They must be made to feel that something positive has to be done to right a wrong. This requires an active, rather than a passive or namby-pamby approach. It means finding and developing one of the themes that lace through most cases. I will venture to point out some of the themes, psychological problems and damage items that are frequently overlooked but have to be reckoned with on damage issues in such cases. They point the way to many others and underline our obligation to give our clients the benefit of our best and most careful thinking.
Most people have an unconscious, or even conscious aversion to tales of trouble and misery.
It is uncomfortable for them to have to be confronted with unpleasant things. Consequently, the parading and repetition of your client's ills may count against you. Since the Anglo-Saxon traditions of our society are averse to wearing our hearts on our sleeves, it is much better if others describe your client's troubles. Thus, he can remain silent, or at least, understate his difficulties. Lay testimony as to disability is a much better way to present it.