How much detail should you reveal in your opening statement?
Some lawyers fear revealing their defense in the opening statement and allowing the Government to adjust their case based on the opening. That can occur; what I do to prevent that is focus on the facts that I know for sure I can prove in the opening, that the Government cannot dispute. Having a motion hearing, allows a lawyer to give a more detailed opening statement because the testimony is locked in.
I prefer to make as detailed opening statement as I can. I do not believe in the theory of holding back for fear of tipping of the Government for a few reasons; first, the Government, likely knows your theory of defense. Second, when you leave things out, you do not deliver as effective and confident opening statement. The more facts and details you can get into from the start the better. There has been research showing that a jurors begin to decide cases immediately. Most believe that by the time the Closing Statements are delivered, most jurors would know how they are going to vote. It is important to start getting jurors to accept your theory of the case from the start of the trial.