If your clients send you a thousand screenshots, a voice memo, three forwarded email chains and a shoebox of printouts, client evidence organization has become your paralegal’s job, at your firm’s expense. The fix is not a better sorting process at the firm. It is a better request at the start, because clients send evidence in exactly the shape you ask for it, and “send me everything you have” has no shape at all.
This article lays out a system that gets clients to do the easy, high-value parts of organization themselves: what to send, in what format, with what description. The firm keeps the parts that require legal judgment. Each section includes wording you can adapt, and the system works whether clients upload through a portal or deliver files another way.
Why do clients send disorganized evidence?
Because the request was disorganized, and because clients reasonably assume more is better. Neither is a character flaw; both are fixable.
- They don’t know what matters. Clients can’t tell which incident is relevant and which is just painful, so they send all of it.
- Volume feels like strength. Many clients believe a bigger pile makes a stronger case.
- Their phone shapes the evidence. Screenshots are the easiest capture method, so that is what arrives.
- They don’t know dates matter. A message with no visible date is a puzzle for whoever builds the chronology.
- Nobody told them the format. Without instructions, every client invents their own system.
How do you ask for evidence by issue?
Have the attorney define the issues first, then request evidence for each issue separately with a date range and a cap on examples. A bounded request gets a bounded, usable response.
For a custody matter, the issue list might cover the actual parenting schedule, communication about the children, school and medical involvement, and any safety concerns. For a contract dispute, it might cover formation, performance and the breach. Each issue then becomes its own request.
Sample issue-based request
Request 3: School involvement, January through June of this year. Please send the clearest examples, up to ten, showing who handled school communication, attended meetings, or managed homework and pickups. Good examples include emails with teachers, school portal messages, report cards you received, and calendar entries. Keep everything else saved on your phone or computer; we may ask for more later.
Notice what the request does: it names the issue, sets the dates, suggests sources and caps the volume, while telling the client to preserve the rest.
What should a client evidence format guide say?
One page, plain language, sent with the first request. It answers the formatting questions before the client invents their own answers.
Template: how to send us evidence
1. Send originals. Upload the actual photo or file from your phone or computer, not a screenshot of it and not a copy sent through a messaging app.
2. For text messages and chats, ask us about exporting the full conversation. Screenshots leave out dates and context.
3. One item, one upload. Don’t combine several photos into one collage or PDF.
4. Don’t edit. No cropping, highlighting, filters or notes on the file itself. Put your notes in the description.
5. Describe each item using the short form we provided.
6. Keep everything. Don’t delete originals after sending them to us.
7. If you can’t find something, tell us. A “can’t find it” answer is useful.
How should clients describe each item?
With a short, fixed set of fields. Call it an evidence card. Consistent descriptions are what let staff sort, date and map items to issues without calling the client about each one.
| Field | What the client writes | Why it matters |
|---|---|---|
| Date and time | When it happened, as best they know | Builds the chronology |
| Who | People involved or shown | Identifies witnesses and parties |
| What it shows | One or two factual sentences | Saves staff a guessing game |
| Source | Whose phone, account or camera it came from | Supports later authentication |
| Issue | Which request it answers | Maps the item to the case theory |
Coach clients to describe what an item shows, not what it proves. “Message from the other parent at 9:40 p.m. saying pickup will be late” is useful. “Proof they never care about the kids” is argument, and it buries the fact the attorney needs.
How do you get messages instead of screenshots?
Ask for exports of the full conversation, and help clients produce them. Exports capture timestamps, senders and surrounding context that screenshots crop out, and they are far easier to review and paginate.
- iPhone: desktop backup-and-export tools can produce spreadsheet exports of iMessage and SMS threads; see exporting iMessages for litigation.
- Android: SMS backup apps can export threads to a structured file.
- WhatsApp: the app’s built-in chat export; see WhatsApp evidence in litigation.
- Facebook and Instagram: the account data download.
- Google Voice: a Google Takeout export.
If a client can’t manage the export, have them bring the phone in. If screenshots are all that exist, ask for complete captures that show the contact name or number at the top and the date dividers, scrolling through the whole exchange rather than isolated messages.
How do you keep the system working after the first batch?
Review the first submission within a day and respond with specific corrections. The first batch is where habits form; correcting the tenth batch is much harder.
- Acknowledge receipt. Confirm what arrived, so the client knows it worked.
- Check it against the guide. Originals or screenshots? Described? Within the date range?
- Send one short correction note. Name what worked and the one or two changes that matter most.
- Ask item-level questions. Tie each clarification to a specific file rather than a general email.
- Update the request list. Mark what is complete, what is partial, and what is still missing.
- Set the next request. Move to the next issue only when the current one is in usable shape.
This is where tooling helps. A system like CourtBriefly keeps each request, its submissions and any follow-up questions attached to the matter, so the whole team sees the same status instead of reconstructing it from inboxes. You can see how intake connects to exhibit preparation on the evidence intake and exhibit page.
What about clients who can’t keep up with the system?
Adjust the method, not the standard. Some clients are overwhelmed, grieving, frightened or simply not comfortable with technology, and a format guide alone won’t carry them.
Separate the story from the evidence
Many clients send evidence as a way of telling their story. Give the story its own channel: ask for a written timeline or narrative in their own words, addressed only to the attorney, and keep it apart from the evidence uploads. Remind them not to share it with anyone else, including friends or family, because communications with the firm should stay confidential. Once the story has somewhere to go, the evidence submissions tend to get leaner and more focused.
Do one request together
A fifteen-minute call or office session where staff walk the client through exporting one conversation and filling in one evidence card often does more than repeated written instructions. After one guided success, most clients can repeat the process alone.
Shrink the ask
If a client is stalled, break the current request into smaller pieces with nearer due dates: one issue, one month, five items. Progress on a small request beats silence on a large one, and it gives the attorney something to work with sooner.
Whatever the adjustment, keep it consistent across the team. Clients notice when one staff member accepts texted screenshots and another asks for originals, and they will default to whichever path is easier.
What should you tell clients not to do?
Be explicit about the boundaries. Clients eager to help can create problems that outlast the case.
Also ask clients not to provoke exchanges to generate evidence. Real problems deserve documentation; manufactured conflict harms the children and tends to show on the record. If organization has already broken down and a large dump has arrived, start with the screenshot triage workflow and use the system above for everything that follows.
