Attorney Nick Rauch with Larson King in St. Paul, Minnesota joins the podcast and talks with Dr. Bill Kanasky about his recent article in For the Defense on counter anchoring and the reverse reptile and how he has used reverse reptile in depositions. Nick explains the concepts of anchoring and counter-anchoring and shares examples to describe this psychological concept and how it influences jurors. Nick and Bill also talk about leveraging counter anchoring throughout the litigation process, not just at trial and the importance of practicing the skills to defend against reptile, plus more.

Full Episode Transcript

 

[00:00] Bill All right, welcome to another episode of the Litigation Psychology Podcast brought to you by Courtroom Sciences CSI. March Madness version here with our very special guest Nick Rauch. Nick, how are you doing up there in, uh, Minnesota?

[00:23] Nick We’re doing well up here. Uh, you know, it’s, uh, we’ve reached now the end of March which usually means that the snow is away by now but we’re accustomed to having snowfall in April which i’m sure mr Orlando down there…

[00:39] Bill Dr. Orlando. Um, well yeah listen early listen, uh, when the snow melts in June, uh, we’ll have that discussion okay. Um, um, quick question. Um, we all know what’s going on, uh, in your town right now with, uh, the big George Floyd trial. Um, it’s got to be distracting as a professional to, to work in that environment when your hometown is like that. I mean do you, you and your colleagues talk about that and kind of how to keep focused because it has to be very well just distracting overall from the social issues but then just i think i would think emotionally it’s distracting too right?

[01:17] Nick Well you know i to, to both points you know it is, um, and and here’s what i’ll say is you know whether you worked in a small business, whether you worked in a big business, whether you were legal, non-legal, it really doesn’t matter. The, the impact of the George Floyd issue has, uh, widespreading you know touches across all businesses in the twin cities and the state of minnesota i’d say. Um, and so you know right now they’re in the middle of jury selection, they anticipate that’s going to go for maybe even another couple weeks. And the big issue i think has been interesting has been the impact of the civil settlement that just came out on how they’re picking a jury on the criminal side. And so you follow the news the last couple of days, they’ve actually brought back in jurors to say you know with the 27 million dollar settlement that just came out are you still able to be fair and impartial? And i think that’s a, that’s a, that’s a valid question right?

[02:14] Bill Yeah.

[02:15] Nick And yeah and not only you know does that have complications i think with the criminal trial, i think it has complications otherwise with other trials that are going on or about to go on in the state of minnesota and jurors expectations of number settlement value. I mean it’s, it’s wide reaching in a lot of respects.

[02:33] Bill Wow. Wow. It’s a wow, that’s a, that’s a tough situation to be in. We’ll monitor you just stay safe up there okay. Um, so i listen i looked at your background. Um, your CV is quite ridiculous i gotta say i was even maybe a little bit jealous.

[02:49] Nick My mom will be very proud that you said that thank you so much.

[02:53] Bill Have your mom watch the podcast please we need all the subscribers we can get. Can you tell me, uh, because everybody gets into law a different way what what was it about you? And do me a favor, do not do what the last 14 people have done on the show saying i was in the fifth grade and i would i knew i was going to be a lawyer. No you didn’t, you were going to be something else and it finally settled on law. How did that process go?

