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Client interviewing: How to take complete instructions

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 Lawyers Practice Manual NSW

How to take complete instructions

Document Path: • Lawyers Practice Manual NSW : PART A – Legal practice > Client interviewing > Client
interviewing

AUTHOR AND CURRENCY

Original author(s): Dr Colin James BA, BJuris, LLB, GCertPTT, MPhil, PhD Solicitor and Senior Lecturer, ANU
College of Law, Australian National University
Current as at: This chapter reflects the law and practice at 22 January 2016

Commentary

How to take complete instructions

[A.101]

Overview

The legal client interview is a learned skill crucial for most types of legal practice. No two interviews are the same, and lawyers
working directly with clients need to develop their own unique style. Observing experienced interviewers in practice is one of the
best ways to develop one’s own style, but it is important also to understand the theory behind best practice interviewing technique.

This chapter refers primarily to client interviews in a client-centred practice and especially to the first interview of a new client. It is
important to understand the goals of the interview, the professional attitudes and appropriate interview techniques. Lawyers also
need to be aware of their professional ethical responsibilities, to recognise issues which often arise in legal interviews, and to follow
appropriate steps before, during and after the interview. The chapter also suggests strategies for interviewing clients with a hearing
disability and suggestions for working with a sign-language interpreter.
[A.102]

The goals of the client interview

On meeting a client for the first time it is crucial to establish a trusting and professional relationship. This is achieved best if the
lawyer is relaxed, caring and sincere, rather than overly formal or forcing a kind of professional impression the lawyer does not
actually feel. Many clients will trust and relate better to a lawyer who comes across as genuine and unpretentious, rather than a
lawyer who is knowledgeable but comes across as arrogant. Once initiated, the professional relationship will help the client to relax
and to have confidence in the lawyer and the process involved in obtaining legal help.

The client may have a biased or erroneous view of the law and lawyers, based on a negative experience in the past or on aspects
of popular culture and beliefs. Such biases are not uncommon but can be overcome by the lawyer successfully establishing a
professional relationship with the client and building trust and confidence using strategies discussed below.

Sometimes clients are very nervous at the initial interview due to anxiety over their case, including embarrassment or fear of the
consequences. Often you will be the first person they have spoken to about the problem, and often you will be the client’s “last
resort” in trying to resolve the issue. The lawyer needs to take steps to reduce the client’s anxiety to help the client communicate,
since stress can reduce a client’s ability to recall aspects of the case, and to remember any advice given or directions about what to
do next. Therefore, it is important for the lawyer to develop sufficient emotional intelligence to identify and understand the personal
significance to the client of certain events and situations. Often a client’s concerns will include non-legal issues or problems that do
not readily involve a legal answer. The lawyer should be careful not to dismiss such issues, but to acknowledge them and suggest
an appropriate referral or other way to manage the situation.

The goals of the client in a legal interview may not be the same as the goals of the lawyer. Primarily, after beginning a professional
relationship with the client, the lawyer should identify the client’s goals, to clarify them if necessary and to communicate to the client
the nature, capacity and limitations of the help the lawyer can provide. Therefore, it is the lawyer who should control the interview,
even in a client-centred practice, to ensure the needs of both parties are met as much as possible.

Keeping control of the interview, clarifying the legal needs of the client and advising the nature and limitations of assistance
available, while remaining sensitised to the client’s personal situation sounds complicated, but it is part of developing a professional
Tuesday, 22 March, 2016 at 12:28 EST Page 1
 Lawyers Practice Manual NSW

lawyer-client relationship.

The lawyer needs to identify the legal issues from the client’s narrative and to obtain as much relevant detail as possible using
direct questions in the time available and without causing exhaustion or distress. The legal issues and the relevant details may not
accord with the client’s priorities, which should not be ignored or dismissed. The lawyer may need to dedicate time during the
interview to discuss non-legal issues and appropriate referrals if necessary.

The lawyer needs to provide clear advice on the law concerning the legal issues identified, the options available to the client with
the likely outcomes, and the likely costs involved in the lawyer’s opinion. In complex matters, a second or third appointment may be
necessary before such full advice can be given, and in some cases as mentioned above it should be delivered or confirmed in
writing.

