Client suffers from total blindness (recent onset). What would you all suggest in terms of handling written discovery responses and verifications? Is it sufficient for attorney/paralegal to review the responses with client and then have client sign verifications? Or do we need someone like a reader/interpreter who would also need to sign an affidavit that the responses were read to the client correctly. And how would these responses be used at trial? (“Is this your signature?”) -TIA

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It’s simple, you’re the attorney of the client. Even if the client wasn’t blind, and (depending on the jurisdiction) you could sign the verifications on their behalf if it was needed.

For this particular file, pay double the effort to review and make sure that it’s perfect.

I have been to multiple PI firms, for foreign tongue clients, we typically have a double verification: one for client to sign and another for client translator witness (affidavit) — translated verbatim and client affirmed.

For the client to be comfortable, have them bring a relative as witness as well. You don’t want an insecure client during depos, confidence is key. Also make sure to give a final copy to client for their personal records.

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