S4 Eps 18: Leigh Lewis Interview

Speaker A: Welcome back to another edition of the Dirty Verdict podcast. I'm one of your hosts, Peter Taft, joined, as always by Kyle Herbert. And he's waving for anyone who's, uh, only listening. So the, um, we're. We're debuting a new format, which is the remote podcast format on Riverside, which, uh, we will let you know after today if we recommend it or not. But it comes highly recommended. We've got our crack producer, Josh Bellen, um, behind the scenes coordinating all this, and we'll edit it and make it. Kyle. Make Kyle look like Richard Gere circa 1982. When this is all set.

Speaker B: Officer and a gentleman Richard Gear, please.

Speaker A: That's right.

Speaker B: Uh, not American Gigolo.

Speaker A: Yeah, that was the one I was thinking. Okay.

Speaker B: Oh, really?

Speaker A: So we're joined by Lee Lewis this week. Lee, thanks for joining us.

Speaker C: Thanks for having me. I appreciate you guys asking me to join.

Speaker B: Hey, Lee, how are you?

Speaker C: I mean, awesome. How are you? Good.

Speaker B: Fantastic.

Speaker A: So, Lee, Lee. Up until about two weeks ago, Lee was a very accomplished insurance defense lawyer at Walters, Polito and Crane. And so probably, um, wouldn't have come on our little show up until recently when she flipped and now joined the ranks of Como Mediation as a full time mediator.

Speaker B: Boom.

Speaker C: That is correct. For one, I was never asked to be on this show until I joined Como Mediation. Um, I mean, I feel like even before I was on the defense side, I had friends on both sides of the V. I would have been happy to have come in. I don't know what you guys would ask me. That's always a little scary. But.

Speaker B: Well, some people make this mistake. Uh, they think they haven't been invited because they're not important enough, but the reality is actually true. We just figured you'd probably say no, and we didn't want to embarrass ourselves, so we didn't extend the invitation.

Speaker C: Fair?

Speaker A: Fair.

Speaker C: It's the fear of rejection. I mean, just like you're. Just like when you're teenagers, you know.

Speaker B: Dave, you want to go to the prom with me or Peter?

Speaker C: Yes, both. I want to go to prom with both of y'.

Speaker B: All. Okay.

Speaker A: Uh, yeah. So it's been, it's been challenged for me to get insurance defense lawyers on, but I do have a couple coming as well. So. Um, but who.

Speaker B: Who's coming on that does insurance defense?

Speaker A: You have to. You have to read your text. Kyle, um, know that I want to spoil the surprise, but they're cool.

Speaker B: Like Christmas.

Speaker A: Yeah, they're cool. You just show up. Kyle just shows up, says, where do I Go and, and. And then turns on the talent. So, um, yeah, so Lee, um. Yeah, so obviously I mediated with Lee and I'm sure Kyle, you had cases with Lee back in up until two weeks ago. Um, but she's made the decision to, to switch over to do full time mediation. And she's affiliated with our group, Coma Mediation. So we're now up to four on our the term of artist panel. Our panel members are four. Me, Danielle Lee Lewis and Angela Wood.

Speaker B: So with an emphasis on pain.

Speaker A: Yeah, that's right. So you can find us@, uh, comediation.com where you can see all of our calendars and book of mediation. It's very easy. You don't have to call around and get dates and then lose dates and all that kind of stuff. You can do it all with a calendar and uh. So, um, so Lee, um. What? Well, let's just start your background story. You are originally from Midland, Texas, is that right?

Speaker C: That is correct. Sarah was born and raised in Midland, Texas. I went to Midland Lee, but my sister, she also went to Midland Lee married a guy from Midland High. So between the two of us, we know a lot of the section of Midland Lee Midland High that graduated between 1996 and 2002.

Speaker B: Um, are you friends with Cedric Benson?

Speaker C: My sister was.

Speaker B: Yeah. He's awesome.

Speaker A: Rest in peace.

Speaker C: Yes.

Speaker B: Ah.

Speaker A: So. And then your father, was he a lawyer?

Speaker C: Yeah, he's actually still a lawyer. Um, he does oil and gas work and is kind of a jack of all trades. So he doesn't live in Midland anymore, but his firm still exists there. And, uh, he still has some clients that he does some work for. In fact, he got to argue in front of the Texas Court of Appeals just last year.

Speaker B: Cool.

Speaker A: Which one? On some oil and gas obscure rule against perpetuities or something.

Speaker C: Things that made no sense to me. Yes. Like the things that he knows versus the things that I know are like two Aardvin diagram never comes together. Like our law experiences are completely different.

Speaker A: Got it.

Speaker B: Where does he live now?

Speaker C: He lives in Burnett.

Speaker A: There you go. Home of Camp Long. Burn it.

Speaker C: Can't you learn it?

Speaker A: Yep. So semi retired, I guess.

Speaker C: Semi retired. I think he would like to retire, but I think he's still got some of those clients that he just can't quit, you know?

Speaker A: Yeah, it's. I mean, I don't. There's no reason to keep. Keep going. My dad's still working.

Speaker C: Keeps him occupied, so it keeps him happy and keeps him busy and so that's good.

Speaker B: What'd you do after M. Midland Lee.

Speaker C: So I went to McMurray University in beautiful Abilene, Texas. Um, and then I figured out I was going to graduate when I was 20 years old. And I was like, well, what the crap am I supposed to do at 20? So, um, for reasons unbeknownst, were you

Speaker B: just advanced and got through McMurray super fast, or is McMurray like, super easy?

Speaker C: These are excellent questions. I, um, have an August birthday, so I started when I was 17, and then, um, I started college with a bunch of college credits already from high school, and so just ended up that I was able to get done early. Um, but I didn't. Wasn't mature enough to be able to do anything. So it's like, well, I guess I got to go to more school. And somehow I got into Duke. So I got into Duke University and got, uh, my master's in environmental management. And so while I was there doing that, my dad's like, what are you going to do when you graduate from Duke? And I was like, I don't know. I guess be an environmental consultant. He was like, why don't you take a law school class and see what happens? So I took a law school class at unc. Um, environmental law. Shocker. Uh, I really liked it. I got an A minus. And, um, he's like, okay, well, let's take the lsat. Did. I can't remember. I did okay on lsat. Um, so that worked out. So then I was an environmental consultant in Austin for a year and then got into UT Law, so why the hell not? So then I ended up at UT Law, and then I moved to Houston, and I've been here ever since.

Speaker B: Nice.

