In this week’s podcast, trial attorneys Paul Motz, Shareholder, Segal McCambridge Singer & Mahoney and Matt Moffett, Partner, Gray, Rust, St. Amand, Moffett & Brieske, LLP, join CSI Litigation Consultants Dr. Steve Wood and Dr. Bill Kanasky to discuss the topic of attorney credibility and attorney demeanor. The group talks about the difference between plaintiff and defense attorney performance, the aggressiveness of plaintiff attorneys compared to defense attorneys, and how that aggressiveness impacts all aspects of the litigation process, not just the trial. They speak about how the plaintiff’s bar has kept the defense bar in a reactive mode, how that has helped contribute to nuclear verdicts, and what can be done about them. In addition, the group discusses how the insurance defense industry can be better prepared during litigation and how they can leverage research, data, and witness training to guide settlement negotiations and decisions, and much, much more.
Full Episode Transcript
[00:00] Steve Welcome to another edition of the Litigation Psychology Podcast brought to you by Courtroom Sciences Inc. and I’m excited about today’s podcast. We have a star-studded cast. We got some old faces and we brought in a new face as well. Our first guest is a first-timer to the podcast, but I’m sure we’re going to be seeing a lot more of him here in the future: Paul Motz. Paul is an attorney out of Chicago. Paul, how you doing today?
[00:29] Paul Doing very well. I’m happy to be here.
[00:31] Steve Good, I’m glad. I’m glad you were able to get you. My next guest is a fellow IPA connoisseur as myself. Uh, Matt Moffett. Matt is an attorney out of Atlanta. Matt, good to see you today.
[00:41] Matthew Good to see you Steve. West Coast IPA, right?
[00:44] Steve That’s right. And then finally, he needs no introduction, but I’ll do it anyway. That’s—my guest is actually my colleague Dr. Bill Kanasky. Bill, how does it feel to be on the other side of the podcast today?
[00:59] Bill I—I can’t stand it. I like to—I like to have the steering wheel in my hand. Um, and by the way, I’ve been—uh, I’m on the—I’m back on the IPA banned list. My wife has banned me from all IPA consumption uh, until 2021, so I guess I didn’t handle my IPA very well last time.
[01:21] Matthew That means more room for martinis, Bill.
[01:23] Bill Um, I think that ban is in place too, actually.
[01:28] Steve All right, well gentlemen, today’s topic is one that I—is near and dear to my heart. It’s actually a topic that I did my dissertation on and I’ve done a lot of research on, and we’re talking attorney credibility, attorney demeanor, anything related to attorney performance. And what I want to talk about today is how defense attorneys and plaintiff attorneys differ in the way that they approach their cases. And what I seem to find is that plaintiff attorneys will get right up to that proverbial line—and what I mean by that is, you know, the line of sanctions, the line of a mistrial, whether or not they’re going to piss the jury off, whether or not they’re afraid that, you know, jurors are going to be pissed at them, you know, or objections or anything like that. Plaintiff attorneys just don’t seem to care as much as defense attorneys. And I wanted to talk to you, Paul. Am I wrong on my assessment? Is—am I wrong on what I’m seeing as far as that plaintiff attorneys are a lot more aggressive and defense attorneys tend to be a lot more conservative in that approach?
[02:27] Paul No, you’re not wrong at all. Um, I—I think that the plaintiffs’ bar is—is frankly kicking the defense bar’s butt in a lot of ways across multi-facets of litigation. It’s—it’s not just in the courtroom. Uh, it starts in the discovery process, heck it’s in the pleading process a lot of times. But when it—when it comes to trial practice, um, you know, I’ve seen a very, very aggressive plaintiff’s bar, and it’s just getting more and more aggressive. Um, and the—the more we litigate cases, and I’m going to guess once we start getting back in a full swing of trials, either remotes or in person, we’re going to see um, a hyper-aggressive plaintiff’s bar just because they’ve—uh, they’ve been refining their tactics and—and—and taking notes and exchanging notes with everybody during this pandemic.
[03:22] Steve Yeah, and I was going to see you have any insight into why that is? I mean, is it—is it a feeling that you get from the client? Is it something that you learn as far as just as a personality trait of those who take up defense work? I mean, help us understand a little bit more about why it is that defense attorneys feel the need to take that approach.