[03:18] Nick Okay well, um, so i’ll i will start off not like anybody you’ve ever had so i had no expectations to be an attorney. Uh, i, i have no in my family, i have no judges, i have no attorneys, i have no legal background whatsoever coming into law school. Um, so what happened was i actually my junior year in undergrad i did an internship at the Iowa Cubs, which is the AAA team for the Chicago Cubs baseball team. And, um, it was a great it was a great summer, um, had a great time and i was a marketing intern that basically would go through the marketing contracts and proposals and just make sure they happened during the season right? It was, it’s a, it’s a 20 something year old’s dream internship during the summer especially for a baseball guy like me it was huge. And so we get to the end of the summer and the GM i was working for said, hey Nick we loved having you, if you like doing this type of stuff you should think about going to law school because actually some of the bigger name teams are hiring people if they have JD because they need to know how contracts work. Um, my initial reaction to that conversation i remember was i’m not smart enough nor am i qualified enough to go to law school, i have no background, it’s not me, i’m not doing it. And, uh, i had a luckily a, a girlfriend at the time now was my wife and family at the time who said you should do this why not take the LSAT just see what happens. So took the LSAT, um, went decent enough that i could get into Drake Law School in Des Moines. I’m a Des Moines guy that’s where i grew up, um, so i went to Drake just because i, i could live with in my mom’s basement and have cooking and laundry and everything and it just worked out. Um, and then i, i once i started getting into it you know i, i originally thought i was just gonna go to law school to do sports law and i just ended up loving the litigation aspects of it and i did a lot of mock trial moot court, uh, and then towards the 2L and 3L year of my time in at Drake Law i applied to do our student license internships which at that point in time were with the Dallas County Attorney’s Office and the Polk County Attorney’s Office. And i liked this litigation stuff so much that the prospect of those internships was intriguing to me because they said as a law student you’ll be able to get in the courtroom and try cases if you want to. I took that to the fullest extent and by the time i had graduated from Drake my 3L year i had tried either first or second chair tried seven jury trials front to back. Um, which was awesome and i’m extremely grateful for the mentors and the opportunities that i had to get that done because it really did set me up to, to go and do litigation and trial work. And so, um, after doing the criminal stuff for a little bit, um, i, i loved it but i knew i wanted to do more of the civil type, um, stuff to get more personal injury wrongful death type disputes. And my wife ended up getting into grad school up here in the twin cities at St. Kate’s so we moved up here about three years ago and since then i’ve been at i was at a smaller firm in Minneapolis and now i’m here at Larson King in St. Paul. So it’s just funny how the world revolves.

[06:25] Bill That’s a great story, um, and you’re probably avoiding sports was probably a good thing. My cousin actually does that and says it’s the biggest pain in the ass. Uh, it’s nothing but babysitting, it’s like babysitting children all day, he can’t stand it. So, uh, and by the way i took the LSAT as well which is why i am a clinical psychologist and not an attorney. That solved that problem really really quickly. Listen man, you came out with this paper. This paper, um, i, i found to be very intriguing and, uh, i don’t have the title right in front of me which means i’m a really terrible, uh, host but it really focused a lot on, um, reverse reptile and anchoring of damages. Uh, which those two things go hand in hand and, um, i’ve done a lot of public speaking on this this issue as have you and then somebody from California sends me this paper and typically here’s how this goes: i get the email and the email usually says don’t be mad, right? Or you’re gonna be really really mad. And i’m like i open it up and then it’s some paper and it’s typically some author that’s plagiarized me 19 times, uh, copying my reptile stuff right here and i’m not getting credit. Then i read it and my head starts to explode. Uh, this was the opposite. This guy i get so i get the, uh, i get the paper, um, through this email and the email says, “Bill like something like i think this guy is a man crush on you, this guy cited you i, i lost track how many times he cited you, you need to, you need to send this paper around Bill he actually cited you so many times.” So number one thank you Nick for i really appreciate that, i really appreciate the citations. But number two tell me what what what gave you the ideas to write that paper because i got to tell you it was one of the most well-written papers i have seen because again i have no problem telling the truth however this is what gets me in the most trouble. Most of the reptile papers out there that have been written by attorneys quite frankly they just it’s a lot of regurgitation of stuff that we already know. Yours, yours was not. Can you tell me what sparked that idea to write this paper?

[08:46] Nick Yeah so first of all, um, i’m i should be the one thinking you so i mean in doing the research for this paper you know we, we wanted to pull from all the sources we could and your name Bill came up across the board. So i, i mean really i should be the one thanking you for having the groundwork to even write this paper. Uh, and even just to be here on this podcast i and Bill did not tell me to say this i listen this podcast all the time. Um, i, i travel a lot for work and doing trucking inspections and all kinds of stuff and this is one of the ones that it’s, it’s you know it’s short enough in 20 or so minutes that i’m able to, to put it on. So i just i appreciate it i’m a big fan boy so i’m happy to be here and Bill did not pay me to say that.