Speaker A: So you must have done okay on the lsat, because, uh, Kyle and I, I think, no offense to our schools we went to, but we probably would have preferred University of Texas if they would have let us continue the dream.

Speaker C: I. I think I probably did okay. But I also think it was. I think it was also the Duke on my resume. And I'm pretty sure the only reason I got into Duke was because they were looking for a redneck. I mean, I'm pretty sure that they were just like, you know, the words to country western music. We've never had anyone like you in our environmental program, and I think I just kind of snuck on in there. It's just been like, good luck. Honestly, I think all my stuff has been pretty good luck.

Speaker B: Did you enjoy your time in, uh, in Austin in law school?

Speaker A: Yes.

Speaker C: My husband constantly wants to move back to Austin. I'm like, it's not going to be like, when we were in law school. He was not in law school. But, you know, like, you're in school, you have a ton of friends.

Speaker A: You can.

Speaker C: You know, you live cheap. There's always, like, free things to go and drink. I'm like, it's not like that anymore. Now we're old, and we had a full year in Houston.

Speaker B: I had a, uh, bachelor party in Austin that lasted, like, four days. And at the end of it, I told my friends. I was like, I really miss Austin. Like, I want to move back, like, really, really bad. Like, I'm homesick for Austin. Uh, and they were like, no, you like drinking in the afternoon with your friends. That's not what Austin would be if you were an adult as a lawyer living there. And I think there's a lot of truth to that.

Speaker C: I think, though my old firm did have an Austin office, and they all really loved it out there. I think it's definitely. It's definitely doable. I just don't think it would have been the same for me. And for the life of me, I could not find a job in Austin, Texas, when I graduated from law school, because please know that if I would have, I would have stayed. But all my job offers there were, like, working at TCEQ or something, which would have been awesome, but I wouldn't have made any money, so I wouldn't have been able to do anything anyway. So there's that.

Speaker B: But to be fair, you only would have. Need needed to have made enough money to, like, have a small house and a boat and football tickets, and then that your ambition would cap out right there.

Speaker C: Yeah, that's probably true. And we already had a boat. My dad bought my. I don't think he was probably, like, leading you some of this. My dad lives on a lake, and so he's really into BO which makes sense because we lived in Midland, so where there's no water. M. But. So he bought my husband this little. But, I mean, y', all, it fits in my garage. Like, it's this tiny, tiny little boat, um, that we've had since. Since I went to law school. So we've had this boat for over 20 years. Um, my dad has a similar one. We call his the Exxon Valdez because it leaks oil everywhere it goes. Um, yeah, so we actually do have a boat. My sights are probably. If that was what I was going to do, it'd probably be a better boat than the one that fits in my garage, but who knows? Maybe I just would have been okay with that. Yep.

Speaker A: All right, so first job in Houston was. Was where?

Speaker C: Tucker Taunton.

Speaker A: Okay. And that's doing insurance defense. And how long were you there?

Speaker C: I was there. I was there for four years, and I was under Keith Slade, cosmic interface. Um, Keith Slade was the. The best. I don't know if either one of y' all knew him when he was alive, but he was amazing and he was awesome, and I just thought he was really great. I still. It's still crazy to me that he's gone. Um, but yes. So my first job was at Tucker Taunton. I was there for four years.

Speaker A: Yeah, that's how, uh, I think it was called. Like, Tucker Hendricks. When I was coming up, it had a bunch of different names. With Tucker at the front.

Speaker C: You are. So by the time I got there, Tucker was already gone. Tucker wasn't there. I think he was already deceased, actually. But those guys don't get rid of anything. So there would still be like, you remember the old school briefcases, where they're like a big giant box and they flip over the thing and you pull the handle out? I mean, they had those everywhere and they had all the different names. Uh, Donato, uh, Hendrix, like, anybody, anybody. They had those everywhere. So, yes, it definitely went through bunch of name changes. And in fact, I think it's now Taunton, Snider and Parish is what I think it is now.

Speaker A: Yeah. But I think Norm Snyder's retired.

Speaker C: Yeah, I did hear that. I actually, um, I ended up in a, ah. In a docket call with Norm a couple like a year or two ago. And that was the last time I'd seen him. But yeah, he still looks great.

Speaker A: Good, good. And then did you go from there to, uh, Walter Spolido and Crane?

Speaker C: I did, I did.

Speaker A: All right. How long were you there before you retired? Two weeks ago.

Speaker C: Sixteen years.

Speaker A: Okay.

Speaker C: Where you go kind of like everything you don't know is super scary. You should just stay. You should just stay where you know. Um, and Walters, Blito and Crane was a. Was a great. A great location for me. I feel like I learned so much. And, you know, when I started there. Oh, shoot. When I started there, it was in. The Houston office was just David Bradley and Mark Ybora and, uh, Danielle Ross. And I was the fourth attorney. And now the Houston office has what, like 15 attorneys, and now WBC overall has over 100 attorneys. It was not like that when I began.

Speaker A: Good. And so doing defense of just every kind of case, every kind of matter, like auto, premises, what Else.

Speaker C: Yeah, so auto Premises. I, um, had a sex toy case. Um, I've had. I had a.

Speaker B: Well, you're not just gonna go right past the sex toy case.

Speaker A: Tell us. Tell us a little bit about that.

Speaker B: This is what the dirty verdict lives for.

Speaker C: So. And it was. It was. It was awesome. So basically, it was a, um. I don't know the appropriate words. Is this rated? Like, what do I need to do? I need to watch what I say. Okay, so it was.

Speaker B: We can. We can edit this out.

Speaker C: Okay, so.

Speaker A: But we won't. But we won't.

Speaker C: But we won't. Okay, so it was a dildo, and it was like, um, not a battery one. Like a floppy around one. And, um, some people were using it, and it didn't. It. A wire poked out. Wire poked out of it.

Speaker A: So products liability.

Speaker C: Products liability, yes.

Speaker B: Um, so that's a slippery situation.

Speaker C: So slippery.

Speaker A: Um.