[03:45] Paul You know, I—I don’t have uh, all the answers on this, but I—I will definitely say I think that there is uh, for lack of a better term, an old-school approach to trial, uh, and then the the new-school approach to trial. Uh, you know, the—the old-school approach is one where, you know, especially during opening statements and closing arguments, um, you don’t want to object too much because that’s—that’s impolite and you expect to have the same courtesy delivered to you. I don’t think that the—the plaintiffs’ bar is not uh, playing by those rules anymore. They want to win and they want to win big. So when it comes to their efforts at trial, they will do everything they can um, and go all the way up into that line and maybe even toe the line of a mistrial, sometimes even passing the line of a mistrial, such that they are positioning their arguments in a way that, you know, really resonate with the jury. And conversely, it puts the defense um, on much more of a weak footing. It looks—it makes us reactive instead of proactive. Uh, I—I when I’m trying the case, I don’t like any surprises. I like having game-planned out everything, uh, even the plaintiff shenanigans, so that, you know, when—when we get into the situation of them, you know, pushing that line, we—we can just basically like muscle memory fall into, you know, how to appropriately respond and aggressively respond. Courteously, of course—I’m not—not advocating for being an asshole to the judge uh, or to the jury—but aggressively and forcibly putting out why the plaintiffs have overstepped their bounds.
[05:35] Steve Excellent. And Matt, I want to turn to you. Same question to you is: have you noticed the same thing that I’ve noticed, and kind of what are your thoughts as far as the thinking behind why it is that this is such a stark difference between the two counsels?
[05:53] Matthew Yeah, I think Paul’s exactly right. Um, the mindset and the strategy of the defense that was effective for many years is no longer effective. So it’s a paradigm shift at this point. So the way I approach cases, if I’m not prosecuting the defense, I’m not winning the case. The plaintiff uh, and the plaintiff lawyer, everybody understands that they’re prosecuting a case, but I’m not going to be reactive, because that doesn’t work. That might have worked 25 or 30 years ago. You know, “We don’t have to prove anything, uh, and let me tell you what uh, the plaintiff lawyer said that’s wrong and let me tell you why my client didn’t do anything wrong and let me tell you why how great my client is.” None of that works anymore. We have to prosecute the defense and lay out our case to explain why we win the case and not the other side. And I think there’re not enough of us, there’re not enough Pauls out there that understand this and do it effectively. We’re coming around, but the plaintiff’s bar has lapped us already. They’re very equipped, they’re well-funded, they’re extremely talented at this point more than ever before in my career, and they’re formidable. So we’ve got to be ready not to react anymore, but to focus the case on what we believe uh, shows and proves we should win the case. Prosecute the defense.
[07:21] Steve Great. Excellent. And Bill, I mean, from a jury psychology perspective, you and I have done a lot of mock trials and we’ve done a lot of talking with—with jurors. Have you seen that jurors notice this? I mean, it’s not just us talking here. I mean, have you noticed that the jurors are actually noticing this difference and this dichotomy between the way the two sides approach cases?
[07:43] Bill Yeah, and they’re absolutely fine with it. Uh, they expect it. Uh, they watch TV, they watch movies, okay? Attorneys aren’t supposed to be nice; they’re supposed to be aggressive. And I think when you have a huge difference between approaches, it’s very, very obvious. It’s like, hey, this team’s throwing the ball and they’re throwing it deep, and this guy’s—he’s running it for three yards a carry. Well, those are two very different approaches and the juries pick up on that really fast. I think this is all—I’m gonna give this psychological answer—this is all learned behavior. Okay, this is how this started, and some of this is very reptile-based. It’s learned behavior, meaning—and Paul said the magic words—these people talk. The plaintiffs’ bar, they trade notes. So one guy does something right in the courtroom that maybe is judged as outrageous by a defense attorney, and guess what? They hit on nuclear verdict. This guy goes and tells everybody, “Hey, look what I just pulled off.” Everybody else starts trying it, and that system has multiplied exponentially across the country, and they all copy each other’s tactics and they’ll tweak them a little bit for their venue, for their particular jury pool. It’s been working, and that’s why we’ve seen this level of aggressiveness kick up.