[09:23] Bill The advertising check is in the mail in the i’m going to fedex i’m going to fedex that check is what i’m going to do thank you.

[09:31] Nick No but you know where it came from and, um, my my partner and i and colleague Mark Solheim we were sitting down and we’re prepping for, um, a week-long, uh, trip up to northern minnesota for depositions and we had just been through a mediation with a plaintiff’s attorney who was anchoring us the entire day was just really painful. And then we had sat through another week about three months prior with reptile questions across the board. And so i remember distinctly you know we’re sitting in this conference room prepping for these depositions and we finally just said you know it’s, it’s five o’clock the light the sun’s starting to go down it was winter time and we said you know what why aren’t we doing this? You know why, why aren’t we taking the techniques that are being used against us and why aren’t we going the offensive? You know we bring in our corporate reps we do a prep for eight hours we’re prepping them we’re on the defensive. Why don’t we go on the offensive? Why are we so stuck in this mindset of we have to step back and defend and block and do all this when we could go on the offensive? And so what it was was let’s go out there, let’s find the information the science we need to, to tell other defense practitioners hey you know that five hours you spend sitting there thinking about how to defend your depo? Maybe spend an hour of that thinking about when you depose their next rep. Yeah or you’d depose the plaintiff again how are you gonna circle back and use the same topics on them? You know these topics were, were created, were drafted, were cited, were studied because they’re based in psychology right? Psychology isn’t just for the plaintiffs bar to use right? It’s for everyone to use and so that’s what prompted the paper.

[11:14] Bill Outstanding. Well, um, again i, i love the paper. It’s funny the defense bar it’s like they go on defense first right? They defer the kickoff for so and they go to the prevent and you know what they say about the prevent defense and football right? It prevents you from winning right? If you’re on defense you can blitz right? Um, define now i’m going to ask you something very basic. Because i want you to show off a little bit but i’m asking you this question because you’d be shocked how many attorneys i’m not going to name names, you’d be shocked how many insurance claims people don’t know what anchoring and counter anchoring actually mean. So can you please just give some basic definitions of these concepts because this is i think this is the one of the hottest topics going on right now because it’s happening at every trial.

[12:05] Nick Here’s how i explain this and and Mark and i present on this topic to a lot of defense organizations and here’s the best way i can explain it. And anchoring in my mind when i think about it is the concept of reference points okay? So we all have reference points in our head for what something is worth. I can say Bill give me the cost of a 12 pack of diet coke and you’d say oh it’s probably five or six dollars whatever it is and i’d say okay now Bill give me the cost of a you know a ticket to a tampa bay buccaneers game okay well it’s probably 200 300 bucks depending on where you’re sitting and that’s just based upon your experience as a consumer your experience just as Bill as someone who’s done those things repeatedly over time. But then if i said Bill give me the cost of a brand new lamborghini you say well i don’t have a lamborghini i don’t know what it is i, i’ve never had one before and i said okay Bill well let’s say i sit down with you and i say Bill a cost of a brand new lamborghini is a, is a hundred thousand dollars and you’d say well i, i don’t know how much it’s worth how am i supposed to know if it’s one way or the other? And then i bring in, i bring in an expert and the expert says yeah Bill it’s a hundred thousand dollars and then i show you the manual, manual says it’s a hundred thousand dollars car value and then i bring in other people who have bought lamborghinis and they say yeah it’s actually a hundred thousand dollars. At that point in time Bill’s sitting there and say okay well it’s probably a hundred thousand dollars. Now if we take a pause just right there for a second, it’s exactly what plaintiff’s counsel claims attorneys are doing to juries all across the united states every case. And what they’re doing it what if anybody listening is caught on they know that the jury that you’re in front of usually doesn’t have any experience valuing an injury valuing a death valuing or whatever it is…

[13:47] Bill Nope.

