Repeat important points in new ways.
Lubet, supra, at 26, 41, explains:
“Important points should be repeated . . . to increase the likelihood that they will be retained and relied upon by the trier of fact.
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“Repeat [essential ideas]. Restate them. Then repeat them again. Then think of ways to restate them again. . . . [E]mploy your lawyer’s creativity to fashion numerous slightly different questions, each stressing the same point. Repetition is the parent of retention, and your most important points should arise again and again . . . .
“The corollary to this principle is that less important points should not be repeated in like manner. Increased attention should be used to make key subjects stand out. If too many points are given this treatment, they will all be made to seem equally unimportant. How do you decide which facts are sufficiently important to bear repetition? The answer is to consider your theory and theme. . . .”
Fine, supra, at 18, agrees:
“Repetition is known as “the mother of learning.” And so it is. Ask any actor struggling to learn his or her lines, or any student struggling with complex mathematical formulae.”
A compelling instruction is offered by Ball, supra, 81:
“You may repeat anything . . . so long as with each and every repetition you follow the two
RULES OF REPETITION
“1. DIFFERENT: Make some substantial alteration in how the material is communicated (different words and organization, different medium, different visceral, or different point of view, etc.) . . . .
“2. STRONGER: Make certain that the importance, or intensity, or viscerality, or general impact of the repetition is stronger than the time before. In other words, arrange your repetitions so that they progressively increase in intensity or impact.
Obey both Rules of Repetition with every repetition or you will bore the jury and undermine the effect of the thing you are repeating.”