The second reason that’s kicked up is there are these uh—well, there’s two of them really—formal training programs to teach you how to do this stuff, whereas the defense has nothing. Reptile, Trojan Horse. You can go and pay for training to learn how to be an aggressive litigator in front of a jury, learn these tricks, gain that confidence and how to be aggressive and—and push it right to the line. Now, you’re gonna have to pay for it, but those training programs are out there and they’re booked solid from our—from our research. Uh, a third reason this is happening is litigation financing. It used to be back in the day where the plaintiff attorney would put up his own money, right? And that’s why maybe he or she would be aggressive. Now, if you get a third-party litigation—litigation slush fund who says, “Hey, I’ll—I’ll fund the case, you just go win, baby,” there’s kind of nothing to lose. I—so I think that’s why you’re seeing this is happening. And it’s still kind of staggering that the defense bar as a whole has not really come out with the plan to um, to address this. That’s actually my—firm by firm.
[10:18] Steve That’s a good point actually. I wanted to segue into that and actually um, ask Matt, you know, the—the defense bar is a little bit less open with their conversations in that. Could you talk to a little bit more about that? I mean, is it—how is it looking that the defense bar is starting to come together a little bit more and say, “Hey, you know, the plaintiff bar is really reaching out to one another and sharing information and stuff, we should start doing the same thing,” or is it one of those things that is still more of a tightly held belief?
[10:48] Matthew Well, the elephant in the room—and I’m sure Paul will agree—all defense lawyers are in competition with each other. So that disturbs, to some extent, our professional, you know, exchange of strategies and ideas. Having said that, I think we’ve all realized we better get with it. And so we have state organizations and national organizations, uh, you know, from DRI to FDCC to other very established, prominent, successful organizations of defense lawyers, and we’re beginning to exchange more ideas, participate in seminars together, strategies, trial, whatnot together, reading each other’s uh, position papers, if you will, or other blog uh, you know, articles or information. So I think that’s changing. I think the defense bar is waking up. Unfortunately, for some reason, the defense bar just can’t seem to keep the pace, let’s say, of the plaintiff’s bar. But we’re catching up. Paul, I don’t know how you feel about that, if you see it differently.
[11:50] Paul No, I—I absolutely do. And I—I think for those of us that do work for insurance carriers, we get the—the extra layer of—of—I—I don’t want to say problems but uh, of complications. You know, I’m—I’m hearing from my friends on the plaintiff’s bar, you know, they’ll mock these high-value cases five times, seven times, ten times over the life of the case. And sometimes it’ll be a full-blown uh—it’ll be multiple full-blown one-day, two-day mock trials. Others it’ll be, “You know, let’s just get random 10 people off the street and just talk about it, be a focus group.” But they’re doing that level of research because they know that’s how they can, you know, drill down during discovery on the key issues, and then that transit—transitions into experts and then it transitions into the trial presentation. So by the time they get to trial, they know exactly what are the key phrases, in addition to the—the reptile and the Trojan Horse tactics. It’s all of the—the research that they do on these things.
Whereas us on the—the defense side, a lot of times our clients and the insurers, they will say, “Well no, you can’t talk to anybody in the firm or you know, you—uh, about it, or we won’t pay you to do that, or if you’re going to do a mock trial, it’s got to be as cheap as possible, maybe even online, and you’re not going to really get any usable data.” And that’s only going to be in the build-up to trial. You know, it’s—it’s one of those things where some of these cases, they deserve much more attention to the pre-trial workup so that we can as the defense counsel appropriately adjust strategy and tell the client, “Hey, this is something where we think we have a good shot at defending this, however, here’s the downside.” Uh, you know, it’s—it’s more about empowering us, or what we need I think as the defense bar is being able to be empowered to have that frank conversation with the client saying, “Hey, here are the upsides, here are the downsides, uh, this is the research that backs it up. It’s not just, you know, uh, my—my word or Matt’s word, but we’ve—we’ve done this and here’s the value on the case. Let’s either go full-blown, full—full-throttle to trial or let’s try and shut this thing down and save some money.”
[14:15] Matthew Absolutely agree with you, Paul. Absolutely. Those are excellent points. You know, let me just add one other thought to that. Before we mediate a case, certainly before we try the case—let’s back up to mediation—I’ll recommend to clients that we might want to do some scientific research on this. How about, you know, a mock or a focus or some combination? Let’s make sure we don’t miss an opportunity to settle a case for less than what we might get hit for at trial, and let’s make sure we don’t overpay a case that we might do better at at trial. So that’s the purpose of investing in something like that at that point in the case. But I agree with you, I would love to do these focus and mocks on the front end of a high-exposure, high-risk case—which are a lot of the cases you and I seem to be handling now, that the farm cases—because it’ll help steer and guide us successfully throughout discovery. And Paul, these cases are lost in discovery because of politics—the witness is not properly prepared.
