Closing argument is where the evidence is connected to the verdict form. Its structure should follow the questions the jury will be asked.
Use the instructions. Quote the element, then the evidence proving it. Juries are given the law in writing and want to know how to apply it.
Use the verdict form. Walk through each question and state the answer and the reason. A jury that leaves the courtroom knowing how to fill in the form is far more likely to fill it in your way.
Documents over recollection. In a commercial case the strongest closings are built from exhibits displayed and read.
Answer the other side. Address the two or three arguments the opponent will make, before they make them if you argue first, and directly if you argue second.
Damages. Give the jury the arithmetic. A number with a visible derivation is adopted; a number without one is discounted.
What is not permitted. Stating personal belief in the justice of the cause, referring to facts not in evidence, appealing to prejudice, suggesting the consequences of a verdict on the parties’ finances, and inviting jurors to place themselves in a party’s position.
Object when it happens. A closing objection preserved is worth more than a post-trial motion.