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The Velvet Hammer™ Podcast
Trial lawyers can be real people, too—and this podcast proves it. The Velvet Hammer™ is back, and this time, Karen Koehler isn’t going it alone. Known for her fearless advocacy, bold storytelling, and, yes, even the occasional backwards dress moment, Karen is teaming up with Mo Hamoudi, a lawyer, poet, and storyteller whose empathy and resilience add a whole new dynamic to the show.
Together, they’re pulling back the curtain on trial law, diving into bold topics, heartfelt stories, and the messy, hilarious moments that make trial lawyers human. This is an unscripted, raw, and fun take on life inside—and outside—the courtroom.
The Velvet Hammer™ Podcast
How to Interview Clients and Win Juries
Episode 32: How to Interview Clients and Win Juries
In this episode of The Velvet Hammer™, Karen Koehler, Mo Hamoudi, and Mike Todd dig into one of the most overlooked skills as a trial lawyer: the client interview. This is not just about filling out intake forms. Karen shares why she spends hours with clients before even asking about the incident and how those conversations create the foundation for damages storytelling.
They explore how to go beyond surface-level questions and reach a place where clients feel seen and understood. Karen explains why juries distrust “perfect” people, how to get ahead of biases, and why embracing flaws and adversity makes for stronger narratives.
This episode is a blueprint for any lawyer who wants to connect deeply with clients and craft stories that resonate with juries.
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Hosted by Karen Koehler and Mo Hamoudi, trial lawyers at Stritmatter Law, a nationally recognized plaintiff personal injury and civil rights law firm based in Washington State.
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Good morning. Good morning, Mike Morning.
Mo Hamoudi :Good to see you, Mike. Good to see you too. Okay, All right. So I had a pretty wonderful experience watching you interview a client, and I thought that we could do an episode focused on teaching lawyers how to interview a client, the importance of the interview and what you're trying to do with it. So, how do you interview clients? What's your approach?
Karen Koehler:Well, first of all, it's not always wonderful.
Mo Hamoudi :Okay.
Karen Koehler:Secondly, it's like what is the purpose of the interview? So what you saw me do was interview a client to get the story and you've seen the damages part. So there's many reasons to interview a client, some people just the old style. And what a lot of people experience is you get in an accident, you go to the lawyer's office, they interview you and then you never see the lawyer again and you get a settlement check are those the types of interviews where they come in and they say what happened?
Mo Hamoudi :I got a car accident, my back hurts and my leg hurts. I have injuries it takes about half an hour and they get that, and they give that to the insurance company and then they settle the case yeah okay, but you talked about and then you know there's a, there's an in-between version where you have to file a lawsuit.
Karen Koehler:So you had that first initial interview and then there's several other touch points. The other side will send interrogatories, questions that you have to answer. So maybe you'll have a law firm where you actually come in or over, zoom, work with, probably, the paralegal. You know what's your name, what schools did you go to, all your employment history, you know all these little details of your life and those are all written down and you have to sign it at the end and then maybe you have your deposition taken by the other side and maybe your attorney prepares you for that and then maybe you have a mediation. Your attorney prepares, but the attorneys often don't come back and talk to the clients, just to talk to the clients. So if you're really lucky, you get a lawyer that talks to you a lot and really wants to get your story. Now why do we want to get their story On a level that's pretty intense? I would say For me it's because that's what drives me to want to even do this job.
Mo Hamoudi :What do you mean by that?
Karen Koehler:I want to know who I'm representing and I want to be able to fight for you, and to do that, I need to feel like I'm connected to you, and to feel like I'm connected to you, I need to be able to see beyond this.
Mo Hamoudi :Okay, so you want to connect to them by getting them to speak about themselves. How are you doing that? How are you connecting with them? You don't know this person really.
Karen Koehler:It's almost more than that. I just don't want to even hear just the words. I want to feel them, I want to see them, I want to absorb everything. It's kind of like what I do with you in this here whereas you know, you just say something and then maybe I don't even. Yeah, that wasn't, that wasn't a good enough answer. I really, really want to know, and I think that's the difference between someone that's doing a job, who's filling out the blanks, and someone that really wants to know, even like I'll ask questions that are maybe not relevant.
Mo Hamoudi :Yeah.
