IDEAS ON OPENING STATEMENT AT TRIAL

​This is your moment as advocate to provide the jury with your perspective of the case.  You must remember you are not to make argument on any matter or issue.  Remember it is a statement, not an argument you are delivering. 
Opening statements are a speech that provides for an overview of the case.  You get to tell the jury what they should expect to hear and receive in evidence.  Do not promise what you may not be able to deliver.  Do not promise evidence that has not been stipulated to, because something may go wrong and that evidence may not be seen by the jury at the end.  Do not promise to provide them with full transparency because you cannot control your objections or those of opposing counsel and given the side bar practice you will have failed the jury if you promise transparency. 
Tell them who you are, why you are there, what you expect the evidence will show and why, and explain the process of the trial.  Explain to them that the importance of their job largely rests on the fact that there are no do overs.  This is it forever and the stakes are high.  In this way you are impressing upon them the importance of their job.  When you empower others, they tend to do a better job. 
You are setting the tone for the trial.  Make sure you speak not only to your presentation of the case, but what you expect the presentation of the opposing party to focus on.  You want to thwart the other party from being able to have a moment that allows the jury to generate the sensation that you had concealed something, even if it is the ability to perceive a fact in more than one way.
Keep it short, and simple.  Do not get suckered into the limelight.  It is not about you aside from your need to become the mythical truth-sayer in the jury’s mind.