Speaker C: Uh, yes. So slippery. And had to take all these depositions and then had to, like, figure out how to do the depositions. Right? Like, I had to figure out, okay, like, what does this term mean to you? This term means this to me. So at the beginning of the depositions was, like, setting up a dictionary of what things meant, like, penetration. And, like, what is. What does this mean? It was. Yeah, it was a lot, but it was very interesting. And so the best part about that case was that, um, my client decided to send me some exemplars so that I could know what they were supposed to look like, and then some other things so that I could know what I was arguing about. And they're like, well, do you want us to send this to your home or to your office? And I was like, to my office. I do not want them coming to my home. And because I have three kids, um, I was like, no, that's okay. And they're like, don't worry. We're going to make it very discreet. And I was like, okay, that sounds great. So one day I'm in my office, and I'm taking a depot, um, over Zoom. And my sweet little assistant at that point in time comes into my office, and she's, like, peeking her head around, and then she sees I'm doing something, so she leaves because. And then later on, she comes back, and I'm still on something, so she leaves again. So when it's over, I walk out, and I was like, is everything okay? And she's like, well, you just got a huge box here, and it says Dicks all over it. It's just stamped Dicks, Dicks. Dicks. Dicks. And I was like, oh, okay. Um, that was the COVID thing that I was supposed to get. That wasn't supposed to be obvious what it was.

Speaker B: And so very subtle.

Speaker C: She was like, don't worry. I got it before anyone would know what. But I got it before anyone else really saw it. And she was like. As I asked her, like, what would do you think that I'm doing with this box full of dicks? And she was like, well, I figured maybe it was a bachelorette party or something. I was like, a really good guess.

Speaker A: Yeah, that is.

Speaker C: No, it's not. And in fact, it was research. When I left my office just at the beginning of this month, I threw away the last one. It was

Speaker A: Kyle. Yeah. Kyle's going, why? You know, I'm here. I've been a nice gift.

Speaker C: Allegedly. They were dangerous, Kyle. I wouldn't feel, you know, thank you.

Speaker B: Thank you. You know, and a lot of wear and tear and a lot of miles on those things. You don't want them breaking loose.

Speaker A: Please did.

Speaker C: My last one that I had was still in the packaging. Um, so. No, no. No use of it.

Speaker A: So did that go to trial, or. I assume it resolved privately.

Speaker C: Yes, it did not go to trial. Um, it. We were able to get that one done, um, through mediation. Actually, I think Danielle actually mediated that one for us, but, yeah, so we were able to get it settled out.

Speaker B: Can you please tell us who the plaintiff's lawyer was? Because I really want him or her on the show now.

Speaker A: We will. I'll do a little research, Kyle, and we'll find out.

Speaker C: Actually, we're actually. We're actually friends. Um, and in fact, that person still owes me a lunch, so I may. I should bring this up. Um, but that would be up to them if they want to disclose that or not. You know? You know, clients.

Speaker B: I mean, all joking aside, you'd have to be pretty. I mean, it's an embarrassing situation. Were the damages, like, fairly serious to justify a lawsuit?

Speaker C: That's a great question. So according to my vagina expert, vaginas are very strong and very tough. And as he told me that, you know, Lee, having had three kids, that vaginas are resilient and they can heal up pretty well. And he thought this one had healed up pretty well.

Speaker B: Did you guys do a site inspection?

Speaker C: We did not do a site.

Speaker A: Were there. Were there. Was there an. Like, a product's liability expert that opined that this was a defective device?

Speaker C: Yes, there was.

Speaker A: And the other side, you had one that said, no, it's Totally fine.

Speaker C: We. Unfortunately for me, we didn't get to that point, so I didn't have to, because I was like, where am I going to find this expert? I mean, please know, it was fairly difficult to find a vagina expert, you know, So I was already like, I already did my expert work. Heavy lifting in this case. Like, it's time to move on to the next thing. Oh, and I will also say this. My vagina expert told me that my depots were the best depots he'd ever read.

Speaker A: Okay, good.

Speaker B: But to be fair, does he do a lot of work as a vagina? Is there a lot of vagina experts?

Speaker C: Like, so they're not, like, local. Right? So he wasn't local. He was, like, from another state. So I think the answer to your question is yes, but I don't think that it's like, you. I don't think you can find a Houston one. Right. Like, I think you've got to find a Just a vagina expert.

Speaker B: I mean, I'm adding this to the firm website. We're gonna start advertising for these kind of cases.

Speaker A: I mean, just from a. To be more serious side, I'm sure. I mean, just that part of your body gets injured, just like any other part of your body. And someone's got to opine on what the future will look like either way, you know, for better or worse. Just like your back, knee or your foot.

Speaker C: Exactly. Everybody's in. Everybody's entitled to their lawsuit. You know, this is America. Everybody can sue anyone and. But everyone else is, uh, entitled to defense. So that was probably my most interesting case. I also had a deer lease that exploded. That was pretty interesting, too.

Speaker B: An entire deer lease?

Speaker C: Yes. It was like a. Like a trailer that they had converted into, like, a deer lease, like, on a piece of property and a propane tank exploded and it injured a bunch of people. Yeah, pretty bad. My client, probably the worst. The one that got sued because he's the one that, like, turned off the things and did all the things. But, yeah, it was pretty bad.

Speaker A: Yeah.

Speaker B: I mean, I'm learning so much new stuff in the last 20 minutes. I mean, I. I might need a break. Just a few. Just a few minutes alone.

Speaker A: How many, uh. How many, uh, cases did you. Were you part of that? Went all the way to verdict either as first, second chair?

Speaker C: Oh, shoot. Uh, that's a great question. Um, and I'm not going to know a number, but one year, David and I did seven in one year. I did seven with Bill in 2024, so. 30, probably.

Speaker A: Yeah. Bill Rustum.

Speaker C: Yes.

Speaker A: Yeah. Uh, yeah. So quite a few. Quite a few. What was your last trial? Because you always remember your last trial.

Speaker C: Well, Joel, actually talk to my last trial plaintiff's lawyer. It was Trey Barton. It was a. The. It was the accident with the. The woman that was on her bike that ran into a car. I can't really take any credit or criticisms for that one. And that was one that was handled.

Speaker A: Ah.

Speaker C: In our Dallas office. And I'll, um, always offer to sit second chair and offered to help the things. And so that was a different attorney, so I just showed up.

Speaker B: And who out of Dallas tried it?

Speaker C: Uh, Jonathan Davenport.

Speaker A: So that was the one, I think. Kyle, you remember that Trey had an issue where he bought new clothes for the plaintiff, but she'd worked at a pizza parlor and.

Speaker B: Oh, just a pizza lady. Yeah.

Speaker A: Yeah.

Speaker C: And she refused to wear her teeth. So. She had teeth, but she refused to wear them. But I think it actually really endeared her to the jury. I think the jury thought she was really nice.

Speaker B: Um, you know, it's interesting. Uh, I mean, you guys got to bring clients to trial just like we do, right?

Speaker C: Right.

