Interview with Ryan Squires About His Record-Setting Verdict
We’re joined by Ryan Squires, a partner at Scott, Douglass & McConnico. He is an experienced trial lawyer with many trials under his belt. In this episode, he talks about one specific trial he did in Austin in July 2021.
It was a record-setting verdict in that the jury awarded them worth $40 million in damages and money, something they haven’t seen in the last 20 years in terms of a private plaintiff in Austin. It also answered certain questions in a manner that allowed the judge to also give them a constructive trust that included real estate and Bitcoin.
To give you a brief overview, this was a father versus son case concerning cryptocurrency and some real estate controlled by the son, but those have been traced back to the seed money provided by the father.
Today, Ryan shares what went behind the scenes in preparing for this trial from how they’ve set up the focus groups to gathering evidence and witness preparation.
In this episode, you will hear:
- How they’ve set up focus groups for trial preparation
- Using deposition testimony in court as evidence
- The cross-examination preparation
- COVID protocols observed in the courtroom
- The importance of having time limitations for the witnesses
- The benefits of focus groups in this case
- The challenges in gathering evidence
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Supporting Resources:
To learn more about Ryan Squires and his practice please visit: https://www.scottdoug.com/attorneys/ryan-squires/
If you’d like to learn more about the jury verdict we discussed in this episode, you can go here: https://www.scottdoug.com/sdm-obtains-record-setting-verdict-in-bitcoin-case/
Episode Credits:
If you like this podcast and are thinking of creating your own, consider talking to my producer, Emerald City Productions. They helped me grow and produce the podcast you are listening to right now. Find out more at https://emeraldcitypro.com Let them know we sent you.
Episode Transcript:
Elizabeth Larrick: Hello and welcome back to another episode of Trial Lawyer Prep with me, your host, Elizabeth Larrick.
This is a podcast designed to connect trial lawyers with tips and tricks. and tricks for courtroom connecting with jurors and their own clients. I am very excited to have an interview today with an [00:01:00] exceptional trial lawyer, Brian Squires. He is here in Austin with me, and he’s a partner at Scott Douglas McConnico, and he’s done many, many, many trials, but we are here to talk about one really specific trial that he did here in Austin, an actually record setting verdict.
So I’m excited to have Ryan joining us today. Hello, Ryan.
Brian Squires: Hey, Elizabeth. Thanks for having me.
Elizabeth Larrick: Absolutely. Well, I want us to jump right in and tell us a little bit about why is this a record setting verdict for Austin and then tell us also if you can a little about the case.
Brian Squires: It’s a record setting verdict just in terms of the amount that was awarded by the jury.
I think the jury awarded north of 40 million in damages and money and then also answered certain questions in a manner that allowed the judge to give us some equitable relief in terms of a constructive trust, which included real estate and Bitcoin. And depending on the price of Bitcoin at any given day, it might [00:02:00] be well north of 40 million.
And so I think When we were trying to look at the numbers and see when the last time a Travis County jury gave that type of an award, we looked and we really couldn’t see any in the last 20 years in terms of a private plaintiff. I mean, in Austin, sometimes we have public plaintiffs, maybe even the state of Texas bringing suit against somebody.
And sometimes those numbers are enormous. And so we’ve excluded that. But in terms of a private plaintiff, actual damages. We didn’t see many that were bigger than this.
Elizabeth Larrick: And this was to make it even more unique. It was father versus son, right?
Brian Squires: Yes. Unfortunately, this was a case where the father had essentially provided almost most of the father’s net worth back in the nineties to the son to invest.
And the son did what he did over the course of 15, 20 years. And ultimately Did not give the father [00:03:00] back his share of the ultimate investments, which is why we ended up suing.
Elizabeth Larrick: And one of those things was crypto, right? A lot of crypto.
Brian Squires: It was, it was an interesting part of the case because we had to trace beginning with the father’s money back in the mid nineties.
We had to trace it all the way through the years. In various investments, various liquidations, various reinvestments, which we were able to do. And the jury certainly followed our tracing, but it started off as stocks and stuff like that. And it was moved into some real estate. And then from the real estate, it was moved into cryptocurrency and Bitcoin.
And that’s ultimately over is just some cryptoc controlled by the sun, but which can be traced back to the seed money provided by the father.
Elizabeth Larrick: Gotcha. So what ultimately were the claims [00:04:00] in the suit?
