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McElhaney, supra, at 40, expains:
“All things being equal (which they never are), what you hear first, you are more likely to accept as being true . . . .”
Lubet, supra, at 35, says:
“The doctrine of primacy tells us that the trier of fact will pay maximum attention to the witness at the very beginning of the testimony. You can make further use of this principle by continuously “re-beginning” the examination. That is, every time you seem to start anew, you will refocus the attention of the judge or jury. This technique can be called reinitiating primacy . . . .”
Ralph Adam Fine, The “How-to-Win” Trial Manual 17 (2nd ed. 2001), puts it this way:
“The rule of primacy tells us that what we learn first colors the way we look at what follows. This is the tool that sets the jury’s gyroscope; once set in favor of a particular result, it is more likely than not that the jury will arrive at that destination.”
David Ball, Theater Tips and Strategies 68 (1994), simplifies it primacy to:
“A good beginning makes your jurors start listening.”
And Mauet, supra, at 22, states:
“When trials are short, primacy is the more important concept.”