Client Management: Do Not Assume Understanding

In general it is best not to assume that your client understands anything, including the importance of meeting deadlines and following through on commitments.  In most cases it simply is not enough to explain to a client, for example, what interrogatories are and that they must be answered within thirty days.  You will also need to explain to them what that means in terms of the overall scheduling of the timely completion of the Answers.  In order for you and the attorney to draft, review, correct, revise and fill in gaps in the answers, the client must get initial information to you by a date far short of the thirty days. Set dates for completion of each task the client must complete.

It is human nature to delay unpleasant tasks. It is likely that left on their own the clients will treat each deadline as many treat filing taxes. Just as many people rush to the tax preparer on April 14th with a shoebox full of receipts and tax forms, clients will wait until day twenty-nine to start answering interrogatories due on day thirty. When you meet with the client to explain the interrogatories, give them an instruction sheet that repeats your explanation and instructions including the specific dates for completion of any task you assign to them. Write this information down for them before they leave. Again, your office may have or you can develop standardized checklists or forms for this purpose. (Some clients may protest that they came to you to do the work and do not understand why they have to do so much. This can be avoided by a clear explanation during the initial interview with appropriate reminders during the process that they are an essential part of the litigation team with their own role to fill.)

Once the client leaves immediately enter the date for your follow-up reminders to the client on your calendar. Do not assume the client is out there somewhere faithfully doing exactly what you told them to do. Send a reminder in writing and set a date for a follow up telephone call. If you send an email or leave a voice mail message, ask that they respond with an update on the status of their progress so you know they got the message and can make a file note. This seems like a lot work, but much of it can be systematized and it serves several functions which I cover in a later post.

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