[15:09] Paul I—I can tell you, uh, I had a case uh, a couple years ago, when a court-ordered mediation a couple months before trial. Uh, I think it was like two days before the mediation, we get a letter from the plaintiff’s counsel saying, uh, “Due to new information, we are withdrawing our demand. We will only accept if you, you know, pay above and beyond all policy.” Uh, and I’m like, new information? These—these guys just mock tried this case and just learned something. Fast forward to the end of the trial, um, you know, it settled during trial uh, right at the end of trial but before the verdict, and I asked the plaintiff’s counsel, “You remember that letter that you sent out? Did you guys do a mock?” And it was like, “Yes, we did. And not only did we do a mock, we actually had our clients uh, do examinations in front of the jury, and the jurors just absolutely loved the clients.” And on a damages-heavy case, that—that—that was the new information they had to go towards a nuclear level of uh, settlement uh, ranges.
[16:17] Steve That’s interesting. Bill, I know you’ve been—
[16:19] Matthew Can I just ask one other question, Steve? I don’t want to interrupt you, but I gotta ask.
[16:22] Steve Go ahead.
[16:23] Matthew You know, I’m at the point now on these high-risk cases, I will just say, “Look, I—I want and really ask and expect a jury consultant like Steve or Bill or somebody from their group with me at trial. If we can’t get a written juror questionnaire through on the front end, then I want them there at trial to at least help me deselect, so to speak, the jury—I don’t want to say I insist on it, but I strongly recommend it.” I don’t know if you’re doing that or not. I want to hear what you had to say about it.
[16:53] Paul Well, I—I absolutely am because it’s—it’s one of those things where the more information, even if you’re in trial, you know, the client is still going to be evaluating whether or not they attempt to resolve this case. You know, our job as trial lawyers is to focus on the trial. Um, I don’t want to spend time thinking about, “Okay, this is what the jurors are thinking,” or—or, you know, the settlement side of things. I got to focus on the—the expert the next day or the plaintiff the next day. Um, but you know, those—having Bill or Steve or—or any competent person in terms of a jury consultant sitting there in trial helping you out is—is a huge, huge benefit. Also, some of these cases also warrant a shadow jury, uh, and we’ve used those from time to time. And, you know, it’s—it’s interesting hearing it from four people instead of uh, every day instead of, you know, at the end when it’s the, you know, “Has the jury reached a verdict?”
[17:53] Steve Those are all—all great points. Bill, I want to shift back to you then. When we’re talking about, you know, they discussed bringing in jury consultants to sit there, you know, at trial or to help assist at trial, from a juror or attorney demeanor perspective in the trial strategy perspective, how would you go about suggesting to defense attorneys they change their approach and help, as we would say, fight fire with fire?
[18:18] Bill Yeah, well here’s the problem. And so what Matt—what particularly Matt and Paul just pointed out. When you have your adversary doing multiple mock trials across multiple cases, right? And let’s take a three-year span. Okay, they—those attorneys are honing their skills literally ten times the amount as defense attorneys. That’s like two football teams, like, “Okay, well Clemson, you’re gonna practice ten times and Notre Dame, you’re gonna practice once.” That makes a big difference at the end of the season, right? And so the problem is because of the—I see what the attorneys here are saying is, “Hey, the mock trials provide us with strategic value to help us try the case.” What it also does is what no one’s talking about: it gives you, and particularly your younger attorneys, exposure in front of mock jurors practicing opening statements, practicing cross-examinations. I think that’s the biggest factor here is if you’re going to be a very aggressive plaintiff attorney, you’re going to take it to that line and you’re going to push it. Well, if you’ve mock tried your case seven times already and you’ve been down this road and you know where that line is, you feel very confident about that. If you’re a defense counsel and you weren’t allowed to do a mock trial and you haven’t tried a case in a year and now you—you see the—this is—this is not—this is a—a—a gunfight that you’re bringing a knife to, and you’re—and you’re gonna lose.
[19:54] Steve Excellent.