Speaker B: And, um, to a certain extent, we pick our clients. Right? You just get a stack of files from an insurance carrier, and whoever the client is, right. They. They paid their premiums, they get a defense, whereas we can be a little bit pickier. Um, but I'm always entertained one by how just clients present, right? They're just random people off the street. And it also cracks me up, like, how. Well, people can be rehabilitated in the six months between deposition and trial, um, kind of on both sides of the docket. I've seen some people present for, uh, defense depositions, like defendants. And you're like, man, I don't know if he's smoking weed right now, but he sure smells like it. And, you know, do people look like. Just like they just walked in out of the homeless shelter. I mean, I've been surprised. I've had one or two of them show up at trial, and I'm like, sir, what Ivy League college did you graduate from in the last two weeks?

Speaker C: You know, and that's something we always being on when you're on the defense side and that you always have to tell all your folks, right? Like, yeah, in the depot, they were yahoos. Like, this is. They didn't remember anything. But that can be cleaned up. That can be a different outfit. He's not going to wear the do you want to see my wiener shirt at Trial, you know, like there are things that can be cleaned up and you need to know that this, this can happen. Um, but then there are other people that when you take their depos, you're like, this ain't happening. Like, this one cannot control it. He can't. Or she can't keep it bottled in, you know that you just have to twist that knife just a little bit and they're going to go off the rails. And I've never seen a verdict workout for a plaintiff that starts yelling at people. It's just, I've never seen.

Speaker A: Yeah, that's bad. Mhm.

Speaker B: Uh, I was in a hearing on Monday morning where the defend. I'm actually, uh, the defendant in this case. I represent a real estate development company. And um, the plaintiff has a habit of showing up for hearings and teleconferences, uh, where she screams, no, no, I represented this real estate company. This lady brought this lawsuit against him. And the client, the plaintiff shows up and like completely unhinged and like, accuses everyone of like harassing her. And um, like we agreed to a site inspection and we like, we went out there with our experts and she called the police on us. Like, she's just totally unhinged. Anyways, so the lawyer, the plaintiff's lawyer withdraws because, uh, for a lot of reasons. And um, I'm like, judge, I got to be honest, I really don't want to have to communicate with this person. And I'm not going to call them on the phone. Like, I'm just telling you right now, if I call her on the phone, she's going to call you and tell you that I'm harassing her. So I'm not going to call her on the phone. I need the order to say when they withdraw, it's okay for me to communicate just by email. And that's it. The judge was like, yeah, that's fine. That's totally fine. I had another client years ago who was a plaintiff, who was a very devout Christian and he was from East Texas. And he showed up for deposition wearing a, this is no joke, a crucifix. But it was like a crucifix that someone had taken off the wall and put a chain on. So it was about a foot and a half wide and about 3ft tall. And he just so happened to also wear like a brown sweatshirt hoodie. And like, he walked in and I jokingly said like, is Robin Hood with you? And he was like, what are you talking about? And I was like, I don't know. Friar Tuck, what are you wearing today? Yeah, and I was making fun of him, and he's like, are you making fun of Jesus Christ? And I was like, oh, man, no, this is going to be great.

Speaker A: So, yeah, that leads us to. So, Lee, we want to lean on some of your defense expertise. So what, um, what would you advise both, let's see, for both defense plaintiff, uh, and weaving in your mediation, your new career as a mediator, uh, what would you advise plaintiff lawyers to do to help maximize the ability for a positive, um, settlement at mediation? What can they do to help. Help. Help educate.

Speaker C: It's a great question, Peter. I think the first thing that I would say is I think all plaintiffs lawyers think they need to search super crazy high. That's the only way they're going to be able to get any money. Think that that's true? I, you know, I think everyone's very aware that some numbers, you know, say, for instance, you have a million dollar policy and the meds are at 25, and there's nothing super egregious. There's no need to start at a million. Like, let's, let's start somewhere reasonable. We all get that. You could ask for that. We get it, but that doesn't mean that that's what the case is worth. And the other thing I would say is, you know, help your mediator, right? Give them all the facts that are going to make it easy for them to fight for you. You know, I. Mediation memos are fantastic. I know that a lot of plaintif do it. Um, I always did it as a defense counsel one, so I could review my file again, but also to kind of help the mediator know what the meds were past, future, there's any gaps in treatments, you know, things like that. So same thing on the plaintiff side, like, if whatever you think really helps your case, let us know that, so we can make those talking points in the other room, because we are going to fight for you. I mean, that's the, you know, we're the neutral, but we're fighting in both rooms. So making sure that you kind of have a handle on your case and what's going on is super helpful. So along that same vein, like showing up with a bunch of stuff that you haven't already disclosed or you haven't already told the other side, you know, if your damage model was at 50, and then you come in on the day of mediation and say, well, I haven't told anybody this, but I've got an extra million in lost wages. I've never disclosed. And I also have this. I mean, there's no way to get that to work. It just puts everybody on the wrong foot. So if you can make sure that everybody's got the stuff that they need to evaluate your case appropriately, you know, most folks are going to do that.

Speaker A: So on the defense side, what's the timeline on when you are required to present a premediation memo to the adjuster? Is it 30 days, 45 days, 15 days?

Speaker C: That's a great question. It's going to depend on your carrier. Every carrier is different and depends. And sometimes it depends on how much you're asking for. You know, if you're asking for a certain number, it may have to go up multiple levels. So if you're a plaintiff lawyer and you're going to ask for a bunch of money, get that information in as soon as possible so that it can get to the people that it needs to so it can be properly evaluated and they can come in with the right money. You can't, like, sandbag. You can't, like, sandbag and not tell anybody until the day of mediation and then expect that they're going to be able to evaluate, uh, an extra $300,000 worth of damages that might be legit. Um, so I would say a minimum of 45 days to give that information. Because also, you have to think about the time lapse. Right. Like, so, Peter, say you're the plaintiff's lawyer and I'm the defense lawyer. So you update everything and then you send it to me. Okay. I still need to have time to be able to review that. You're. Yes, Kyle.

Speaker B: Can I be the plaintiff with the defective dildos and. Yeah, yeah, I'm not sure which one. He represents me, but I've got some questions.

Speaker C: So, you know, but I need time to be able to look at that and evaluate and get it over to them. Then they have to evaluate it, then they have to get it up. So the more time you give somebody to look at this stuff, the better. Um, because that way it can get to the people. Needs to.

Speaker A: And what types of things are in the, um, your report, the defense lawyer's report to the adjuster. Obviously, the facts of the accident, um, and the damage, you know, medical treatment and the, uh, medical bills. What future past. What other info can a plaintiff lawyer give make sure is disclosed to the defense lawyer that can help them with their reports?