[13:48] Nick And so the concept of reference points is if you don’t have a reference point for a certain position or a certain value the human mind will latch on to the first piece of information it hears and takes that as value right? So in a jury trial you have a plaintiff’s attorney who gets up there in closing and says the cost of medical expenses life care planning whatever is 50 million dollars. As a juror as someone who has no experience you say yeah you know what it probably could be 50 million dollars. That reference point right immediately serves as the anchor, it immediately serves as the starting point for where that juror is thinking for the remainder of those closing arguments and going into it. That’s what i think is so fascinating about anchoring is it it’s a psychological concept that if you don’t have a reference point you’re just gonna latch onto that number and then it does anchor you for the rest of the time. And so in my terms that’s kind of a long definition of it but it’s, it’s anchoring to anchor that juror or anchor that person of a reference point so that they add value to that and they see that as truth going into deliberations.

[14:57] Bill Yeah and then you also have the timing of the anchor which is just as important. And so what you’ve seen the players bar moving is to, um, anchoring in the first two or three sentences of their opening statement to get the number out there and keep repeating that number and then they’ve heard that number the whole trial. And and then let’s talk talk about the dangers. I mean again i know all this stuff i, i like i’d like to hear you explain it because then you can show off a little bit but if you don’t counter anchor well first of all what’s a counter anchor? And if you don’t counter anchor what’s ultimately going to happen right?

[15:32] Nick So the paper talks about, uh, it was either the campbell or the study i can’t remember which one it was they talk about the four different ways to counter an anchor and there is, uh, to ignore, to identify, to counter anchor, or to counter and identify. Um, and all of them if you just take the word by itself you’ll understand what it means but to counter essentially is to give the jurors another reasonable number or a reasonable reference point to the number that was already presented by plaintiff’s council. And so you know we, we get this all the time and actually Mark and i got a question we were presenting to a local bar organization for this and we had a attorney ask well you know i’ve been trying cases my entire life and i never bring up damages i don’t even talk about it and, and we said okay you know and honestly we don’t have all we don’t have the answers sure and i’m not an expert i don’t intend to be, uh, but i just think that if you don’t counter you’re, you’re gambling that your liability argument is so good that it’s going to it. But if it’s not just think about the position you’re in. The only number that that jury has heard for last 10 minutes to seven days has been that 50 million dollar number so how are they going to base it how do they have another reference point? And so i, i think counter anchoring is something that can’t be oversold especially if it’s a case where you think you have you know the chances for any type of excessive liability i think it’s something you have to think about and have to be intentional about when you’re drafting your closing statement and and when you’re drafting any of your submissions.

[17:07] Bill Yeah it’s funny how you mention, uh, how that discussion always starts. I’ve been trying cases for 30 years and then they start going on why they don’t mention it’s a different jury pool and i i quite frankly think anchoring works with Gen X, Gen Y a lot better than it does, uh, with the you know with the boomers and war generation so it’s a very powerful effect. They’re using it early i’ve advised all my clients in fact i’m in, uh, well i can’t tell you which there’s a trial going on right now in Iowa that i’ve been deeply involved with all week so if you look it up you’re going to figure out which is this one. And i told this attorney i go if he anchors damages in this opening statement it better be the first thing out of your mouth in your opening you better do it. Because if you don’t you’re going to be in big trouble because this is going to drop that number the whole trial and then it’s again once they have that number wow, uh, yeah because the the danger here which is a grave danger. Remember the movie Grave Danger any is there any other kind that was called A Few Good Men Jack Nicholson thank you very much. But it is a grave danger to just let that number go because yeah if you lose then the jury goes well what should we award? Well we only heard one number which is terrible. And then the other the other thing that i see going on here is the what i call double anchoring i just invented that term by the way meaning it’s like you know okay so my sister called me she’s like, uh, I’m interviewing for this job i go how much i don’t know she’s like i don’t know how to interview very well or negotiate what do you want to make? She goes well i, i really want to make a hundred thousand dollars i go ask for 200. If they, if they cut it in half they think they’re sticking it to you and you get exactly what you want. So what the plaintiff’s bar is doing i just had a mock trial we did this where the the mock jury sits down i kid you not they sit down at deliberations and the fore person goes can you believe the gall and just greediness of that plaintiff attorney? This, this guy wants a hundred and fifty million dollars we’re only going to give him 75. We’re going to show him there’s no way we’re giving we’re going to really stick it to this guy while he’s laughing to the bank and i’m just like have you seen this? So i call it double anchoring meaning not just anchor, anchor way above so if it does get cut you’re right where you want to be anyway that’s something i’m seeing now and it’s also something i see the plaintiff’s bar using in negotiations to threaten to say hey listen if you don’t give me what i want right now before trial in this nuclear settlement right i’m going to ask for this at trial and you don’t want me to do that and it puts the defense in a very, uh, let’s just say difficult position correct?

