Addresses generally

[11000] Generations of advocates have found that a good address, opening and closing, has these parts:

1. Introduction.

2. Identification of the issues.

3. Evidence that proves each issue.

4. Conclusions or inferences to be drawn.

In its composition, it should be logical and expressed in simple language.

[11005] In a jury case it is generally not wise to refer to the law in any detail. The reasons are these. If you do refer to the law you must do it by way of submission as you would to a judge. Most advocates find that ungainly. The judge will be referring to the law in the directions to the jury. Those directions of law will be combined with the evidence you have referred to and your arguments or submissions contained in your final address. You will often have to refer to some general law, but try to make it so well known as not to need citation or submission. It will possibly take the following form:

[11010] There are several things that you must not do in any address. You must not give your opinion, except perhaps on matters of general human nature.