Speaker C: Um, experts, you know, if you are going to claim lost wages, lost earning capacity, you know, you're going to have to have an economist I mean, or at least like, provide, if you have documentation about it, like, like something from the manager of the company, the owner of the company, like, turn all that stuff over. You know, we're going to, we're evaluating, you know, how good you're. Everyone is, is a witness, right? If it's disputed liability, you're always evaluating the witness, right? You're evaluating the damages. Like, okay, so is. Are these pictures going to be able to come in or not come in? Who, who do they benefit? Who do they not benefit? And, um, what experts do you have? Do I feel strongly about. Do I know these experts? Do I think that they're yahoos? Do I think they're legit experts? And, um, our court, you know, who's. Whose court are you going to be? And what do we think is going to happen with this court? When do we think this trial is actually going to happen? Um, and the other side, you know, is this a law firm that tries cases? Is this a law firm that doesn't try cases? Um, if they try case. If they try this case, who's going to try it? Is this someone you tried a case against before? You know, all that stuff kind of comes into play. I think that's why the plaintiff's work is so different from the defense work. Is that because there's people that most defense have to report to. You're constantly having to evaluate what you're seeing and what that means. Like, what is, okay, great, you got in a, like, your plan. What does that mean? Is it a legit life care plan? Did it get drafted by chiropractors? Like, where did this come from? You know, like. So we are forced, because of who has to be reported to, to constantly evaluate cases. And on the plaintiff side, I don't know this, but I assume that you're not constantly forced to evaluate your case. It's until something's going on, you know, a depot, a mediation, any, you know, status conference, anything like that. But on the other side, on the defense side, when things come in, you have an obligation, right?

Speaker A: Then, yeah, you. I, um, mean, I know a lot of demand. Plaintiff demands will include, uh, that particular firm's verdicts or other verdicts that are similar from other, um, other firms. So my question is this. So obviously you did a lot of State Farm work, and obviously State Farm has, uh, probably the most cases in litigation. So I would, I put them at the very top. As far as evaluators, they know what's going on in the courthouse. But are there some insurers that Maybe don't cover a lot of claims in Texas and don't know, hey, Houston's had these kinds of verdicts. Should plaintiff's lawyer put those in there anyway?

Speaker C: Well, I mean, it doesn't matter what I say. I think that plaintiff's lawyers are going to do it. If they're proud of them, they're going to, you know, they're going to put those pictures in there, they're going to put those verdicts in there. I think it can be helpful. But I think that probably plaintiffs attorneys. I don't know how much defense counselor are being asked those questions already. You know, I think that Harris county for a minute seemed very scary to insurers, you know, like, oh, gosh, we're seeing all these crazy verdicts, yada, yada. But people were talking about the good defense verdicts. And so, you know, I think that tide is slowly kind of starting to shift over a little bit. But most insurers are aware of the venues and certain attorneys. But if you're, you know, if you're not one of those big names, then, yeah, I think it could definitely be helpful to put that stuff out there. But, Peter, you know this. Everybody talks about verdicts. You know, like, I'm trying to watch the Busby verdict right now. So, I mean, people talk about verdicts. If they know anything about it, then they share that information, good, bad, and ugly. And I think that's beneficial to everybody to know what to expect. But the fact is, is that every jury panel is different. You know, I had a case that we won. We got a no neg verdict, but we had popped the first panel. And that first panel, I think, would have read us the riot act, but we popped that panel. And then the next panel that came in the next day, we got a great verdict for us. And so you just, you don't know. You. You just, you know, and as much as we have these little formulas about who we want on our panel and who we don't want, you just don't know what's going on in the background of those people. You can't just take that one little piece and decide. That's it. But unfortunately, that's what we got to do.

Speaker B: Yeah, I just take the first 12 that can read and write. And look honest.

Speaker C: Yeah, yeah. And look honest. Okay, so tell me how they look honest. What would you look at to determine if someone looks honest?

Speaker B: That's honest. That's easy. Lee, can you see me right now? Yeah, I got an honest face.

Speaker C: Well, good for you.

Speaker B: Good for you, you see Peter? You see how his eyes are a little bit too close together and a little shifty? Now you know what I'm talking about?

Speaker C: Yeah, for sure, for sure. Yeah.

Speaker A: Um, m. Okay, Kyle. Any, any. I've got some more questions, but I didn't want to hog it.

Speaker B: Well, I was just going to say, um, you know, I did defense work for about three years early on, and,

Speaker A: um,

Speaker B: I used to tell plaintiffs lawyers if they would listen, I would say, hey, I'm not Santa Claus. Like, I don't imagine your hopes and dreams and bring you presence. If you put it down on paper, I'll make sure an adjuster gets it. And to the extent I can provide additional information, I'll do it. And that's, for the most part, my approach, um, when I want to get a case resolved, is to give the opposing side as much useful information as they can. And oftentimes I'll take our. Whatever pre mediation memo gets drafted, uh, and I'll actually read it. If I didn't write it, I normally don't, but I'll read it. And it's a framework for me to prepare for trial. But if there's nothing like some secret sauce in it, I'll send it to the mediator and opposing counsel at the same time. And then I'll usually call or email opposing counsel and say, bare bones, this is my damage model. This is what I think the liability issues are. Before we argue about anything, do you have all the information you need, good and bad, to make a recommendation and evaluate the case? And if they say no? I say, great, well, let me, let me make sure that I've given you everything I've got. Because if I'm going to show it to a jury, I'm sure as heck going to show it to you.

Speaker C: Uh, agreed. I mean, help me help you. The way I do everything in my life is, well, how would I want to be treated, Lee? Like, what would I want to know? So I always try to think, okay, so if I was going to evaluate this, what do I need? So if you kind of put it in that same framework and think about it, then it makes everything so much easier. I know that there are attorneys, though, that definitely like to do, you know, oh, I've got some secret stuff in my back pocket. And there's going to be secret stuff. There's going to be some secret stuff. But in general, a subtle case is a good case. You know, you just never know what a jury's going to do. So if you can get something resolved do it.

Speaker B: Like, I've had secret stuff, but I've rarely had secret stuff in a fifty thousand dollar state farm rerender. I mean there's, there's no big secrets in these. I mean we, we pretty much all know what's gonna. Well, you know, you never know what your jury is going to be like. But the rest of it, it's not exactly, ah, rocket surgery.

Speaker C: No, it's definitely not rocket surgery or rocket science. Like, I mean it just provide the information, like let them know, Let them know what's going on.

Speaker B: Yeah. Peter.