[20:08] Nick Well it puts it in a difficult position and i think the other side of this too is is to your tail point which is you know anchoring is it it certainly is something to consider for jury trials obviously and it’s something that we think about all the time when we’re prepping for a trial but it’s also something that can’t be overstated in just your day-to-day right? From, from, from when the claim comes in from your adjuster to when you are first communicating with plaintiff’s counsel to when you’re exchanging communications to when you go to, to mediation, um, presenting counterpoints and reference points and making sure you’re being intentional with counter anchoring. You can do that all the way through litigation and it’s just about being more intentional with it i think that’s sometimes overlooked, uh, with attorneys as we get into litigation.

[20:54] Bill Absolutely. And by the way i can prove this scientifically but you know this as well if you counter anchor that does not mean you’re admitting liability it’s just…

[21:03] Nick No it doesn’t.

[21:04] Bill You have to do it the right way right and which just means which i tell i go do it in voir dire if you may not be able to give the number in voir dire but at least drop the hint of hey i’m going to give you an alternative number because that’s my job as an attorney. I don’t even think you’re going to get to anywhere near numbers but if i do that are you going to hold that against me because that’s part of my job? And you tip them off that you’re going to do it and then you take that any any type of liability stuff i think if you save it till the end when you you look like you’re defeated well yeah it looks like you’re admitting liability because you saved it to the end and it looks like your toast right right?

[21:42] Nick I mean i think you have to you have to set the hook early right? And so i think that’s in opening statement and in jury selection it has to be again an intentional point of your prep and an intentional point of the language that you’re using with the jury.

[21:55] Bill So i think it’s important for, um, defense attorneys to learn how to reptile people. I really think it’s important and quite frankly they don’t do it very well and, and and i the reason why is they’re not going to reptile training programs and spending 10 grand a weekend to get this vigorous training. Now i’ve written all these papers to teach them how to do it you’ve just written the paper you know there’s a lot of resources out there that are completely free but i think with anything else in life whether it be sports whether it be litigation i think if you’re a defense attorney you need to read all these articles and start to practice how to do this. You have to learn how to do this and if you struggle i get phone calls all the time can you teach me like very quiet like can you teach me? I’m like yes of course i can what’s your case i’ll reptile you i’ll reptile you right now just tell me what the case facts are and i can do it. And they’re like how the hell did you do that? I go well that’s the last 11 years of studying this stuff scientifically and practicing it with witnesses. What would you recommend particularly young, um, attorneys like you do to get up to speed? Because i, i think those resources are out there but if you don’t get up to it’s actually a very difficult skill to learn it’s not something you’re going to pick up on the fly.