Karen Koehler:But it's because I really want to know what motivates them. What is what? What happened? Not just the details, but how it impacted them, why it happened, how it felt, what the experience was. It happened how it felt what the experience was. Who is this person that we are representing? And so sometimes to do that takes a lot of interviews.
Mo Hamoudi :And now I mean logistically. We've done, for example, two interviews in excess of two hours each. We're going to do a third one and you're going. You're almost in my assessment. You're almost as if you're writing a biography. You're an intended writer, a biography of the person, and you're asking questions dating back to before they were born, and so my question is how is that? You're talking about a feeling, but how is that important for telling a damages story?
Karen Koehler:so like we've spent about four hours with this person and we still haven't talked about the incident yet, right.
Mo Hamoudi :So how is all of what we talked about even related to damages? Yeah, the damages says pain, suffering, inconvenience and economic. How is any of this relevant?
Karen Koehler:Because who are you communicating with ultimately?
Mo Hamoudi :The jury.
Karen Koehler:Or even a federal judge.
Mo Hamoudi :Or a federal judge.
Karen Koehler:But preferably a jury.
Mo Hamoudi :Yeah.
Karen Koehler:And people make snap decisions. They are going to like you or not, quickly, and then you have to overcome the biases. They're going to like you or not quickly, and then you have to overcome the biases. But people also want to connect and they're going to judge you if they can't connect with you, and so I don't want a false narrative or one that is so surface that people can make assumptions. I also want to tell the correct story, and if I don't know that person, I can't tell the correct story. Because when I tell a story, when I'm crafting the story, it's a true story and it's normally written or told. And I write because we have mediation, we have settlement demands we have to send out. It's going to show them why a jury is going to let this person and embrace the story and it's going to explain all the actions of that person.
Karen Koehler:So, for example, let's say that you have a person that had to have I don't know back surgery. Okay, you know, they had herniated discs. Now they have a sixth level fusion, meaning six of those vertebraes on your back, from your neck down somewhere in there. They're connected with rods and plates or potentially they they put like I call it, like they call it, a cage wire cages around them to make them hard and so you can never, you know, maybe you get rid of the pain but you can't move again. So let's say I have that kind of a client. And let's say that client, I say, well, how are you doing? Well, okay, well, do you have much? Do you have much pain? Yeah, I have pain. Well, when's the last time you went to the doctor? Well, you know, a year ago. Okay, what's a jury going to think? They're going to think it must not be too bad. They don't go to a doctor and they're really not in very much pain.
Mo Hamoudi :Okay, so those are the false assumptions and those are somewhat of the biases.
Karen Koehler:But they're not even really false assumptions. Those are logical assumptions. Those are logical assumptions If someone tells you they haven't seen a doctor in a year and they don't really have much pain or can't describe it to you and they're doing okay.
Mo Hamoudi :A logical assumption is they must be doing okay or they're too busy to go to the doctor.
Karen Koehler:They don't have the time. You're too nice and empathetic.
Mo Hamoudi :Okay, well, maybe they don't. They're not the doctor type, they just go I'm gonna live with this okay yeah, but I don't think juries think that way.
Mike Todd:Okay, okay, help me, help me. Well, I think if I saw someone I mean, you know, I've only been on a jury one time but if the if I was on a jury and the person came up and said that you know, an attorney asked them when was the last time you were at the doctor? And and the claim had to do with them saying they've got back pain so bad they can't do their job. Well, if they said they hadn't been to the doctor in a year, I'd go. Gee, that sounds like me and I have pain all the time, but I still go to work. That's what I would think.
Karen Koehler:See, it's not a false assumption. That's you pitting yourself against the jury.
Mike Todd:Now if they said I haven't been to the doctor because I can't afford to go, or I can't make it because I can't leave work I can't afford not to work because that's the only way that I can pay to go to the doctor and so I haven't been able to make it in a year because of this, then that opinion might change. But what Karen was presenting was a person going. Yeah, I haven't been there. I can't remember the last time I went to the doctor, but it hurts so much that I can't do anything. To me that sounds like somebody's lying.
Mo Hamoudi :That's very cynical.
Karen Koehler:Most jurors are cynical Most jurors are cynical.