Speaker A: Yeah. Okay, another question. So, um, we've had a lot of plaintiff lawyers on that have talked about how the plaintiff's bar shares a lot of information with each other. And they note that the defense bar does not seem to do that as well. Was that now you were at a big firm with 100 lawyers that just did insurance defense, so you had the benefit of a firm that would obviously share information, but you find the same thing, um, that defense firms don't share as much information among each other.

Speaker C: I think that that's true. Um, and of course I've only had two law jobs before I started mediating. So take, um, that with a grain of salt. But I do think the plaintiffs bar is much better at sharing information than the defense bars. And I'm not sure why that is. I think that the defense bar has realized that and is working on rectifying that. Um, and again, I also think it depends on your attorney. Um, you know, because I knew well and know a bunch of different defense attorneys and plaintiff's attorneys. So I felt like I knew a little bit more than some people did because I was able to ask other people and to talk to other people besides just my firm. Um, and then, you know, also we've got adjusters and insurers and they're also talking and they have information as well. But the plaintiff's bar seems to be much more organized. The defense bar seems to be a little bit more piecemeal than you're just keeping your fingers crossed and hoping that someone's going to be able to provide you some additional information. But I think that they're getting there. I think that's something that's going to happen

Speaker B: a couple years at like the state bar or University of Texas Advanced Trucking cle. And there was. The overwhelming majority of speakers were from the defense bar. And the three lawyers on the plaintiff side were me, Jim Perdue and Mark Murray. Right. So one of them is not like the other two. Um, but the Defense lawyers, man, like, they really played their cards close to their vest. Like. Like we send out interrogatories. That's a proprietary secret. Don't tell anybody. And it was. It was like, you know, and in the couple of years I did defense work, it was, uh, very, very much like they had a secret recipe that they didn't want other insurers or other carriers or other law firms to find out about which. And I'm not saying that's a bad approach. It just seemed like, I guess if you're competing for the same pool of potential carriers, you kind of can't really give up how you do it better than everybody else.

Speaker C: Right. And I think that.

Speaker A: That.

Speaker C: I think you hit the nail on the head with that because they, uh, Insurance, you know, insurance defense firms are fighting for the same clients, and, um. And there's only so many. I mean, let's. The Spanish. There's a bunch of insurers out there these days, but they're still only this finite group. And so if you've got them and you've got their secret sauce, then you sure as crap don't want to tell somebody else. You know, you want to be. And I think that's what drives a lot of insurance defense lawyers is that you want to be the best one you can, because, you know, there's 20 other people right behind you knocking on that same insurer's door, being like, I could do a better job than that. I could be more responsive. I could be better than that. So it is. It is more competitive amongst ourselves. It's more competitive, for sure.

Speaker B: And on the plaintiff side, you just do a good job where you go bankrupt very quickly.

Speaker C: Exactly. It's totally different. Ball game.

Speaker A: Yep. Okay, so we talked about, um, deposition kind of horror stories. So on a scale of, say, 1 to 10, would you say when you're writing a report to, uh, adjuster, what do you think the. How the plaintiff came off as a wit? Because that comes up a lot. And, you know, where they'll say, well, the plaintiff was an above average or below average. Is that a. Is that a significant factor in risk assessment, how the plaintiff did in their depot?

Speaker C: Yeah, I would say. I would say that is, um. But it. I think it depends on why. 1. You know, if you're disputing liability, then for sure, that's very important. Right. And also, you know, we're seeing, you know, or I was seeing a lot of attorneys that were like, uh, you know, or plaintiffs that don't know anything about their medical treatment and it's as someone who has not been injured a bunch of times and doesn't know, like, what that would be like, it seems off putting to be like, okay, you got all this treatment, but you don't remember how many injections you got. You don't remember from when to win. And I'm not asking for specific things, but it is. Oh, Buzz, we just got a verdict. Um, but it is. But, yes, it is. It's definitely important. Um, but again, I think that's stuff that can be cleaned up. Um, I think one thing that probably people discount, I think, on the plaintiff side a little more than they should, are the medical records.

Speaker B: You mean.

Speaker C: Well, min. Uh, evasive. Uh, for a long time, they. The back of all. Every medical record, they would ask them, like, does this affect your activities of daily lifting, living? Like, how's this? And those fools would write, no, constantly. Or they'd be like, I'm fine. Everything's fine. And plaintiff's attorneys wouldn't know that we'd get. I mean, they provided this to us. And then we'd get to trial and

Speaker B: be like, I would take. I know what forms you're talking about. And I would get them, and I would just write in the back. I'd be like, things are really bad, you know?

Speaker C: Yeah, yeah, yeah. I mean, you could. Or stamp that. Ignore this. Ignore this.

Speaker B: But I actually had just redacted all out.

Speaker C: I had a case that we ended up with a mistrial on it. But, um, we were moving forward, and she. The plaintiff's counsel had never seen those. And so whenever I brought up that her. Her batch didn't include that. And she looked at. She's like, yeah, I'm going to throw out all my mental anguish. I don't think I'm going to be pursuing that anymore. Because it is a lot like, again, defense lawyers have to evaluate everything. The plaintiff's lawyers don't have to do it as much. So there might be things you're missing in your medical records that are important that you just didn't see.

Speaker B: I think that having an agreeable and honest client is maybe the most important piece of trial. I mean, I've had cases that I thought were gonna go just fine, but I hadn't been the person who sat through the depot. And then. And then you sit down with that client the weekend before trial, and you're like, holy cow. She can't answer honestly about her name, address, and phone number. And I've been to. Obviously I've done enough trials that I've seen Some just go totally south. Sometimes it's because a client gets nervous, but sometimes it's because the client's a bad person. Uh, and I've seen that for both plaintiffs and defendants. Sometimes the defendant comes in and they're like, I got a great case. And you know this. Your little old lady clients about to get hammered. And they show up with a client who just lies for no reason. And you're like, what? Well, okay, I guess I gotta drive a truck through this now.

Speaker C: Yeah, exactly. And let's be honest, everybody that's tried cases has won cases they had no business winning, and they've lost cases they had no business losing. Um, and so when people are like, I love trial, I'm like, oh, I don't understand that. Like, it's, you know, it's a lot of pressure. It's so much to prepare for. And you, you don't know what's going to happen. It's going to. But I always wanted to be, if I could be the most prepared person so that would be ready for whatever might kind of get thrown at me. But you still don't know.