[23:23] Nick No it’s, it’s not and and it’s also something that to your point is a case-by-case basis. I mean it’s something that you have you know the reptile questions you’re going to ask in a trucking case are going to be different than the ones you’re going to ask of you know if you have a products case or or a workplace accident case that you might have. And so you know what i would say is number one, um, i, i learned how to do it just by defending depos right? And so you learn from sitting there and unfortunately having some of your witnesses go through the ringer and and saying okay here’s what they’re doing and learning how to object to it. But what it is you know at its very core is and the the plaintiffs bar has learned creative ways how to do this through the years ever since the the ball and keenan you know dropped it it’s essentially find your the nexus of, of the accent right? And so whether it’s driving conduct or if it’s safety or if it’s you know whatever whatever it is within that set of facts that is going to be the core issue in the case. And it’s a matter of breaking it down to a level of importance that we take just as members of the community and members as human beings. That’s a very hard skill learn how to do i didn’t learn it immediately i had to read transcripts and sit through depositions to learn how to do it now and i’m still not a master at it myself. But once you do that it’s just a matter of breaking it down so that you can build up with that witness the importance of factor to the community and be able then to come back and cross-reference that importance with what happened in the case. Um, it’s a it’s a nuanced skill that, that you know i don’t think enough defense practitioners put in their practice and especially when they’re prepping for party depositions or even you can use them on on fact witnesses or on other people as well.

[25:12] Bill Yeah i need when i did the reverse reptile seminar with attorney Paul Moats in Chicago that was the most attended webinar they’ve ever had in DRI history. I think we need to do part two of that to really break this down so i’m gonna share with everybody right now i wasn’t playing on do this openly share this but you can start pra i reptile in the shower i reptile when i’m driving because all you have to it’s a three-step process. You ready? You have to do it backwards right? You start with the blame question.

[25:43] Nick Yep.

[25:44] Bill Okay you start with the blame question for now let’s take a non-litigation thing right parenting right? Well Bill you’re a terrible parent that’s the that’s the ques if i say yes to that question i’ve admitted guilt right? That’s but that’s the last that can’t be the first question that’s not the system in the reptile right. Now let’s work backwards all right so from the end zone let’s work backwards to where this ball get has to get kicked off from the questions preceding that are factual questions. Well you let your kids stay out too late and you you know you know you have bedtimes nine o’clock and you let them stay up till 10 right? And then first day of march madness you let him skip school like your mother did right? Those are the factual questions that precede the blame question right? And those are facts i have to agree with those. And then where the reptile sequence comes in is the questions before that and that is all the parental rules i’m supposed to follow to be a good parent and it’s, it’s safety rules and litigation right? And employment litigation that’s rules like, um, transparency, trust, loyalty, things like that and it’s like well Bill to be a good parent you gotta you gotta set boundaries correct? All right and if you don’t set good boundaries as a parent your kids can take advantage of you right? You see where i’m going this i can reptile anybody anywhere and i absolutely love it. But that’s the sequence it starts general goes to facts gets to blame. But the way to architect it you start backwards you work with blame you work backwards so in any case you can do that and i think you need to start practicing. I think i need to redo this seminar i think i need like an interactive seminar of, of some people to really, uh, do this. Maybe we could do it for some of you your folks at your at your law firm but really really fun stuff and i’m looking forward, uh, to working with you on it, uh, hopefully really soon. Let’s wrap this up with a topic, um, overall impressions of virtual depositions yay or nay?

[27:49] Nick Er yay-ish if that’s an answer you know i think number one it’s okay in terms of if you’ve got witnesses that, that you just need to get information from fact witnesses i think that’s fine. For party you know depositions sometimes it’s good to be in the room to gauge how they make as a witness how they interact with people different non-verbal ticks that they may have. But i think that the one struggle that we’re still trying to get over with you know is dealing with exhibits any times and technical issues you know those those things are always going to come up. I think you know i just this morning was sitting in on, um, not depositions but or argument for for the court of appeals, um, that was done through zoom i mean i think that the new norm i think for the foreseeable future is going to be zoom for both depositions and for, um, and for court hearings. And i think you know for for its purpose i think it does exactly what we need to which is allow us to communicate allow us to ask questions and and have a dialogue. But i think long term i think we’ll, we’ll get back to some sense of normalcy with being in person once we figure out the whole vaccination and and our people rate no type deal but, um, i i think at least in our firm everybody has, um, has made that transition really nicely and we all have zoom technology that we’re able to use. And so for the time being i think it’s good i think it’ll wear out in in about a you know maybe a year or so and we’ll get back to normal. But i think it does what we need it to do and and you know we’ve done multiple hundreds of zoom depositions, uh, since the pandemic started.