In addition, the lawyer has to decide the level of service best suited to the client’s needs. It may be that one advice session during
the interview is sufficient. At the other extreme, the client may have a case that merits further investigation, researching the facts
and the law, and possible representation in court.

Time is of the essence. Ideally, the first interview should be no more than one hour and maybe as little as 20 minutes. Interviews
that go too long are usually the result of the lawyer losing control and failing to manage the dialogue in an objective way to meet the
legal needs of the client. Some clients will try to dominate the meeting and use it to vent their emotions or give many examples of
their case, such as the extent of their suffering or loss, or the behaviour of the other party. It may be necessary for a lawyer to be
assertive and with compassion, provide clear but respectful indicators when it is time to wind up the interview. In any case, the
lawyer should ensure the client leaves the interview knowing the next steps to be taken (if any) to progress the case. The lawyer
may need to write up (or dictate) notes from the interview, conduct legal research, write a letter, contact witnesses, commence
negotiations or initiate an action. The client may need to gather documents, follow up a referral, obtain contact details of witnesses
or gather financial records or other evidence.

The lawyer should ensure the client has understood the advice, any options, and the limitations of the service offered. This check
back can be done at the end of the interview as a way of concluding the interview, or ideally, it can be done in writing with a
subsequent letter of advice that summarises the content of the interview. If the matter is to be ongoing, it is advisable to send the
client two copies of the letter confirming the advice and request the client to sign and return one copy, together with a signed
retainer and cost agreement if appropriate.

Finally, it is difficult to overstate the importance of the initial interview. The quality of the professional relationship established at that
time is crucial to the client’s experience of what happens in the life of the case, including the client’s attitude to billing, to the
reputation of the lawyer and the law firm, and to the client’s overall satisfaction with the legal help, regardless of the outcome of the
case.
[A.103]

The interview room

Ideally, initial interviews of clients should be conducted in a room dedicated and prepared for client interviews, not in the lawyer’s
office. A first interview in the lawyer’s office may be intimidating and/or distracting for the client; there may also be files or notes
visible to the client which could breach confidentiality and the interview may be disturbed by incoming calls or messages.

The interview room should be clean, with basic but comfortable furniture, keeping in mind that many clients are anxious at the first
interview. As well, overly luxurious surroundings may intimidate or distract the client who may worry about the likely costs. Both
lawyer and client should be seated at the same height. The lawyer will need a desk to write on, but unless there are security
concerns it is preferable not to sit with the desk as a barrier to communication between lawyer and client. The room should have a
door for confidentiality. A well-equipped interview room will have a distress-signal button discreetly placed under the desktop for the
lawyer to use if help is required. Preparation should also include drinking water and note paper for the client to use, and tissues
discretely placed. Offering tea or coffee may help an anxious client to relax and can facilitate better communication.

The lawyer should dedicate at least 20 minutes for the initial interview and ideally not more than one hour. Inward telephone calls or
other interruptions should be prevented, although a telephone and computer in the room may help to gather information and assist
with advice or referrals.

The lawyer will have to ensure a conflict check was done prior to the interview, and that copies of all documents and relevant
correspondence have been previewed and are at hand for the interview. Finally, the lawyer should be informed, or be sensitive to
the possibility, of whether the client has special needs such as a disability or other concerns which may hinder communication or
otherwise impact on the interview process. To that end, the lawyer needs to keep an open mind and be able to respond
appropriately to the needs of this client, rather than adhere to rigid office practices, no matter how well-intentioned. Similarly,
support staff will be trained in client-focused behaviours and able to respond appropriately to individual client needs.

Tuesday, 22 March, 2016 at 12:28 EST Page 2

 Lawyers Practice Manual NSW

[A.104]

Listening to the whole story

Lawyers are generally not trained to listen, yet the ability to listen deeply is a paramount skill, essential to finding out as much as
possible about the client’s case in the shortest time. Listening at a deep level means hearing the facts but also interpreting them
through the client's tone of voice, body language and other non-verbal cues.

To develop this skill, lawyers need to be aware of how their own preconceptions, their values, beliefs and attitudes, can affect their
interpretation of the client’s case. It is important to first understand the case from the client’s point of view in order to recognise the
client’s priorities and motivation. Then it will be possible to give advice in ways the client will better understand and more likely to
accept.