Speaker B: We, I had a case in front of judge, uh, Schaefer a few years ago where we put my client up last. And I've. I have never been through this before, but the client literally, Like, came after me during her direct and then was even ruder to the defense lawyer. And I mean, the jury was just so off put by her. She was just terrible. And we got, she left the bench, we broke for lunch, we were doing the jury charge. And opposing counsel, who I got along with great, said, I want a directed verdict on mental, uh, anguish. And Schaefer goes, what do you think, Kyle? You got mental anguish? I was like, fuck, yeah, judge, I got some mental anguish. I have some mental anguish about this. And the judge is like, he was like, I know, man, it happens. It's like a train wreck. You can't stop it. Nothing else you could have done. It's horrible.

Speaker C: But that's exactly it. You just have no clue. And you also kind of know your client, right? And to you, you can be like, oh my gosh, they're so sympathetic. Like, they're so nervous up there. But then it reads to the plaintiff's counsel, the opposing side, and maybe the jury that they're flipping, that they don't really care what's going on, but really that's them being super nervous. So you just, you just don't know. And a jury, a, uh, juror could hate you just because you're wearing yellow tie, and they hate yellow.

Speaker B: Well, let me ask a strategy question then, because we have found a way that we try to short circuit some of that nervousness and that freak out that you get standing in front of 12 people. So we really try and be exhibit and demonstrative, heavy on direct examinations of clients. Is this the X ray of your kneecap? Is this a picture of the car so that they don't have to extemporaneously speak on whatever question you ask? Um, we found that works pretty well because we can kind of walk them through it in advance, and if they get lost, we can. Okay, we're going to go back to the picture now. Have you seen other ways that plaintiffs lawyers or defense lawyers do a good job of making, uh, testifying easy for a client?

Speaker C: No. And I, and I do think that, you know, as, uh, a, uh, when I was doing defense work, I like to use the records because I wanted to keep everything as short and succinct and to keep them on track with where I am. So I love exhibit. I loved exhibits. I, you know, I loved being able to show medical records and pictures and things like that because I felt like it kept everything on track. And I think it keeps the jury engaged because it's more interesting if you can actually read something as well. And a lot of people are visual learners that I have not seen very many plaintiffs lawyers utilize documents in the same way. Most plaintiffs lawyers just kind of want that I've seen and, and trial that they want them just to kind of tell their story, to be like a human in front of the jury. Which makes total sense. It makes total sense. But I think it does likely help, uh. I think it does likely help a jury to hear, to see stuff as it's moving forward. And I think it helps. I think it helps the client as well.

Speaker B: So maybe this was Peter's next question. So you can cut me up. And I was going to ask, why did you decide to get into the mediation game as opposed to the litigation jam, man?

Speaker C: Um, so, you know, I feel like everything in litigation, I feel like. And please know that there are definitely parts of litigation I'm going to miss, but there's a lot of parts I'm not going to miss either. Um, but, you know, Harris county has been so backlogged because, you know, we got hit with Hurricane Harvey years and years ago, and civil, you know, criminal had to move in with us, and everything got backed up. And then we got hit with COVID and everything got backed up.

Speaker A: Are you looking at the verdict?

Speaker C: Yeah. So 5, just under 5 million. And they put 23% on the plaintiff.

Speaker A: All the total damages were 5? Yeah.

Speaker C: Total damage is 5, 23. So then reduce that, uh, by 23%.

Speaker A: Yeah, there's a. I mean it was a Jones act case, so you've got made 4 million bucks and all that. But.

Speaker C: Yeah, yeah, sorry, I was telling. I had two different friends watching it. Okay, so, um, and now I forgot my. See, this is the new thing where I forget the thing.

Speaker A: But you're saying the courts are all jammed up.

Speaker C: Yes. So, and then, you know, Covid. And so then the courts are getting, you know, railroaded by the Texas Supreme Court. You got to try cases. You got to try cases, which I get. But when you have so many cases and then you're being called to trial left, right and center, it gets exhausting.

Speaker B: Um, so I'll tell you real quick. I have had three pre trial hearings in the last two weeks. And at one of them, and this is like fair warning that you guys can both agree with. So people that listen to this know, um, we were set for trial. We everybody filed a motion for continuance for very good reason. And the judge said, you have to try your case. Your motions denied. And the defense lawyer said, judge, we have too many cases. We just, we can't, we can't get to all them. And the judge said, hire more lawyers. Hire more lawyers. I don't care. I'm getting pressure from the Supreme Court. The calendar must stay. Hire more lawyers. And look, this was a case that was not super old. Um, and I'm not criticizing that judge. If you know what's going to happen, you can plan for it. Right? If you know your second continuance is going to get pushback, great. Just know it and prepare your case. But lawyers, especially in Harris county, need to start getting real aware that judges are not, are none too pleased about motions for continuance anymore.

Speaker C: Well, and I think most folks that do try cases are very aware of this. But, uh, it was getting to the point. So last summer I was in Mexico. I had a vacation letter on file. And I happened to just check my phone while we were out at dinner with my family on Sunday night. And I had gotten an email from a court at 8:30 that night to be at the courthouse at 8:30 the following morning. That was on a Sunday. So a. Ah, lot by. I'm usually asleep pretty early on a Sunday. I enjoy a Sunday Funday. And then I took it to nine out at a decent Time. But I was just lucky that I saw that. And then I had to reach out to the court and say, no, uh, no, no, I have a vacation letter on file. Plaintiff's counsel tried to fight me on it. He was like, I don't see it. But luckily my assistant was able to find it and send it over to them.

Speaker B: But easy to find. It's on the clerk's website.

Speaker C: Exactly. But what was. You know, that. And that happened to me several times. I had another case where it got. The case got dismissed. It got dewapped because, uh, plaintiffs council forgot to. He just did not have the docket call on his calendar. So that's fine. I called him. They were like, we're dismissing it. So he filed a motion to reinstate. Um, unbeknownst, um, to us, the court had granted the motion to reinstate and then immediately called us to trial. So we thought the motion to reinstate was still pending. And then they're telling us to show up to court the next day. Um, so just. That gets very. That was getting very taxing. Um, please know that there are times I'm definitely going to miss litigation and miss the highs and lows of it. But it's so much. It's so much, you know, and like, on your side, on the. On the plaintiff side, there's. You've got people you've got to report to your client. On, um, on the defense side, Lord only knows how many people you have to report to. And things like that happen. They're like, well, how did this happen? I don't understand what happened. And you don't have an explanation. You're just like, I. I don't know how this happened. So you just have to prepare every case as if you're going to go to trial tomorrow, because you don't know what's going to happen. It's just. It got to be very frustrating. And I think, um, also for me, I decided that, you know, I. I hope that I had built a good relationship and a good reputation as being fair and honest and hardworking on both sides of the V. And so that kind of seemed like the next step for me to go to. Like I always tell my new folks, being an advocate doesn't mean being an asshole. You're not perfect. You're going to need help from the other side. And so, uh, you know, as I was kind of progressing through my career, I was thinking, okay, well, you know, Jesus loves a peacekeeper. You know, it was like, so, you know, what. What's the game? What's the game plan. And so, um, my thought was. Okay, well, my game plan, I think, is to be a mediator. And hopefully that's going to be something that works out.

