A couple of jury trials ago when I was preparing for closing argument my sense on the case was defendant had used several nonsense defenses. As I racked my brain for a phrase that would represent  what I believed were nonsense defenses I remembered a Ronald Reagan /Jimmy Carter debate where Reagan used the phrase “There he goes again” to refer to what he believed were nonsense arguments by Carter. While I am not a Reagan fan I like the phrase. This gave birth to what I now call the Ronald Reagan:

Ladies and gentlemen last night when reviewing our trial and thinking of defendant’s arguments [set forth summary of arguments] I was reminded of a Reagan/ Carter debate years ago. In the debate Ronald Reagan used the phrase “There he goes again” to illustrate  Carter arguments Reagan considered  nonsense.

Well ladies and gentlemen we have “There he goes again” arguments in our trial. These arguments don’t make sense to me, and I know you have been paying attention during the  trial, so I believe  the defense arguments don’t make sense to you either. That’s because they are “There he goes again” arguments.

Now you will soon be retiring into the jury room  to discuss the case.  And when you are in the jury room remember the “There he goes again” defense arguments. And remind each other that is a “There he goes again” argument. And we know what to do with  “There he goes again” arguments. Send the “There he goes again” arguments of defense to defeat.

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