Brian Squires: We had a variety of claims. The theory that we chose to proceed with respect to the final judgment was a trust theory under the trust code.
And we also succeeded on breach of fiduciary duty and unjust enrichment.
Elizabeth Larrick: As far as kind of overall strategy, what were some of the things you guys had in your mind, knowing this is probably not gonna be a case that settles, it’s going to have to go to a trial, go to a jury trial.
Brian Squires: I mean, that’s sort of where you came into play pretty early in the case in terms of the focus groups that we did and just trying to see, because when you’re tracing assets over the course of 20 years.
And sometimes you had the benefit of financial statements. Sometimes you didn’t, sometimes you’re trying to piece together the tracing through. emails and admissions of the defendant, etcetera. We wanted to make sure that we traced those assets in a manner that could [00:05:00] be easily understood. Despite the fact that those investments took many different characterizations, we had to piece it together with evidence that was not just statements, but emails and everything.
We just had to make sure that that message was clear enough. and easy enough to follow that the jury would be able to start here and trace it all the way to here without any real question. And so I think most of the time we did for trial preparation was fine tuning that message so that we could show it in documents, we could show it in pictures on a PowerPoint with a timeline, whatever we could do to simplify it and make it easy to understand is what we focused on.
Elizabeth Larrick: I know that there was a lot of documents and especially a lot of emails between these, all these family members involved for the course of, like you said, 20 years. So how, you know, how’d you guys decide which, which emails were the smoking guns, or did you even give any emails as exhibits? [00:06:00]
Brian Squires: We did give emails as exhibits.
I think there was a ton of emails and there was not just a ton of emails. Some of the emails were extremely lengthy. pages. And so it’s hard to put that type of information in a format that’s easy to grasp and understand and not overwhelm the judge or the jury with paper. And so I think we tried, just like I talked about with respect to the tracing, we tried to pick and use the emails that had statements in there, for example, from the defendant acknowledging dollar amounts on this particular day.
or investments made on this particular day. And I think the focus of the emails was to use them where we didn’t have maybe other evidence, whether it be financial statements or otherwise. to just help plug in any holes on that tracing analysis. And we also had [00:07:00] a defendant who he was an interesting defendant and we needed those emails to sometimes rain in his testimony and get him focused on what he was saying at the time.
versus what he may be saying now.
Elizabeth Larrick: Gotcha. And along the lines of investigating and especially with the defendant, you guys actually went into some of his other divorce lawsuits as well, right?
Brian Squires: We did. And honestly, it was maybe the most important piece of evidence we had because his defense in the case was that dad’s money that he may have had access to or controlled or invested was gone.
Dad had either spin it away or dad had either given it away and thus dad was essentially broke and all the assets that currently existed were all the defendants and the defendants alone and we didn’t [00:08:00] believe that and the jury didn’t believe that but we had to prove it we had to trace it and we had really good tracing evidence starting with dad’s inheritance and sort of the seed money And following that money through the son’s investments and stocks and even some real estate.
But the majority of the wealth that remained at the end of the day was bitcoin and two pieces of real estate, one in Austin and one in Park City. And so obviously we had to show and prove that the bitcoin and the two pieces of real estate. can also be traced back to dad’s money. And we found a deposition that the defendant had given in, I don’t know if it was his divorce proceeding, but I think it was in a, in something related to that.
It might’ve been a [00:09:00] child custody modification type case, but he gave a deposition and it just so happened that the. defendant was asked questions about some of his real estate investments that were important to us prior to obtaining the bitcoin and the two pieces that were at issue in our case. It was investments in some real estate that he had made back in the mid 2000s.
And he acknowledged in that deposition what we had thought all along, which was Dad was invested in those pieces of real estate through him indirectly. And thus, dad may not be on the deed, but dad’s money was invested in those real estate projects. And then he mentioned several of those real estate investments by address.
Several of them had since been foreclosed on, but one had, and the one that had not been foreclosed on turned out to be the smoking gun. As we [00:10:00] Moved forward in time and in tracing that piece of real estate. It was bought back in the mid 2000s. It was then sold somewhere around 2015. And then we saw from there, the proceeds from that sale be used to buy the Bitcoin.
And then some of the Bitcoin be used to buy the house in Park City. And so it was really that deposition testimony that the defendant had given that allowed us to conclusively trace the sort of end of our timeline, which is what we needed to do.
