undisputed facts
Focus on key disputed facts
Focus on three kinds of controlling issues.
Elements of required proof/burden of proof
What inferences can be drawn from evidence
What do the facts mean?
Focus on Witness credibility
Who do you believe

8. Use the witness testimony to tell the story

9. Basis of Guilt/Innocence
Sum up why the facts force the conclusion that it happened the way you claim
Example:

10. Conclusion
Restate your theme
Request a verdict