[19:55] Bill So—so how do you get these people trained up is I think what your client—I think what the corporate clients and insurance clients need to get through their head, which they have not. So I’m not really sure how much the defense bar is catching up, maybe on the corporate side, but not—certainly not the insurance side. Is the mock trial—yes, is it expensive? Yes. Does it provide value? Yes. But it goes well beyond strategic. You’re training your young attorneys for years to come, and you’re making—and by the way, trust me, if you don’t use it, right, you lose it. So even Matt and Paul, veteran experience, they want to do the mocks to hone their skills, right? They want to get ready for the big fight. So I think the value of these mocks and focus groups and having attorneys doing presentations regularly keeps your skill set very high, because that’s exactly what the plaintiff’s bar is doing. And I think that’s why they’re so damn good in the courtroom is because they’re using those skills week by week and the defense is not allowed to do that because no one wants to pay for it.
[21:04] Steve Actually, and I think you brought up a good point, Bill, and I wanted to close with this real question or discussion. Is—Paul, we’ll start with you. You know, Bill mentioned about young attorneys, getting young attorneys up on their feet and getting young attorneys this experience trying cases and being in front of jurors. What kind of advice would you give to younger attorneys as far as how to develop this more assertive style that you found to be beneficial for you?
[21:29] Paul Well, what I would say first and foremost is basically piggybacking off of what Bill just said. Uh, at my old firm, I was presented with an opportunity one day, it’s like, “Hey, do you want to do a mock trial? You’re going to do a plaintiff’s presentation.” Um, I didn’t know anything about the case, I took it, ran with it. Uh, by the time I—I walked out of there uh, the beginning of this month, I think I’ve done 24 or 25 mock trials. And it’s—it’s one of those where Bill is absolutely right. You get as a younger attorney, which I still like to consider myself, um, you get the opportunity to stand in front of 30 some odd people and argue a case. It’s—it’s a lot different if you’re just talking to your associate or to your secretary or your paralegal. This is 30 strangers that you are trying to persuade. And that argument right then and there is one of the best things uh, for developing the assertive style.
I would also say—and one—one of the biggest areas where the defense bar is uniformly weak is deposition witness preparation. I love witness preparation. It’s—it’s a lot of fun because I get to go in and just beat the ever-living snot out of my witness. But that’s where you are—you tell them, “This is—this is—you know, the hope is it’s going to never be this bad, but we’re going to put—we’re going to plan and prepare for any contingency. We’re going to, you know, bring up anything and everything that may be thrown at you, and we’re going to twist your words and make you feel absolutely at sixes and sevens.” That’s great for the witness, but it’s also a great tool for the lawyer because witness preparation—you know, that skills you’re using there—that translates into taking a good deposition, that then translates into being able to stand in front of a jury, a judge, opposing counsel, uh, your clients in the courtroom and be able to cross-examine a witness because you’ve already—you’ve done it so often in the, you know, the practice setting and then the—the, you know, the the truly game, quote-unquote, the game setting of a deposition. But there is nothing like a trial. It’s like pre-season, regular season, and then the Super Bowl. And you got to take every opportunity that’s given for it—given to you, and you’ve got to try and figure out ways to get more opportunities. And you always want feedback. I always want feedback. I want to know what I did well, I want to know what I did wrong throughout everything that I do. Uh, I—I—I am not going to be one that just rests on my laurels like, “Oh my goodness—I’ve made it, I’m—I’m a partner in a law firm.” Yeah, that—no. I—one thing I’ve heard at many mock trials is the—the older generation just are not connecting with juries because they’re using the—the tactics—they don’t listen to what the mock juries are saying, and then they take that into the trial uh, and they have the same—same foible. So I always look for feedback, even ones that hurt my feeling, because I want to keep learning and I want to keep learning and keep growing as a lawyer.
[24:47] Steve That’s excellent. And then Matt, we’ll close up with you. Kind of what are your thoughts on this and what are your—what are your suggestions?
[24:55] Matthew I think Paul gave excellent advice. What I do in every mock: I’m the plaintiff lawyer and the associate on the case with me is the defense lawyer, so they get the experience of being the defense lawyer in the mock trial setting. I’m the son of a plaintiff’s lawyer, which is why I want to be the plaintiff lawyer; that’s what we do. All right. Another thing we do is what Paul said in the 30v6 deposition prep or in witness prep. We’ll exchange the cross-examination. All right, take a shot, I’ll take a shot. “How would you answer this question? I’m going to ask you a few questions now,” that type of thing.