It is important to get all the relevant facts. Lawyers are expected to know what is relevant and what is not, and to have sufficient
communication skills to guide the interview so the client releases the information that will allow a sufficient legal understanding of
the case, without feeling the human and personal implications of the events have been ignored or dismissed. Unless the client tells
you the whole story, the client's interests could suffer. The client will communicate best if she/he knows the lawyer is listening and
understanding the narrative.

First impressions count. So it is important to conduct legal interviews in a comfortable, pleasant environment. Sometimes clients will
be emotional so it is good to have a jug of water and glasses nearby and tissues handy, but not obviously so. Ideally, the client
should also be provided with pen and paper in case they want to draw a picture (eg of complicated relationships, or of how a motor
accident happened) or to write notes of the advice or referral details.

After introductions, put the client at ease by briefly describing the nature of the legal service including any known limitations so the
client is not under a false belief, and assure the client of the confidentiality of everything discussed. Then invite the client to relate
their legal problem and listen without interruption and without writing. Pay close attention, and listen to the client. Keep eye contact
and perhaps give occasional supportive phrases to encourage the client to continue.
[A.105]

Active listening

"Active listening" means conveying to the client that the lawyer not only understands the facts, but also the client's feelings.The
lawyer does not need to agree with the client’s choices or actions to have empathy for their situation. Much human communication
is non-verbal and most people know if someone is actively listening to them or not.

Most clients are anxious at the initial interview. Often their fears involve not being taken seriously, not being understood, not being
able to afford the legal help, and ultimately of losing the case. Such anxieties cause some clients to procrastinate and delay, and
they seek legal help too late for effective legal intervention or just before a deadline for action such as filing a document at court. In
those cases the lawyer needs to think carefully, consult an experienced supervisor if necessary, and give considered advice about
the action to take, the likely costs involved, and the consequences of delaying further.

Avoid listening only for the legally relevant parts of the narrative. The professional relationship is built on trust. It is important for
trust to develop quickly, so the client needs to know that the lawyer takes seriously the client’s emphases, priorities and meaning of
the events. Only then will the client believe the lawyer really understands.

It is unwise to assume that, because the client is prepared to see you and pay your fee, the client also trusts you. If you are listening
"actively" you will show the client that you understand the problem at the practical and emotional levels. This will increase the
client's trust and confidence in you and may encourage further important disclosures.
[A.106]

Open questions

Open questions invite the client to say what they want, using their own priorities. Closed questions invite a yes or no answer, or
indicate a specific short response. Lawyers should avoid closed questions, except for later in the professional relationship when
specific information is required, such as in drafting an affidavit or completing a court document.

At the beginning of an interview, particularly with a new client, an open question such as "What can I do for you?" works well
because it sets no agenda and suggests no structure. Sometimes, the client will speak at length and the lawyer will need to decide
when and how to interrupt, depending on the nature of the problem and the nature of the legal service. Other times, the client will be
anxious, afraid or otherwise distressed, and might need additional questions in order to help them talk about their problem.

Some clients, especially young people, people with disabilities, traumatised clients or clients from a different cultural background to

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 Lawyers Practice Manual NSW

the lawyer may need a slower and more careful approach to develop enough trust and confidence in the lawyer for them to speak
about their problem. Lawyers need to develop their emotional intelligence to be able to interpret how the client feels as the interview
proceeds. Ignoring the client’s emotional shifts in the initial interview will slow the development of trust and risk damaging the
professional relationship before it has fully developed.
[A.107]

Structuring the interview

Good interviews are based on a structure which can be varied to suit the circumstances in each case. As every client, lawyer, legal
service and nature of the case is different, every interview will be unique. The goal is to develop a case theory which is grounded in
the priorities of the client, and composed of the facts and the law in each case. The the following is a good model for an initial legal
advice interview that can be changed to suit different situations.

Stage 1 After introductions, a brief description of the service and assurance of confidentiality, allow the client to speak, stating the
reason for his/her visit without interrupting or taking notes.

Ensure the client is comfortable. Use open questions, focus attention on the client, listen deeply, try not to interrupt and don’t
take notes. This stage may take 5 or 15 minutes, occasionally longer.

