This is a continuation of some ideas about communication. All of these are fundamentals and not something brand new, but they are also essential to good communication. While we often give acknowledgement to them with the attitude "I already know that" I’ve discovered that lawyers often do something very different under the pressure of a trial. They revert to what is comfortable for them without even realizing it.  So here are a couple more thoughts for you to consider 

 TELL A STORY INSTEAD OF GIVING A CHRONOLOGICAL NARRATIVE  

People are interested in a story, not plain facts. They pay attention to a story and reason to conclusions in story form. A well told story does not have numerous details but instead paints a very broad picture without specifics. Always be general and not specific. It has a begriming which leads to an interest of what is going to happen, a step by step story unfolding to a strong conclusion. Think of a ten word telegram as the story: mom in labor, baby is in trouble, nurse ignores, doctor not to be found, baby born brain injured.

Don’t use technical terms in the overall story without first giving the definition and then the term e.g. doctors and nurses are trained to carefully watch the condition of the baby. This is known as "monitoring"

Remember John Wayne’s advice about acting "talk, low, talk slow and don’t say too much"

DECIDE FROM WHOSE VIEW POINT YOU WILL TELL THE STORY  

It makes a big difference from which perspective the story is told. It can be told from the viewpoint of an eye witness, the defendant, the plaintiff or any number of other perspectives. You can describe the defendant’s conduct, for example, as if you were an eye witness or you can put yourself in the shoes of the defendant and tell it as if it were the defendant telling the story. Viewpoint is important. Select the right viewpoint to tell the story from. Don’t automatically begin the story in the way you have always done it.