The ABA’s McElhaney on Litigation suggests replacing chronology with groups of vivid word pictures.
Jim McElhaney writes (excerpt):
McElhaney on Litigation
“. . . Tell them the story. . . . [P]ut together a series of verbal snapshots that you create out of the evidence. . . .
“Then show them word pictures again in your case-in-chief . . . . [U]se the witnesses and your exhibits to paint the pictures. . . .”
“After you’ve decided what goes in each of your pictures,” said Angus, “decide on the order in which you’re going to show them to the jury, with three questions in mind: First, what order makes it easiest to understand the story? Second, what order makes the moral imperative come alive so that the jury decides your client is the victim of a serious injustice? Third, what order puts the focus of judgment on the other party?”