This content is a closing argument in a criminal trial, asserting that the prosecution has failed to prove the defendant, John Perez, guilty beyond a reasonable doubt of drug trafficking charges, arguing that the evidence presented is inconsistent with the alleged crime.
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May it please the court, council,
members of the jury.
It's terribly difficult to go through
life without making any mistakes.
I've made mistakes. I'm sure many of you
have made mistakes. And if you haven't,
you know someone who's made mistakes.
Maybe a family member, a friend. And if
not, you know about celebrities, former
presidents who've made mistakes. But the
beautiful thing about humanity and the
beautiful thing about this country and
the beautiful thing about the great
state of Florida is that we're not made
to pay for these mistakes over and over again.
again.
And that's why we're here today.
John Perez.
John Perez
committed some crimes when he was
younger. He paid the price and he was
later recruited by the Miami Date Police
Department to involve himself in some
drug stings, some operations to bring
down criminals who are doing some of the
same things that he did in the past.
They thought that he would be an ideal
candidate. And in exchange for a place
in the witness protection program, a new
start at life, he agreed to help the
Miami date police department.
And he did exactly what he was asked to
do. Nothing more, nothing less.
They asked Mr. Perez to transport
drugs from Key West to Miami to make a
trip in a plane. And now they've charged
him with possession of the cocaine.
and they've charged him with the intent
to distribute or traffic that cocaine,
the same cocaine that he was asked to
take from Key West to Miami. Well, the
state has the burden to prove to you
beyond and to the exclusion of all
reasonable doubt that he was in unlawful
possession of that cocaine and that he
intended knowingly to traffic that
cocaine. And you know the story. They
alleged that he was flying the plane and
he somehow opened a trap door or a
normal door and he dropped a kilo of
cocaine from the plane that landed on
the ground that he intended to distribute.
distribute.
And that is how the story goes. Well,
in trials like this one, prosecution
puts together
stories, puzzles, kind of like a movie.
And there's different scenes of this
movie that they want you to put all
together at the end of the case to come
to some conclusion.
But at the end of the day, if there are
missing pieces of the puzzle or missing
scenes from the movie or even missing
links in the chain, then you must acquit.
acquit.
Now, in this case, the prosecution has
failed to prove to you beyond and to the
exclusion of all reasonable doubt that
Mr. Perez is guilty of the crimes for
which he's been charged. Let's talk
about this case.
Started off with my co-consel coming
before you and giving an opening
statement. And from the very start of
this case, our story has been
consistent. There's been no missing
pieces, no missing links in the chain.
And the state's council came before you
and also told you a story. They told you
that you would hear information about
how Mr. Perez dropped a package of
cocaine from the plane, how he opened
the door to that plane, and how he
intended to distribute that cocaine. But
let's take a look at the real evidence
that we have before us today. The only
evidence that you're allowed to consider
when you go back into that jury room.
Who else did we hear from? We heard from
an expert witness named Mikey Monday.
Now, Mr. Monday is an expert in the
logistics of airplanes. And he told you
that the air pressure in the plane would
not have allowed Mr. Perez to open up
the door of the plane while the plane
was in flight. And what is the only
conclusion that you can make from the
testimony of this expert witness? The
only conclusion that you can make beyond
a reasonable doubt is that the plane of
that door was not open. But you are the
wise judges of this court today, not me.
You sat here during the trial. You
listened to the testimony of all the
witnesses. You saw the evidence and the documents
documents
and now you have to go back and make a
decision. Well, I submit to you today
that the information that you have does
not prove beyond a reasonable doubt that
Mr. Perez is guilty of the crimes for
which he's been charged. If anything,
they prove that he is not guilty.
But in this state, the burden of proof
does not lie with Mr. Perez. And the
judge is going to instruct you that when
you go back into that jury room, there's
only one side that you have to place a
burden on today, and that's the prosecution.
prosecution.
And if the prosecution fails to prove to
you beyond a reasonable doubt any
element of the crime, then you must
Now, the reason why your job is
important today is because a man's
liberty interest is at stake. And you
can't allow feelings, emotions, the
things that you think about on an
everyday basis to cause you to make your
decisions. It's easy to make that
logical conclusion. The bad man theory,
somebody did something in the past, then
it's more likely that they would have
done it again. But that's not the law in
this state and that's not the burden
that you were to apply in this case.
This is a very serious burden. You have
to look at this charge individually and
decide if on that day Mr. Perez
committed the crime for which he's been
charged. And as I've said before,
there's no information that can lead you
to this conclusion. So members of the
jury, take your job seriously.
Go back into that room, communicate with
one another. Think about the credibility
of the witnesses that came before you.
Think about the witnesses who had
something to gain and think about the
ones who had something to lose. Think
about the plausibility of the statements
that they made. Think about the
alternative theories.
But I'm confident that at the end of the
day, there's only one conclusion that
you can make, and that is Mr. Perez is
not guilty of possession of cocaine
with the intent to traffic that cocaine.
Thank you for your time. Thank you for
Great. Now, let's quickly recap our
chalkboard tips. First, find clever ways
to humanize your client.
Second, recap the key facts of the case
for the jury.
Third, vary your tone and speed for
emphasis. Fourth, memorize your opening
and closing arguments.
Fifth, use analogy to explain the heavy
burden of reasonable doubt. Sixth,
communicate your theory of the case. And
seventh, restate your conclusion.
Remember, you'll want to watch this
video a few times, keep track of the
chalkboard tips, and begin to
incorporate them into your own presentation.
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