Stage 2 Summarise the problem and ask the client questions, to "fill the gaps" from a legal perspective and record notes of the
background, circumstances, and what the client wants.

Interrupt the client in a respectful way if they are still speaking after about 20 minutes by saying something like: "I’m sorry,
can I interrupt you for a moment. I need to clarify a few details, so I can decide the advice". Then ask questions and take
brief notes as required. Does the client have any letters or documents relevant to the case? Has the client attempted to settle
the dispute? Now may be a time to take copies of documents, clarify apparent contradictions, gaps in the story or confusions,
and begin to mentally develop a case theory.

Stage 3 Give feedback on the client's situation so the client is confident the lawyer understands the problem and what the client
wants.

Confirm the client’s narrative in summary form, including their issue, incident or problem and what the client is seeking from
the legal service.

Stage 4 Give legal advice to the client, including the relevant law, the limitation period, if any, the possible remedies or available
options for the client to consider, the legal merit and possible costs for each option, and in some cases, advice on the best option
for this case.

Advise the client, including whether representation, negotiation, mediation, legal research, referrals or other ongoing
assistance is appropriate, and the likely costs if relevant. Here the lawyer may continue to engage interactively with the client
to find out more information such as financial circumstances or alternative accommodation possibilities, as their personal
circumstances might make some remedies or interim measures not appropriate. Now may be a time to complete forms and
draft documents or correspondence.

Stage 5 Next steps to take, if necessary, by the client and by the lawyer.

Clarify what will happen next including referrals, court appearances, references, counselling, witness interviews, negotiations
with other parties, letters to be sent, documents to draft, consider an application for legal aid, and a timeline of actions to be
diarised, as well as a date of next appointment if appropriate.

Clients need coherent advice about the choices they have, and that includes advice about which of the alternatives is most likely to
be of help in their personal circumstances and priorities. Indeed, a lawyer has a positive duty to act or advise the client, and that
duty may include a duty to recommend a particular course of action. However, it is still the client's decision to accept or reject the
lawyer’s advice, and the lawyer must accept that decision, noting on the file the reasons for the lawyer’s advice and the client's
contrary perspective.
[A.108]

Avoiding a premature conclusion

It is crucial for the lawyer to hear the client out, in full, which is best done with active listening strategies as described above.
Lawyers who attempt to cut short a sequential narrative do so at their peril. With experience it is possible to develop a case theory
at speed, particularly with a client already known to the lawyer, but no two cases are identical and the "heard it all before" reaction
should be consciously set aside while the client explains in detail what happened and what they want.

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 Lawyers Practice Manual NSW

[A.109]

The client's motivation

Active listening helps the lawyer to understand the motivation for the client’s behaviour. The client might state their motivation
directly or it may be suggested within details of the case. The lawyer needs to understand the client’s motivation in order to have
empathy for the client, whether or not the lawyer personally agrees with the client’s decisions or actions in the past. In some cases,
the client may have a mental health problem which may or may not be apparent during the interview. Difficulty in understanding the
client’s motivation may indicate the client has a mental health issue. The lawyer should not be presumptuous however as the client
might simply have difficulty communicating or might be affected by anxiety.
[A.110]

Client reluctance

Some clients are reluctant to talk regardless of the skills adopted by the interviewing lawyer. The client may feel the problem should
be kept "in the family"; that certain ideas are offensive and cannot be aired or not aired before a member of the opposite sex; that
the lawyer is too young or too old to understand. Sometimes the client will be embarrassed or shamed due to the sexual or violent
nature of the facts, or that she/he has been "conned" and is not willing to disclose the fact.

There are many signs of reluctance, for example the client may suddenly change the topic or insist that a particular event is
insignificant, the client may flush or become unexpectedly aggressive, or simply hesitate in his/her speech.The lawyer should again
exercise emotional intelligence, proceed with firmness but with sensitivity and respect for the client’s situation , reminding them of
the confidentiality of the professional relationship and explain that proper advice can only be given if the lawyer knows the full story,
even if it is sensitive or embarrassing. If the client's reluctance continues and if other lawyers are available, the lawyer could try
asking if the client would prefer another lawyer (eg older or of different gender) to continue the interview. Sometimes a support
person, such as a relative or a social worker present in the room may help the client overcome reluctance. Sometimes the
reluctance may be caused by the presence of a third person, and the lawyer may decide to suggest that person leave the room for
a short time.