Mike Todd:Yeah, I'm just saying that's what the other side is going to want to be on the jury for sure. They're going to want people who go. It's the same as when we deal with people who can't understand a large settlement for something. When you ask for a million dollars for someone, they go a million dollars. Are you crazy? I don't believe in people getting a million dollars for anything. Yeah, I don't believe in people getting a million dollars for anything.
Karen Koehler:Yeah, so your initial you were thinking like a lawyer, because most plaintiff lawyers they would blame the jury. False assumption, terrible jury. Yeah, and what I'm looking at is jurors come from all walks of life. There are some that maybe shouldn't be on a jury. We're going to probably get those off, but the rest of them, they're not bad people.
Karen Koehler:they're like members of the community yeah there are members of the care of our neighbors, there's someone else's neighbor, there's someone's mother or child. They are just people in general. And so to say it's a false assumption takes away your burden as a lawyer to make sure that things are packaged properly so people can understand. So the reason that story is so important right Goes back to age old times, where you know that's how we learned through stories. We still learn through stories. We love hearing stories. I mean we still are story driven A story that we can understand, then everything else that you hear, these little bits of data that come in later, fit into that kind of storyline. It makes sense. So as a plaintiff lawyer, my job is to create that and I don't like to say storyline that we're reducing people to stories. But you still have to. The narrative that we have to use to explain it has to be believable. Not just believable, it has to be acceptable and hopefully admirable. You want your client to not honestly be the tragic victim. You want your client to be the hero of their story, because people believe in picking yourself up and keeping on going.
Karen Koehler:There's a lot of shared morality when you look at stories of what we think is great. Look at the movies, Look at movie lines. We don't want to see the person that got hurt and then crumpled up in a ball and, like, disappeared from society and cried a lot and got a big jury verdict. That's not what we want to see. We want to see them disintegrate and then get reborn into a superhero and go conquer the world and kill everybody, even though they have to wear terrible, you know huge masks because their face has been completely obliterated. You know that's what society wants. They want to cheer for the person that can somehow somehow triumph even in the most horrible circumstances, and that's why, you know, strip matters.
Karen Koehler:First huge victory for the young man that became a quadriplegic on a motorcycle was when the therapist or teacher came in and was going to have him spell dog. I don't think he could even nod his head. I can't remember how, oh, he blinked, yeah, he blinked, he could blink when you were at the right letter and a strip minor thought he was going to spell out the word dog, but no, he spelled out the word puppy. It took a long time and the jury was just, you know, in tears because they could see that huge effort from a person that really couldn't move anything. At least they could blink and they knew he understood.
Mo Hamoudi :Okay, so the process you just described is this client getting to a place where they're showing the jury that I am not my injury. I'm more than that. I can beat this. How do you take what you're doing in these interview process long hours? What are you doing there to get them to that place? Understand?
Karen Koehler:well, there's two purposes, right. One is for me to be able to write the narrative in a. So, before you go to trial, you have a. You're mandated by the courts to try to get a case settled. Yeah, try it. You have to go to mediation, so I will write a narrative. I often you.
Karen Koehler:That's something that a lot of people will send out to legal interns, young associates and I have. But then you know, I rewrite them. Sorry, but I do because I'm like, who is this person? Like I don't understand. Why would they come to Seattle from, you know, boston? Why did they make that change? You know how does what? Who is this person? Why did they do these things?
Karen Koehler:It doesn't make sense to me. Like I don't, because if you don't understand them, then you don't understand how the injury has impacted them. You don't understand it. Oh, I was fleeing from an abusive relationship and I came here and then I had just gotten a job you know, I'm just starting up and then this happens to me. Okay, now you see a person that doesn't only have a social network, they're kind of alone. They had a of alone. Why do people do things? You have to understand it to understand the narrative that's going to come out In trial. What you're not going to have your client do is tell you their story. No, you'll have other people from that story come in and tell the story, so you have different elements of that story presented.
Mo Hamoudi :Why would you have other people tell the story? Because so you have different elements of that story presented.
Karen Koehler:Why would you have other people tell the story?
Mike Todd:Because, Do you think that the interview process then is sort of a way of also finding out what you don't want to use?
Karen Koehler:Sure, there's some things. No one's perfect. However, this is the truth. Normally, you want them not to be perfect. You do not want your client to be a perfect person, because no one's going to believe that they're actually telling them the truth.
Mike Todd:Because nobody's really perfect, because nobody's really perfect.
