Personal Injury Opening Statements and Closing Arguments: Preparing and Delivering, Handling Objections and Related Motions

Developing and Presenting a Persuasive Roadmap, Delivering a Convincing and Memorable Case Summation

A live 90-minute CLE webinar with interactive Q&A

Wednesday, April 12, 2017
1:00pm-2:30pm EDT, 10:00am-11:30am PDT

This CLE webinar will provide guidance to personal injury litigators for preparing and delivering effective opening statements and closing arguments. The panel will discuss strategies for proper timing and sequencing of opening statements and closing arguments, making and responding to objections during opening and closing, and bringing and defending motions related to conduct or assertions during opening statements or closing arguments.


Opening statements and closing arguments are major influencers of jurors’ perceptions of the theories, facts and evidence in personal injury litigation. A superbly prepared and delivered opening statement and closing argument can lead to a successful outcome, while a catastrophic opening or closing may doom a case.

According to published reports, more than 80% of jurors make up their minds about a case during opening statements. Opening statements are most effective when personal injury counsel employ creative storytelling techniques and appropriate visual or technological aids, introduce controversial or disputed topics before the opposing side has the opportunity to do so, and avoid the common mistakes of argument, exaggeration and misrepresentation.

Closing argument is the personal injury litigator’s final opportunity to convince jurors to rule in his client’s favor. Effective closing statements are memorable, as with Johnny Cochran's infamous line, "If it doesn’t fit, you must acquit." They are persuasive, should display passion and conviction, and should always involve effective demonstrative visual aids.

Personal injury attorneys must be strategic and thoughtful about the proper organization and timing of the opening statements and closing arguments, as well as versed in how to appropriately make and respond to objections during opening and closing, and how to properly bring or challenge motions related to conduct or assertions during opening statements and closing arguments.

Listen as our authoritative panel of personal injury attorneys discusses key techniques for preparing and delivering opening statements and closing arguments and related issues.


  1. Opening statements
    1. Key elements of opening statements
    2. Use of visual/technological aids
    3. Common pitfalls during opening—arguments, exaggeration, misrepresentation, etc.
    4. Common objections during opening
  2. Closing arguments
    1. Key elements of closing arguments
    2. Using visual/technological aids
    3. Common pitfalls during closing
    4. Common objections during closing
  3. Arguing and defending motions related to conduct or assertions during opening statement and closing argument


The panel will review these and other key issues:

  • What are some key considerations for personal injury litigators when preparing opening statements?
  • What common pitfalls do litigators encounter with opening statements?
  • What are some effective strategies for personal injury litigators when delivering closing arguments?
  • What types of objections are often raised by attorneys during opening statements or closing arguments?
  • What are some best practices for bringing and defending motions in limine, motions for mistrial, and other motions related to conduct or assertions during opening statements or closing arguments?


Michael A. Brusca, Shareholder
Stark & Stark, Lawrenceville, N.J.

Mr. Brusca dedicates his practice to representing vulnerable individuals and their families in wrongful death, catastrophic injury, negligence and abuse claims arising in nursing homes, assisted living facilities, psychiatric facilities, hospitals, boarding and group homes. He is a frequent lecturer to lay organizations and fellow attorneys at the state and national level on topics such as facility selection, resident care, litigation, trial practice, and technology issues.

Robert F. Glass, Partner
Glass & Robson, Atlanta

Mr. Glass’ practice focuses exclusively on representing individuals who have been seriously injured or killed by the negligence of others. Since he began his plaintiff’s practice in 2010, he has recovered millions of dollars for his clients. Mr. Glass uses his past experience of representing insurance companies and multinational corporations to achieve the best result possible for his clients. He has been asked to speak on various personal injury litigation issues and trial tactics based on his past successes.

J. Parker Miller, Principal
Beasley Allen Crow Methvin Portis & Miles, Montgomery, Ala.

Mr. Miller’s practice is focused on high-stakes, complex litigation. He currently represents survivors and their families in a wide range of catastrophic injury or death cases, including product liability cases involving vehicles, the workplace or failed safety devices. Mr. Miller served as co-lead counsel for the state of Alabama in the Deepwater Horizon oil spill litigation. He is also a leading figure in a number of legal organizations, particularly the Alabama State Bar, where he is an at-large Bar Commissioner, a member of the State Bar President’s Executive Committee, and a member of the Local Bar Task Force.

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Customer Reviews

The webinar was well-presented, interesting and informative.

Randi Saul-Olson

McKinney, Wainwright & Saul-Olson

Overall, a very good presentation. For my practice, the presentation was relevant and highly informative.

David Lawrenz

Hinkle, Hensley, Shanor & Martin

The relevance of the material and impact on the PI practice area was greatly appreciated.

Derek M. Baroumes

Baroumes & Bruen

Great content, including everyday examples, provided by each speaker.

Tim Reed

Duncan Firm

I liked the practical and specific tips.

Natalie Lyons

The Cannon Law Firm

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Litigation Advisory Board

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Greenberg Traurig

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Akin Gump Strauss Hauer & Feld

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