In any case, failure to explore sensitive areas properly risks proceeding with an underprepared case, and, after the interview, the
lawyer should record any reluctance by the client that was apparent and the lawyer’s attempts to overcome it.
[A.111]

Dishonest or misleading client

If the lawyer suspects the client is being dishonest or misleading during the interview, the lawyer should put that suspicion to the
client as soon as possible in a respectful way. For example "You say (X) however earlier you told me (Y). I’m feeling a little
confused so can you explain it to me please?" or "You say you were at home on that evening however the statements from the two
witnesses say you were in the hotel. Could you be mistaken about the date?"

Sometimes the apparent dishonesty results from miscommunication, a misunderstanding, a genuinely poor memory or from
defensiveness and embarrassment. If the lawyer thinks the later is the case, then the best response is to assure the client, as
above, and clarify the situation as soon as possible. In some cases, the lawyer might decide the level of the client’s dishonesty may
be for "appearances" and is not so significant as to warrant probing for clarification.

However if the dishonesty is significant, or an apparently deliberate attempt to mislead, the lawyer should act as soon as possible
by respectfully and carefully confronting the client with the evidence or reasons for thinking the deceit has occurred.

Where the client persists in apparent deliberate dishonesty during the interview, the lawyer should move to terminate the interview
and advise the client a professional relationship can only be built on trust which is apparently absent in this case. This is a decision
for the lawyer to make on ethical grounds. The lawyer is free to refer the client to other lawyers for legal assistance.

A lawyer’s reputation is crucial for their professional identity. A lawyer’s failure to act on dishonesty by the client as soon as possible
makes any later action by the lawyer more difficult and the delay difficult to explain. If the lawyer continues to ignore the dishonesty,
events could easily and quickly develop where the lawyer feels compromised, or worse, actually becomes compromised, their
reputation may be damaged and in litigation they may be accused of misleading the court.
[A.112]

Completing the instruction sheet

Every client interview should be recorded by completing an instruction sheet or similar document. Ideally, lawyers do this after the
interview using the notes made during the interview, when the lawyer’s attention should be wholly on the client and not on

Tuesday, 22 March, 2016 at 12:28 EST Page 5

 Lawyers Practice Manual NSW

completing forms. Some legal services have paralegals who obtain the client’s personal details prior to the interview, check to see if
there is a conflict, and obtain a brief description of the nature of the client’s problem. If there is a conflict, the paralegal would inform
the client of the conflict and arrange a referral to another lawyer.

The instruction sheet should include full name and contact details of the client, the name and contact details of the other party, as
well as their lawyer and any witnesses. Also included should be the background to the case, the details of the relevant events
including dates and names of individuals, the client’s instructions – meaning what the client wants – and the advice given by the
lawyer at the interview, including advice on limitation dates.

If the matter is one for ongoing assistance, a file needs to be prepared containing the instruction sheet together with copies of any
relevant documents taken during the interview. The relevant dates, including deadlines for filing documents, appearing in court and
other limitation dates, need to be entered in the lawyer’s diary and the main diary of the practice.

Ideally the lawyer would use a standardised instruction sheet to cover as many eventualities as possible although not all of the
information will be pertinent at a first interview. When a particular point in a form is inapplicable, the lawyer should strike it out with
an initial rather than leave a blank space.

It is advisable in every case to note whether or not there is a limitation date or time limit of some sort, and if so, record on the
instruction sheet that the client has been advised about it.
[A.113]

Competence to accept instructions

At some stage during or after the interview the lawyer may need to decide whether or not to "accept" the client’s instructions, to
provide ongoing assistance and open a file. A lawyer has no duty to accept instructions from a client, however a barrister may be
obliged to accept instructions from a lawyer on a client’s behalf in certain situations. A lawyer may accept instructions only in
respect of work in which the lawyer has competence, that is the necessary skills and resources to carry out competently. In
accepting work, the lawyer is "holding out" that she/he is competent, and could be liable for incompetence under the misleading
conduct provisions of the Australian Consumer Law (ACL) as set out in Sch 2 of the Competition and Consumer Act 2010.
Section 34 "Misleading conduct as to the nature etc. of services" in the ACL, states:
A person must not, in trade or commerce, engage in conduct that is liable to mislead the public as to the nature, the
characteristics, the suitability for their purpose or the quantity of any services.

