Throughout your representation of client x, you will need to check in with her frequently. If this is going to go to litigation, no matter wronged she feels by crumbum, make sure she understands that once the case hits that squared circle, her story of woe will be in someone elses’ hands. The Judge and Jury will decide what will happen to crumbum. Make sure she understands this. Make sure she knows what is going on with her case, when important deadlines she needs to hit are coming near, and when trial is set. As trial draws near, make sure she continues to understand that trial is a hearing of fact not a hearing on emotions.
The client must understand that litigation means a lot of discovery hearings at court. She must be made to understand that the case rests on the information she gives you. Make this clear to her that this is a working relationship. If she cannot provide the information you need to respond to objections or she changes her story at deposition, you need to know that as well.
By the time you get to trial, you should be able to know whether you can trust your client to follow your instructions. Make sure she understands that she should only answer the questions she is asked if she is called to the stand. She needs to look directly at the attorney asking the questions. She cannot vary her story from what she worked on with the attorney. Anything less puts your case at risk.
The bottom line is know your client’s strength and weaknesses. If you are the least bit unsure about her ability to be on the stand then do your best to work only with the facts of the case.