The can opener, the opening phrase of the Action Motions 2K10, should be simple, direct and free of convoluted legalese. The opener should "zing." Sensitivity to the presumption of innocence is absolutely essential; refer to your client by name or at least as "the Accused" rather than “the Defendant". Personalize and humanize your client often by using the individual's full name at each opportunity. These sensitivities, together with concurrent sensitivity to terms used to refer to women, minority persons and poor people should be maintained, of course, throughout life -- but especially in the language of motions.