[29:22] Bill It keeps me out of minnesota in february i’ll tell you that.

[29:25] Nick You’re welcome to came up i don’t know why Bill you’re so hesitant to come out.

[29:29] Bill I like to fish i like to fish up there but i like to come up in august

[29:33] Nick ice fishing it’s fantastic

[29:35] Bill I’ve been ice fishing i grew up in pennsylvania. The the problem ice fishing leads to a different problem you know what i’m talking you know what i’m you know what i’m talking about

[29:45] Nick I have a mentor who told me, you know, ice fishing is really not about fishing.

[29:50] Bill It’s not about the fishing.

[29:53] Nick We’ll leave it there.

[29:55] Bill It’s that cool—it’s that cooler of, you know what you’re sitting on all day with your buddies. And before you know it, it’s no—there’s no longer anything going on about fish. All right, okay. So, here we’re gonna post this—the, I believe I’m pretty darn sure we’re gonna post this podcast the week of the Final Four.

[30:13] Nick Awesome.

[30:14] Bill Okay, so now it starts tonight. I need your, your Cinderella—which means I’m just telling, hey, someone that’s a seven seed or higher that’s going to the Final Four. I have my pick right in front of me, but you’re my guest and I’ll let you go first.

[30:30] Nick Um, okay. So, number one, I’m a Drake Bulldog law school. Uh, Drake is playing tonight, it’s the play-in game. Um, I’m hoping they win. If they win, I think it’ll be tough for them to come out of that bracket with Gonzaga, but it’d be great if they made it. Otherwise, the sleeper pick—the sleeper pick, I think, I think LSU is a really tough team that they could go on a deep run. Um, there’s a bunch of other teams that aren’t high one or two seeds, like Oklahoma State, that, that could also make it too. But I’m just happy we have it, man. We got, we got screwed last year. I look forward to March Madness every year with my family and I’m just—I’m missing it, so I’m just happy it’s back.

[31:07] Bill Those, those damn refs. Okay, now I’m gonna pick my, my Cinderella special right here, and it’s right in front of me. No one’s giving them any credit, and when I say this people will be like, “That’s not a Cinderella.” They’re an 11 seed—Michigan State, baby. The Izzo. I’m taking the Izzo. No one’s paying attention when they play tonight. I’m picking the Izzo to, to just pull the shocker, right? And I’d be okay if my Tar Heels did the same thing, but I just—

[31:34] Nick The other team I heard, too, was Winthrop. Winthrop is like 25 and one.

[31:42] Bill Very dangerous.

[31:43] Nick And I think they’re like an 11 seed, too. I think they’re like something like that. So, I mean, they could make a deep run as well. But on my—the other 90 percent of my family are Iowa State Cyclones, and the Cyclones won a total of two basketball games this year. So, we are not even close to being ready. But, uh, it’s just fun like I said. You just can’t wait for it and, uh, and I’m gonna watch all games tonight and tomorrow and it’ll be a good time.

[32:04] Bill It’s, it’s gonna be fun. I’m, I’m—I’m gonna go to the Vegas odds to see how many teams are gonna get booted because of COVID positive tests, which is actually going to be interesting. Nick Rauch, thank you so much for being on the podcast. Definitely going to do a seminar with you soon, hopefully work on a case with you. Thank you very much for coming, I appreciate it. To our audience, thank you so much for participating again in the Litigation Psychology Podcast brought to you by Courtroom Sciences. We’ll see you next time.

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