Speaker B: I think that's truly. I think you've got a great reputation on both sides of the bar. Um, and I know lots of. I don't say that, really, to a lot of people, but I believe that about you. And, I mean, I think you'll do. I think you've got a great temperament for being a mediator. I think it's a really smart move for you.

Speaker A: Agree.

Speaker B: Thank you.

Speaker C: I appreciate that. I'm very hopeful and nervous.

Speaker A: No, you'll be good. It just takes a little while to get in the flow, to get kind of on the radar. And that's why we have you here today, is make sure everyone sees what a nice, reasonable person you are.

Speaker B: Erica, will you cancel all our mediations with Peter and see if we can get Lee Lewis on there? She's. She seems real smart.

Speaker A: All right, thanks.

Speaker C: I told you I went to Duke and UT Law. Must be a genius.

Speaker B: Yeah, for sure.

Speaker C: Yeah.

Speaker A: So before we kind of wrap up, I wanted to. I, uh, didn't want to let this go past because I think it's really important, the medical record part. So there's. To me, there's no reason why you can't have a firm hold of your medical records either side. With the advent of AI and all the different, um, services that you can dump medical records in and they'll turn it into a summary, and you could probably. I'm sure they have prompts that tell you where's. Where do. I have issues here? And, I mean, these tools now are just so good and cheap. So if you're a plaintiff's lawyer, just know your adversary is going to have that done. And so you need to have that done and prep your client before deposition so you can at least have. Maybe have an answer for it or an explanation of what's going on.

Speaker C: I will also say that we. Sorry, Kyle. I mean, I cut you off, but, um, some carriers will not allow you to use AI for medical records because they believe that to be a HIPAA violation. Um, I don't know if it is or if it is not, but, um, I know AI is still, you know, this new tool that everyone's getting their mind wrapped around. So I don't know exactly what it is, but I know that some carriers do have concerns about that. I've always liked to review my own medical records, because I don't. That's the only way I can really retain things. I don't retain things as well if I just read someone else's summary. But it would be significantly easier.

Speaker A: Well, pre AI, you'd have nurse, um, nurses or medical professionals would review them as well. And you know, they know that's what they do on a day to day. So they can pick those things up. Just know that they're going to be looked at on the other side. So you need to do the same on. On your side. I think that's critical. I agree with that, Lee.

Speaker B: A lot of these AI providers have a certification that says that the data that you input to our system, we are using our tool on your data. We are not using your data to improve our tool. And we've been toying with the idea of sending out a letter when litigation starts. That sense says, you agree not to put my client's personal information and medical records through an AI database unless you tell me which one it is so I can check and make sure that it's one of the certified ones that is HIPAA compliant. And I'm about to add a disclosure on the exact same topic to my fee agreement to tell people we're going to use AI in certain contexts and that we've done our best to make sure your information isn't just floating around out there. Um, but it's a crazy new world out there to not to. For a robot to basically come up with large pieces of your litigation.

Speaker C: How have we not learned our lesson? Has no one seen the Terminator? Like, what are we doing? Like, why are we letting it? Like, I'm like the Matrix Terminator. Did no one watch any of these movies? Do we need to bring these all back so that everyone can learn that we.

Speaker B: It's gonna be bad someday. You're gonna, like, be on the Apple terms of service and you're gonna click confirm. And then Schwarzenegger is going to come from. Skynet's going to take over. It's exactly what's going to happen. I just hope that's why I only say nice things about Peter Thiel and our robot overlords. I hope when they send me to a camp, it's going to be a nice one.

Speaker C: Good camp. That's why I tell Alexa I always say nice things to her and I always thank her. I'm like, thank you, Alexa.

Speaker B: Alexa, you look great today.

Speaker C: You look so good. That was a really good joke you told the other day. I really laughed about it. Yeah.

Speaker A: All right. Well, that's a. That's A. The AI thing. Of course. I think unfortunately, it's here to stay. And, um, it's just a question of limitations on it, which I think everyone's starting to. To think about that Lee is now. Um, but that's, that's, um, like I said, that's a whole five hour topic. But, um, I liked your. I liked with your thoughtfulness on that and how it's affecting your clients. And so I. I'd recommend maybe Josh will clip that and some people will. Will get that as a, uh, learning. Well, Lee, thanks for joining us. We're right at, right on our times timeline of hour. Uh, so thanks for joining us. We'll, um, again, you can find Lee's calendar, my calendar, Danielle Angela Wood's calendar at, uh, Coma mediation dot com. And Lee's got some availability. So if you want to get in this summer, come. Come see her and get a case settled.

Speaker B: You guys think I'd be a good mediator?

Speaker C: No.

Speaker A: It would be.

Speaker B: That's the answer I wanted. I don't think I have the pay. I know I don't have the patience for it. That's why you guys. That's why you guys are so important and do such a good job.

Speaker C: That's so funny that you said that, because that's what I've been telling Daniel. I'm like, patience.

Speaker A: Yeah, that's it. Yep. All right, well, we'll let everyone go this evening. And thanks, uh, for joining us. Follow us on Instagram, M. LinkedIn, YouTube, Spotify, where else? Kyle. Facebook only.

Speaker B: Fans, MySpace, ESPN.com, draftKings and Kyle

Speaker A: somewhere. Now, Lee will put her client's name in the show notes. So if anyone wants, um, a delivery to their. To her office, you'll, uh, know where to go.

Speaker B: Well, I just want to say welcome to the mediation practice, and I've got an idea for a great office warming present for you. Uh, if it vibrates when you pick it up, that's for me.

Speaker A: Okay.

Speaker C: I won't open it. I'll make sure. I'll be like, this is a bomb. I'm pretty sure this is a bomb. Return to sender. No. Um, all right. Okay.

Speaker B: Thank you guys.

Speaker C: I appreciate you all letting me be on you.

Speaker A: Got it. All right, we'll see you guys next week. Thank you. Good night.

Speaker C: Bye.