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The astute trial lawyer must always be aware of the jurors' ability to process information and effectively learn from that information. Perhaps this is why trial lawyers have long familiarized themselves with the psychological concepts of primacy and recency—that which a juror hears first and last will be far more memorable than that which has been lost in the middle. Of equal importance is the psychological concept that information that we both see and hear is processed and retained better than that which we hear alone. Studies have repeatedly shown that people recall 65 percent of the information that they have seen and heard after three days, when compared to 10 percent of information that they have only heard.1

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