Note: A pecuniary penalty may be imposed for a contravention of this section.

The ACL also applies in New South Wales. See s 28 "Application of Australian Consumer Law" of the Fair Trading Act 1987, which
states:
(1) The Australian Consumer Law text, as in force from time to time:
(a) applies as a law of this jurisdiction, and
(b) as so applying may be referred to as the Australian Consumer Law (NSW), and
(c) as so applying is a part of this Act.

(2) This section has effect subject to sections 29, 30 and 31.

A lawyer may also be liable for breach of an implied condition of competence under the contract with the client. Therefore, a lawyer
should refuse to accept a client’s ongoing instructions where the complexity of the matter is beyond his or her capacity.

A dissatisfied client may complain to the Office of the Legal Services Commissioner (OLSC), the Law Society of New South Wales
or the New South Wales Bar Association (The Bar Council) – or equivalent in other states or territories – that a solicitor or barrister
has shown "unsatisfactory professional conduct" (ss 296-299 of the Legal Profession Uniform Law (NSW)).

A lawyer should not hesitate to seek guidance from a senior colleague or from their state or regional Law Society, or to refer a
matter to a senior colleague or other practitioner if they have doubts about the necessary skills and resources to act competently in
a case.
[A.114]

Authority to act and obtain information

A client authority is a document signed by the client which evidences the legal professional relationship and the authority for a
lawyer to act for a client. An example is a request for a medical report about a client. A lawyer can only obtain such information from
third parties such as a doctor with the client's consent in writing. The "authority to act and receive information" can be combined in
one document, and it should bear a recent date.
Tuesday, 22 March, 2016 at 12:28 EST Page 6
 Lawyers Practice Manual NSW

Ideally, an authority to obtain information should be addressed specifically to the supplier of the information rather than "to whom it
may concern". In the case of medical reports, the information should not be provided unless the request is an original document
signed by the client.
Open a client file
A lawyer must open a file in the name of the client as soon as practicable after an interview where the lawyer agreed to provide
legal services to the client. The file should contain at least the full name and address of the person, the date of the initial interview,
the background of the case and a short description of the services which the practitioner has agreed to provide. The file should
contain and highlight any important dates, such as a limitation date, which should be included in the office diary. The lawyer should
also enter the client’s details in a file register. The file and the register should be kept for at least seven years after the date of the
last entry.
[A.115]

Terms of engagement

As soon as practicable after interviewing a new client for whom the lawyer will continue to act, the lawyer should send to the client a
"Terms of Engagement" letter which includes a summary of the background to the case, the client’s instructions and the services
the lawyer has agreed to provide.
[A.116]

Costs agreement

As soon as practicable after interviewing a new client for whom the lawyer will continue to act, the lawyer should send to the client a
"Costs Agreement" which is an offer inviting the client to agree to pay the lawyer an agreed amount or at an agreed rate for the
agreed services to be provided by the lawyer.

The Costs Agreement should include the date, a brief description of the legal services proposed by the lawyer for the client, a
description of how the client can accept the offer and how the money can be paid, and of how either party can terminate the
agreement, as well as information about the retention of documents and the confidentiality of the client’s information.
[A.117]

Proofs of evidence

The lawyer should draft a proof of evidence as soon as practicable after obtaining full instructions from the client. A proof of
evidence is a full and complete statement of the factual history of the matter from the client’s perspective. The document should be
dated, signed by the client and witnessed, and the client should be provided with a copy.

Other proofs of evidence should be obtained from each witness willing to support the client’s case. Those proofs of evidence should
also be dated, signed by the person and witnessed.

The proofs of evidence should enable the lawyer to provide confident advice to the client about the merit of the case and the nature
of any weaknesses that need to be addressed in preparation for negotiation, mediation or a trial. A proof of evidence will also
enable the lawyer to advise the client appropriately if the client or a witness seeks to vary their evidence at a later stage.

Tuesday, 22 March, 2016 at 12:28 EST Page 7

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