An opening statement tells the jury what the evidence will show. It is not argument, and courts sustain objections when it becomes argument, but the line allows a great deal.
Start with the theme. One or two sentences that state what the case is about in ordinary language. Jurors form views early and revise slowly.
Chronology. Most commercial disputes are best told in order, because juries understand sequence better than legal categories.
Concrete detail. Names, dates, documents and quotations. Abstractions about breach and damages do not hold attention or memory.
Address the weakness. Whatever the other side will make of your worst fact, say it first, in your own framing. A weakness disclosed is a credibility deposit; one concealed and revealed by the opponent is a withdrawal.
Promise only what will be delivered. An opening that describes evidence never produced is quoted in the closing against you.
Damages. Introduce the measure, and the number, in the opening. A jury that hears a number for the first time in closing treats it as an argument rather than as a fact.
Length. Shorter than counsel wants. Twenty minutes of clear narrative outperforms an hour of detail.