Karen Koehler:That's number one. Number two what people want to see is adversity and overcoming the adversity, and not just because of one you know incident. They want to see how do they do in other incidences. My parents were divorced. I, you know, I didn't realize I was in a depression. I got really bad grades in school, you know. I was kind of lost for a while. I ran in with the wrong people, but then X happened, you know, and I did this. That's a story people are going to appreciate they don't want. Well, yeah, I just took a gap year, right yeah they don't want that.
Karen Koehler:No, they don't. Well, they do want that, because then they're going to cream your client yes um, so everything kind of weaves together.
Karen Koehler:What's important about that mediation letter win or lose is either the what I want the insurance company to know when I write those is how I'm going to win that case from a damages perspective. I want, I want them to know that. Um, because, like, you're not going to, not gonna, you're not gonna get out of this narrative. It's like a taunt. This is a narrative. You can do whatever you want to try to hit that narrative and you're gonna fail. Um, you don't want a weak narrative. No, you don't want a narrative that can be easily attacked.
Karen Koehler:Um, so, for example, let's say that you have an ex spouse. You're really worried about the ex spouse. Um, you have a new spouse and the defense is going to talk to that ex spouse and now, now, you're really worried. No, you want in the narrative to say that you got married, you had this situation there an ex-spouse and then lean into whatever the negative is you want to lean into it. So like, yeah, go ahead and call the ex-spouse, see how that, see how that goes for you we've already laid everything she's going to say out.
Karen Koehler:Yeah, we've talked to her yeah, or him, yeah. So you want a really strong narrative that they can't come out and in fact, what I'll often do is take their worst stuff and I put it, make sure I put it into the narrative with the way that it's going to be presented.
Mo Hamoudi :So the interviews help you embrace truth. And then, by embracing truth and knowing everything, you know all the good and the bad and you get to control the narrative and you're directing the case. It's too simple? Well then, complicate it for us.
Karen Koehler:It's not just the truth, I'm not just seeking the truth.
Mo Hamoudi :Okay, what are you seeking?
Karen Koehler:I'm seeking love.
Mo Hamoudi :Love, mm-hmm. Well, okay, love is complicated.
Karen Koehler:I'm seeking to love my client, okay, and I want to understand how I'm going to do that. There's times when I don't, and that's a problem.
Mo Hamoudi :Yeah.
Karen Koehler:I wish I could. Just if I went back through like there's some that I didn't now, some of them, no, no problem, still may manage to do just fine. But I need to love my client me personally because I feel like if I can love my client, then other people can love my client through me.
Mo Hamoudi :I think that's the first time I've heard you say love. I don't think I've ever heard you use the word love before, have I?
Karen Koehler:I don't think I have. It's a precious word. Yeah, yeah, but I want you know, I want to, I want to, I want to, okay, like. So I'll ask them questions about that. Like, why, why did you do that?
Mo Hamoudi :Yeah.
Karen Koehler:Right.
Mo Hamoudi :Yeah.
Karen Koehler:And you've heard me say love before because you commented on it to one of the clients. I asked the client if they loved X.
Mo Hamoudi :I asked the client if they loved X. I think when I say love I say like you wanting to love. I've never heard you use it in that sense.
Karen Koehler:Yeah, I mean this isn't like the same love I feel for my kids, but it's partially. It's all from the same place. Yeah, I mean there's a lot of differences, right, in types of love, but there is look at, he's all got all puppy dog he's because, you know, mo is a love-based person oh, I know if you hadn't known that, but this is, here's the truth yeah almost all of them. I don't know that. I've never had this experience, certainly not lately. People want to keep talking, they want to keep telling the story.
Mike Todd:Oh yeah.
Karen Koehler:They want to keep coming to have that experience. You know why? Because they feel loved they feel loved, they feel seen, okay, which is kind of almost the same thing in that context.
Mo Hamoudi :I think it is.
Karen Koehler:To be able to be seen is, even if you hate that person, I think is the most validating thing. Yeah.
Mike Todd:I would even say it's more to be understood.
Karen Koehler:Good point, that's a better word.
Mike Todd:I think that whether or not you like someone. If you feel that you're understood, then you can accept whatever else is going on thank you for that lesson.
Mo Hamoudi :That was a good one that was something like how.
