I recently sat in a meeting with a client regarding ongoing litigation and noticed the gap that exists between lawyers and other professionals when a lawsuit is pending.
Imagine a client that is being sued for millions of dollars regarding a dispute about a construction project gone awry. The plaintiff's complaint is about 30 pages long with over 200 numbered paragraphs full of dollar amounts and references to hundreds of attached pages of exhibits. The client needs to prepare an answer to the plaintiff's complaint. He spent the first weeks/months gathering the information to respond to the complaint and now it needs to be organized and written up. But the client's project team is not composed of lawyers and they don't have experience with drafting answers to complaints. The clients have the information but the lawyers have the drafting experience. What the client needs is direction.
Tip #1: Break the complaint up into sections. Answering a complaint with hundreds of paragraphs could be overwhelming for a client. Like any other task, breaking it into smaller pieces should help. Usually there are natural section breaks in the complaint. The beginning of the complaint consists of general introductory facts about who the parties are and their relationship to one another. After that it gets more specific and if written well it will have headings for each claim with the supporting claims below. Walking a client through the different sections in the claim can make it less intimidating.