Elizabeth Larrick: Were you able to use that, that other deposition testimony in court as evidence?
Brian Squires: We ultimately were, although I’m not sure that basically the way it happened was, we We were asking the defendant the very same or similar questions that he had been asked at that deposition. We had wanted to [00:11:00] introduce just the excerpt that we cared about. The defendant’s objected. The judge initially wasn’t, I don’t believe, going to allow that deposition testimony to just be entered into evidence.
And so we had to do it through sort of impeachment, if you will. Like we had to ask him the same questions. If he gave us different answers, we had to impeach him. And If I remember correctly, the defendant would not give us the same answers that he gave back in the day when he gave that deposition. You know, certainly before there was any dispute and fight with his dad, all indications where he was being honest in his testimony back in the day.
But we had to impeach him so often that I think that the judge finally said, Look, if we’re just gonna have to impeach every question and answer, we might as well just enter these two pages or whatever it was into evidence Yeah. Eventually they actually did get entered into evidence, but initially I don’t think that was the plan.
Elizabeth Larrick: Gotcha, gotcha. And you were doing the cross exam, is that right?
Brian Squires: [00:12:00] Yes.
Elizabeth Larrick: Okay. So how long did that ultimately take, and was the jury like, could you see if they were frustrated or if they were loving it or, I mean, I know. Tell me a little bit about that cross exam.
Brian Squires: cross examination for this witness took a ton of preparation because I knew that for every question I asked him essentially I need to have backup if he gives me any answer that’s contrary to what I know the answer should be.
And because this litigation span the course of 20 years of correspondence and emails and tracing investments and because we had prior depositions that the defendant had given because we had prior proceedings in this very case, depositions that he had given and or testimony at injunction related proceedings.
I had a lot of material [00:13:00] to go through and master the minutia of. And so the cross examination preparation was extensive. It took a long time and I basically had to have impeaching evidence at the ready for almost every single question I asked. And so I think my cross examination lasted the entire day of trial.
And then the defendant’s direct lasted a day or two. And so the defendant himself was on the stand, I would say most of the first week of trial and then things picked up a little, but he was the most important witness. He had the most important things to say. And so it’s natural, but we did take a long time.
Elizabeth Larrick: Was he your first witness?
Brian Squires: Yes.
Elizabeth Larrick: Okay. Wow. So you guys right out of the gate
Brian Squires: just, yeah, we did. We did openings and then we called our first witness and we called the defendant adversely. And so my cross examination was that entire day after [00:14:00] that. And then the direct happened. Gotcha.
Elizabeth Larrick: And tell me, we jumped a little bit into the trial.
You guys tried this case in July of 2021. So what were, what was going on with the covid protocols? What was the courtroom like? I know you got to do in person, which was pretty amazing for Austin.
Brian Squires: We did, although I think it was touch and go. And I think, you know, I think we were the first in 16 17 months to get to do an in person jury trial.
I think we were the last for another maybe 10 months to do an in person jury trial. One of my partners here just finished a week or two ago. an in person jury trial in Travis County. And so it very well may be that those the only two that have occurred in the last 2. 5 years. I don’t know. I know ours was the first to occur in person since the covid pandemic and the judge did an awesome job in terms of the protocols in place in terms [00:15:00] of wanting to land the plane and get through an entire verdict without people falling off because they’ve been exposed or concerned about exposure.
And so the way the judge did it, which worked fantastic under the circumstances was she rearranged the courtroom completely. The jury sat in the section where the audience usually sits and spaced out. And so we had, I think, 12 jurors and two alternates and they were in the gallery. You had some of the courtroom personnel like the court reporter in the jury box.
You had everybody wearing masks. The attorneys were allowed to take off their masks. and use a face shield if they were the ones asking the questions or making the objections, but otherwise everybody wore masks. The judge wore a mask and was behind some [00:16:00] plexiglass at the bench. They had set up monitors in the courtroom such that the jurors, even though they were in the gallery, could very easily see on these big monitors the evidence that was being presented.
The board dire was done in two stages. Let’s say for number sake, there was 80 people on the panel. Numbers 41 through 80 came in the morning and spread out in the gallery and you did your board dire and then they were allowed to leave at lunch and they weren’t released from juror duty because some of them did not know if they were going to be picked or not, but they were released for the day.