And the last thing I tell young lawyers because as we all know, um, too few cases seem to be tried these days. I mean some do, but for as many—I think I mock trial more cases than I try now. Paul, I don’t know if you’re in the same situation but—
[25:44] Paul Absolutely, absolutely.
[25:45] Matthew So I—I—I remember doing this when I was younger. I didn’t—I thought I was getting a lot of trials but I wasn’t getting enough trials. I had to figure out how can I hone my skills, how can I develop, you know, good techniques of presentation and persuasion and entertainment also. And so my recommendation is, we’re in the Bible Belt: where do you go to church? Do they have a Sunday school program? Go teach a Sunday school class every Sunday. 20, 30 minutes, you’re presenting something, you’re engaging in facilitating discussion like jury selection. “What do you think about this? Does anybody see it differently? Let me show and tell you what this lesson is about.” That type of thing. I’ve recommended that, I’ve done it, I think it’s helped me actually.
[26:30] Bill I—I actually have the final word here because uh—because I said so. And by the way, if I go anywhere near a church, there’s a strong chance I’ll be struck by lightning, so I try to avoid that—that type of venue. Um, I really think the answer to this um, which I kind of knew before we started, but based on this discussion I’m going to bring up again—and maybe you’ve heard about this. I don’t believe, after 17 years of doing this, that the defense bar has it in them to catch up to the plaintiff’s bar. Rather, this is going to happen on a firm-by-firm basis. So what I have been seeing—and I have actually been a faculty member on many of these—is many um—many law firms, defense firms, are taking a week per year, which is not a lot, but at least it’s something, and doing their like trial tactics university. And they’re forcing their associates to do these mock trials, to do these focus groups, and it’s all mock stuff, but they’re putting on internal training programs because they cannot rely on the insurance companies to provide them with enough volume to train their own folks. So what do they do? Once or twice a year, they do the trial tactics university, and these associates have to go through the trial process. And I—I see that as where the answer is. This is what I’ve seen from law firms. I would love to hear your—your take on that, because I don’t think clients are—are going to pay for it. I think law firms are going to have to go firm by firm and train their own folks to be better attorneys rather than—rather than them really rely on the defense bar as a whole.
[28:21] Paul I think that, you know, it’s—I—I—I pride myself on wanting to make those that work with me better. I’m just as like—I want the—as I want them to make me better. And so I—I’ve always embraced the concept of training uh, associates and young attorneys to—to learn to do the things that, you know, 15 years ago I didn’t know anything about. So it’s internal training is definitely the start, because something’s got to change. Otherwise uh, carriers and corporate clients are going to just start settling and settling fast before any real litigation goes if we—we are not providing any value as defense counsel uh, to lower their exposure on these uh—on these catastrophic claims.
[29:08] Steve Excellent. All right, so that—with that we will wrap up today’s podcast. Matt, Paul, Bill, thanks for being on. Uh, Matt, if someone wants to get a hold of you, how do they get a hold of you?
[29:21] Matthew Just look me up on the internet in Atlanta, Georgia. Matt Moffett. And Merry Christmas to all of you.
[29:28] Steve All right. Paul, how do we find you?
[29:32] Paul Uh, you can uh, go to uh, my firm’s website at uh—my firm is Segal McCambridge Singer & Mahoney, it’s smsm.com. You can also do what—what Matt said and just do a Google search. But happy holidays, Merry Christmas, and uh, hopefully everybody is—is doing well as we round out this year of years, and hopefully 2021 is actually going to turn and—and be a little better than this—this year.
[29:59] Steve Let’s hope so. Finally, Bill, how do we get a hold of you?
[30:03] Bill Uh, the back of your milk carton would be a good place to start. Uh, but just go to—uh, to get a hold of Steve or I, go to our courtroomsciences.com website or go to LinkedIn and—and put our names in there. And anybody watching this that wants more information, happy to—uh, happy to discuss it with you.
[30:23] Steve All right. All right, gentlemen, thank you. I truly appreciate it. I’m glad were able to get you all on this. This was a great discussion and hopefully to look forward to further discussions with—with both you and Bill in the future. So that’ll do it for today’s episode of the Litigation Psychology Podcast. Goodbye.
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