Much folklore and myth surround our perceptions of closing arguments. So many times you will hear attorneys say that, "I'll tie that together in closing," or "I'm saving that point for closing," and so many times, you will hear lawyers puff about how someone is such a great closer. Sometimes it's even true, but most of the time those puffing statements are just that - puffing statements.
The closing statement should not be a surprise. The closing should emphasize and echo the themes that the trial team has developed throughout the trial - in voir dire, in opening, in direct examinations and in cross-examinations. As the thread that weaves together your closing, the theme should be a short, memorable statement that incorporates key facts, suggests why your client wins and appeals to the jurors' values and common sense. With the theme interlaced, the closing statement should tell the story of the case. Portray the facts that are likely to persuade the trier of fact (jury, judge or arbitrator) that your side is right and concede the facts that are inconsistent and place those facts in an understandable context. Your closing argument should provide the jurors with the tools to argue your case in the deliberation room.