And then you had jurors one through 40 come in in the afternoon, sit in the gallery. You did your voir dire again, and then you made your peremptory strikes and picked your jury that [00:17:00] afternoon. And so most of the jurors I think probably came from that panel of one through 40. But some of them did not.
Some of them were in that back panel and they were given a call later that night and said, you’re on the jury and we need you to report back the next day. And so the next day we had our full jury there. But the judge did an awesome job in making everybody comfortable and under the circumstances getting through an in person jury trial when at the time the pandemic everybody thought had sort of slowed down enough to where we could get an in person jury trial but during our trial it started going up again and I think they they shut the courts down again after our trial for a while.
Elizabeth Larrick: How long ultimately was the trial?
Brian Squires: two weeks.
Elizabeth Larrick: Okay. And nobody came down. No exposures. No,
Brian Squires: nobody came down. I think we we might have let one juror go, but it had nothing to do with the pandemic. I think it was [00:18:00] religious holiday type thing. If I remember correctly, and then we had one alternate, at least at the time that the lawyers were giving closing arguments and she had sat through the entire trial.
And then at the close of evidence before closing argument, she was told, Hey, thank you for your service, but you’re free to go. She stayed. She wanted to hear the closing arguments. She obviously didn’t deliberate, but so it worked. It worked out well, thanks to the judge and everybody else who was taking all those precautions.
Elizabeth Larrick: Yeah, that’s awesome. And I remember that because it was like, oh, yay, we’re getting back. And then it was just you guys at that one trial. So other than the defendant witness, how many other witnesses did you guys have? And how did you manage the time that you had?
Brian Squires: The judge gave us pretty strict time limitations, and I think it was designed to make sure that the jury got the case [00:19:00] at a particular point in that second week such that they could continue deliberating as long as they needed to.
But the judge at the time was starting I think another trial that third week. And so there was no way the trial that we were doing and conducting what was going to be allowed to go past the two weeks. And so We had to divvy up our time accordingly. I don’t think as the plaintiff, we ran into any real time constraints.
The defendants did, I think because they spent so much time with their defendant witness on as the first witness. But we got through all of our witnesses and like any other trial, once Once the story comes out and you’re no longer having to put things in context and the jury sort of knows it, the further down the list of witnesses you go, the shorter the testimony can be.
The jury has the context in the story. They sort of know [00:20:00] everybody’s place. And so as we got towards the end of the trial, some of our witnesses weren’t on the stand. But You know, 15 minutes. Gotcha. I think the jury appreciates.
Elizabeth Larrick: Yeah, I was gonna say, I think one of the things that I’ve been hearing through a lot of trials is a lot of impatience with jurors and they’re showing their impatience very clearly at the lawyers in the room.
Did you guys have any of that kind of feeling or get anything back or have any feedback from the jury while you’re trying the case?
Brian Squires: Not that I could tell, but it was a fascinating case and had interesting personalities involved and certainly a very interesting story. The jury seemed to really pay attention and almost be captivated by the story and the witnesses and coming to the right result.
Elizabeth Larrick: Gotcha. Do you guys have any questions once the jury deliberated?
Brian Squires: We did, I believe, and I can’t remember what it was. I can’t remember. [00:21:00] It wasn’t something that was so material it stuck out in my mind, but we did have at least one question and I think it might have been evidentiary related and the judge may have just told them you have what you have continued deliberating, but that’s the only thing I remember in terms of the questions.
Elizabeth Larrick: Gotcha. Gotcha. Well, was there anything else as far as preparation? You said you really spent a lot of time preparing for cross. Was there anything else that sticks out in your mind about the trial prep that you did?
Brian Squires: The focus groups were extremely helpful because, you know, what every trial lawyer runs into is they are trying to get organized in those few weeks, getting up, getting ready to try the case or trying to get their exhibits organized.
They’re trying to get their witnesses at the ready. They’re trying to deal with all of the local [00:22:00] rules may be about designating page lines and depositions and then objecting to the other side’s page lines. Or there’s just a lot of stuff that happens in that week or two before trial that takes up a lot of time.
And I think a lot of times some trial lawyers put off, for example, preparing a robust opening statement. Or even their board dire because they don’t have the time. They’re dealing with all this other stuff. And so the focus groups we did allowed us to prepare for that ahead of time. And thus, by the time that we got to trial, our opening statement message was clear.
