End strong.
McElhaney, supra, at 40, says:
“All things being equal (which they never are) . . . what you hear last, you more easily remember.”
Lubet, supra, at 25, explains:
“Primacy and recency refer to the widely accepted phenomenon that people tend best to remember those things that they hear first and last. Following this principle, the important parts of a direct examination should be brought out at its beginning, and again at its end. Less important information should be “sandwiched” in the middle.”
Fine, supra, at 17, agrees:
“The rule of recency tells us that we will remember with the most clarity what we learn last.”
Ball, supra, at 73, states:
“The end of the story is its emotional climax. . . . In stories for juries, it is whatever fact or event best persuades the jury that your client is right.”
Mauet, supra, at 22, highlights the role of recency in longer proceedings:
“When trials last more than a few days, recency is probably more important.”