Getting the Complete Story from Your Client

Here's a tip from Ashley Lipson's Guerilla Discovery. To insure you're getting the full story from your client, try asking a question something like the following:

I know that you've told me the truth and I believe you. But we have to prepare for those lying S.O.B.'s on the other side. What kind of lies are they going to tell? Tell me what lying description of the events they are going to tell so I can prepare for them.

Lipson suggests this question for deposition preparation, but it might also be useful during initial client interviews. According to Lipson, it's likely you'll hear some things from your client you didn't know before--things you'll need to know about your client's case before getting in too deep.

Comments

[anon]

Please keep in mind that some clients are excrutiatingly honest, are telling you everything - warts and all -- and have been wronged in just the way they are telling you.

I can't tell you how much time my lawyer wasted trying to find out the "real" story, when he had it. What he didn't want to do, was too lazy to do, was review the detailed, documentary proof I had compiled.

Lawyers have blown really strong cases this way, either being too lazy to read the proof, orlacking the nerve.

Lacking nerve is not favored when your alternative strategy is mediocre as a means to winning, but safe in terms of covering the lawyer's tush, essentially the lawyer's interest over the client's.