It was done or dire was clear. It was done, and it allowed us to not have to worry about doing all that while we’re in court. In the minutia of the depositions and exhibits and everything else. And so we found that very helpful.
Elizabeth Larrick: Yeah. And you guys [00:23:00] actually, you did three focus groups. So they all were spread out about six months to three months apart.
That sounds like
Brian Squires: that’s right. Yeah.
Elizabeth Larrick: And you did the same thing over and over again. How come you just why can we chose to do the same thing over and over again?
Brian Squires: It was mainly just to fine tune the opening statement. And as we receive new evidence or new information, we might feed that into the focus group and get some feedback.
But for the most part, it was like I said, trying to make sure that our tracing story and the evidence we had to back it up was easy to understand. And a lot of times you do that with a power point or pictures like we used at trial. In our opening statement, we had a timeline and we just wanted to make sure that that was something that Anybody could grasp and it was easy to follow,
Elizabeth Larrick: right?
Because you guys had a lot of time to cover [00:24:00] and a lot of events to cover.
Brian Squires: Exactly.
Elizabeth Larrick: I know that our focus groups we did together, we did almost all of them were virtual.
Brian Squires: I think that’s right.
Elizabeth Larrick: All of them were virtual, but you had an in person trial. Was there any pause or any concern by doing virtual ones?
Brian Squires: I don’t think so. I think that yeah. With technology, especially power points and everything else, as long as you can show your screen and they see what you’re trying to convey in terms of your demonstratives or whatever, then it works out fine. And it probably is easier in terms of making sure you get participants.
They can do it from their own home. They don’t have to come down to a hotel conference room or something like that. So You know, I’m not saying that in the future, I’m only going to do virtual. I think there is some positives of being in person and seeing everybody face to face, but in terms of substance and effectiveness, I didn’t see any issues with the virtual focus groups.[00:25:00]
Elizabeth Larrick: Gotcha. Have you ever, as far as the setup that you use kind of this, you know, repeating that opening statement, have you used that setup before with focus groups?
Brian Squires: I feel like that’s the only thing I’ve done in focus groups in terms of a 30 minute presentation on the plaintiff side, 30 men on presentation on the defense side.
It’s not an opening statement in the sense that you’re showing evidence that you might not get to show in an opening statement. It’s more of a summary of your case presentation and evidence that you can then fine tune for your opening message or opening statement. I know that other people use focus groups to maybe focus on one particular piece of evidence or maybe they’re focusing on witness.
Deposition testimony or credibility, all of which are bought totally valid uses of focus groups, but I think the ones I’ve done have always been here’s our case. Here’s the defense’s case. What are we missing? What do we need to clarify? What’s hard to understand? All that stuff.
Elizabeth Larrick: Gotcha. [00:26:00] Is there anything else as far as the verdict or the case or even the trial prep or anything that you felt like worked really well for this case that you want to share with us?
Brian Squires: Well, what the secret weapon I had was my partner, Abe Koochai, who was just detailed and dogged. Abe is one of the smartest people I know, and he was the one that really went in and got into the weeds of all the paper that we had. When you think about all of the various real estate investments and the closing documents associated with refinances and then sales and then using those proceeds to go somewhere else and do something similar.
There’s just a lot of paperwork and a lot of small fine print that you’ve got to get into the weeds of. And we were able to do that mainly thanks to Abe. But Abe was definitely the secret weapon in terms of the case preparation and then organizing it in a [00:27:00] way that We think the jury can understand it, but it just takes a lot of time.
And I think those focus groups certainly helped.
Elizabeth Larrick: Yeah. And I think one of the things that I was kind of, when you were telling me about was like, you guys went after the crypto places too, and subpoenaed those records and tried to track all that stuff down too.
Brian Squires: We did. The funny thing about crypto is there are exchanges now, like you hear about Coinbase, Gemini, and for the most part, they’re pretty cooperative in terms of.
Responding to spinous, some of the exchanges, depending on their location, may be more cooperative than others. And fortunately for our case, the tracing that we needed to prove ended up being transactions through Coinbase. And so when we got the Coinbase records, we were able to show pretty conclusively where the money went, but crypto also can be traded.
