Our client is the most important element of a personal injury case. As we discussed in “Characteristics of the Personal Injury Plaintiff/Hero” a quality plaintiff is true to life, without pretense, and honest. When we present the case to the jury we must intellectually and emotionally understand our client. This allows us to sincerely convey the essence of our client and the nature of her injury.

The first step in being able to do this is to know our client. This begins at the first meeting. Here it is essential to listen. Lawyers have a tendency to do the talking rather then the listening. Listening sends a message to our client we care. Listening allows us to grasp the facts from our client’s perspective. Listening gives our client confidence, as it is human nature to think one who listens is intelligent.

I  meet with my client at  the first meeting when she signs the fee agreement.  I get the facts and feelings on: education, family and employment background; mechanism of injury; detailed description of injury; initial pain and disability components of injury; impact of injury on activities;  impact of injury on employment; medical providers; and, insurance information. Next  we agree on a plan of action.  The client will attack her injury through medical treatment. I will take the burden of dealing with her insurer and third party insurer. In this way we begin our bond.

At subsequent steps in the case, I meet with my client. We do the interrogatories together. We set forth the facts in power language using nouns and verbs. We eliminate modifiers-adjectives and adverbs- that suck the blood out of the English language. We continue to bond. I internalize the case deeper into my conscious and subconscious mind.

Prior to my client’s deposition we meet again with emphasis on the on plot aspects of the case: honest true to life presentation of background, mechanism of injury, injury, attempt to dig out of injury through treatment, and impact of injury. This includes facts and feelings on economic loss, disability (range of motion and strength deficits), impact on activities, and pain. We discuss relating naturally with the defense lawyer with candor and decency. In this way the defense recognizes the jury will like my client. (This maximizes settlement value).

In all client meetings I am focused only on my client. I come to know my client. This allows us to form a solid attorney client bond and trust. This allows us to communicate at our highest level with comfort and ease . This allows us to get into our emotional unconscious minds so jurors have a high likelihood of relating to us with their emotional unconscious minds.

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