Peer to peer at a coffee shop on a thumb drive. And that would have been a lot harder. [00:28:00]
Elizabeth Larrick: Yeah. And did you guys ever have any worry that, that people not understanding crypto would have somehow been a problem for y’all?
Brian Squires: I don’t know if they would have been a problem. It’s certainly a. interesting topic that I think sometimes people are interested to learn about.
We had an expert that was just awesome and she was able to explain it in a way that anybody could understand despite its complexity. So it’s not like our case. really depended on the intricacies of how Bitcoin works or the blockchain works or anything like that. It was an asset that the defendant had that we could trace back to dad’s money.
And that’s really all we needed to show. Our expert helped, I think, clear up any confusion and make that whole blockchain, Bitcoin experience Something anybody could grasp. And so she was important. [00:29:00]
Elizabeth Larrick: Sure. Any, any worries that with the price of what crypto is right now?
Brian Squires: Well, like I said, we’ve got a, a final judgment that gives us money, damages, and a constructive trust.
The constructive trust. Includes Bitcoin. And so the price goes down, the constructive trust value goes down. If the price goes up, the constructive trust price goes up right now. It is what it is. We just got to let the process play out and then we’ll determine how that volatility impacts our client.
Elizabeth Larrick: Gotcha. You’re going to go after any more crypto cases.
Brian Squires: What’s interesting is after this case, I’ve actually had one or two cases involving non fungible tokens, and they haven’t been. They haven’t gone very far. They were both resolved. One of them was resolved fairly quickly and I’m not sure the other one went anywhere, but it’s an interesting.
space [00:30:00] for litigation because it’s done on the Internet. It’s virtual. There’s not a real asset you can touch. Somebody owns that asset virtual wallet and sometimes there are disputes about you know whose Asset it is how much this person owns versus this person And so I think we’ll probably see more of it, but it’s just an interesting area That I think is just going to be much more ripe with disputes.
Elizabeth Larrick: Sure. Do you have any crypto yourself?
Brian Squires: I don’t, I don’t know if I have the risk tolerance to watch it. Just go up and down all the time. I sort of like to, and I like to touch and feel assets, dirt, house, that kind of stuff, but if you talk to some, anybody under the age of about 25, I feel like they’re. All in on this world of cryptocurrency and NFTs and metaverse and you [00:31:00] name it,
Elizabeth Larrick: Web3 and oh yeah,
Brian Squires: Web3, and it’s, I feel like my grandparents probably did when I was telling ’em about the internet.
I just . It’s not something I quite grasp yet. ,
Elizabeth Larrick: yeah. What I think you probably have a pretty high risk tolerance. Most trial lawyers have a pretty high risk tolerance, but like I said. I totally understand. But awesome. Well, do you have anything else as far as sharing with everybody? We’re trying to hear help.
A lot of people go back to trial right now as far as after Cove it. Anything else you’d like to share?
Brian Squires: I don’t think so. I mean, I’d love to see us trying more cases. I just think that and I think we will. Like I said, my partner tried one for two weeks just a few weeks ago in Travis County and it may have had some bumps in the road, but I think they finished.
They got a verdict, which is all you can ask for. And I think that this pandemic has on some levels, it’s gonna make future hearings a little more efficient now that everybody knows how to do zoom. There’s [00:32:00] certain hearings that you just don’t really need to go down to the courthouse for. And if you can just do them on your computer in your office and save the client time and money and you time and it just makes sense.
I mean, there’s certain hearings that I think you do need to be down at the courthouse for their certain. Obviously, the in person trials are important, but I think we’re moving in the right direction.
Elizabeth Larrick: Yeah, well, hopefully we’ll pick up. I know that Austin itself is pretty far behind compared. And so there’s a lot of places who are back in person.
No mask. So back in 2021, so awesome. Well, thank you so much, Ryan. I really appreciate you stopping in and talk to us about your trial. And I understand that it’s on appeal. So I wish you and your clients the best when all that gets resolved.
Brian Squires: I appreciate it. Elizabeth, for having me.
Elizabeth Larrick: I hope you enjoyed today’s episode with Ryan Sweeney.
Squires, we’re going to have his information and contact in the show notes if you want to reach out to him. And as always in the show notes will be my email if you have any [00:33:00] questions or have a suggestion for an episode. I appreciate you listening here today. If you enjoyed what you heard, please leave us a rating and review on your