Author: elarrickbrand

In this episode, we reflect on a year of trial advocacy growth and gear up for an even more dynamic 2024. Listen in as I share insights from my tenure as president of the Capital Area Trial Lawyers Association, highlighting how organization and balance have become pillars of my practice. I also discuss the surprising dominance of virtual focus groups, with a staggering 44 sessions conducted online, illustrating their continued convenience and efficiency for our busy legal community. 

Plus, get a sneak peek at future episodes featuring fellow lawyers and experts who will shed light on innovative case development, witness preparation, and the powerful use of medical illustrations and animations in storytelling. 

As we wrap up 2023, I can’t help but share the profound impact certain books have had on my journey both professionally and personally. As I set my sights on devouring 40 business books in the coming year, I extend an invitation for your recommendations. Lastly, we’ll explore how experimenting with AI tools like ChatGPT might revolutionize the way we practice law.

In this episode, you will hear:

• The effectiveness of virtual focus groups (with 44 online sessions highlighted)
• Insights from impactful books for personal and professional growth. 
• Exploration of technology in legal practice, including the use of ChatGPT for brainstorming and content creation.

Follow and Review:

We’d love for you to follow us if you haven’t yet. Click that purple ‘+’ in the top right corner of your Apple Podcasts app. We’d love it even more if you could drop a review or 5-star rating over on Apple Podcasts. Simply select “Ratings and Reviews” and “Write a Review” then a quick line with your favorite part of the episode. It only takes a second and it helps spread the word about the podcast.

Supporting Resources:

To learn more about grief listen to Episodes:

Ep 85: What is Grief?

Ep 86: Ways We have been Taught to Deal with Grief

Ep 87: How to Navigate and Assist Our Clients with Grief

Book Recommendations:

Never Split the Difference by Chris Voss

Essentialism: The Disciplined Pursuit of Less by Greg McKeown

The Big Leap by Gay Hendricks

Loving What is by Byron Katie 

Got a book recommendation? Podcast episode topic? Email Elizabeth: Elizabeth@larricklawfirm.com 

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 I sent you.

Episode Transcript:

Elizabeth Larrick: Hello and welcome back to the podcast Trial Lawyer Prep with me your host, Elizabeth Larrick.

Today, we’re going to do a wrap up of 2023, as this will be our first episode in 2024. It’s always a great time at the end of the year to do some reflection. And I always like to do [00:01:00] that here on the podcast, because it’s a good time to take an inventory, look at what happened, what made an impact, and then also set some things forward for 2024.

Thinking about 2024 and just to get to those folks who are thinking, I don’t really want to listen to what Elizabeth did over in 2023. Totally fine. Let me just give you a little bit of a broadcast for the podcast coming up. We’re going to keep doing every other week episodes and continue to focus on having lawyers join a podcast to talk about things that are helping them develop their cases better.

Get clarity, get confidence, get certainty. How we’re going to have a lot of case studies, folks that are coming on to talk about, Hey, I use this, I use this style of focus group. I use this style of witness prep. I use this kind of organization to help me develop my mediation presentation. Really a lot of.

examples of how to’s where we can really kind of see the benefits. Also going to have some folks come back on our podcast to talk about things that they’re [00:02:00] doing in their Avenue, specifically in my mind, I’m thinking about Annie Goff. She’s going to come back and talk about medical illustrations versus animations.

I don’t know. We’re going to have a few other people come on as well, who are vendors that help lawyers tell their stories, whether it be a mediation or a trial. So let’s talk about this episode. I went back through my calendar as I live and breathe and die by my calendar and block things out, all that good stuff and looked at what really did I do in 2023.

Well half of 2023 was dedicated from, from January until June to the capital area trial lawyers association presidency. I really wanted to serve in that role to give back to the profession and here in Austin Capital Area Trial Lawyers Association provides monthly CLE lunches for members. Uh, we support each other with an email list serve and give back to the community through volunteer service.

I am proud to have served in that [00:03:00] organization as its president and will continue to support them on the executive committee. And I learned a lot about organization as balancing what I normally do with my work, plus also adding on the things to support that organization was just a good exercise and making sure that I balance things out, which is probably one of the biggest lessons that I have learned in 2023, but we’ll get to that just a little bit later.

Also looking back at. What did I do? 44 virtual focus groups and probably more considering inside some of those groups, we had two to three focus groups, right? So if you’ve listened at all to the podcast, you know, that my mantra is really about focus groups, small bites about case strategy, about issues, facts, instead of doing long, Okay.

So that’s why I say 44 focus groups, because we, we, I break it down. And then also [00:04:00] within that, we do even break it down, even smaller for focus groups did eight in person focus groups. I will tell you, this was a little bit of a shock for me. I had figured that the beginning of 2023, we would be doing a lot more in person focus groups only because I knew a lot more folks would be going to trial and be having a lot more action in our dockets.

And that really, for whatever reason, the virtual focus group still continued to dominate the space. My thought is that, one, it’s still so much more convenient to do these virtually. It’s convenient for us as lawyers, it’s convenient for people, it’s easy to put one together quickly. The other thing that we, I really saw in doing the in person focus groups was a huge new cost barrier to renting space, because typically when we’re doing the in person focus groups, the mock trials, we’re going to have a [00:05:00] lot of people.

So we need a lot more space. We joined them for longer and a lot of venues, especially the hotels that I dealt with were Much more difficult this year than last year, which I’d done some in 2022 and didn’t have the same difficulty. So I’m not really sure if there’s just an uptick or if there’s more competition or what’s happening in the space out there for, for in person venues, but that just, um, I was a little shocked we didn’t have more, but again, I just think, personally, the virtual ones are just so much easier for people who have a busy schedule, which those are lawyers who are listening to the podcast, right?

We’re in litigation, we’re going to trial, we’ve got mediations, we’ve got depositions, got a lot on our personal dockets that don’t allow sometimes for an entire day to be set aside just for attending, but not to mention the preparation that’s involved. So kind of a big takeaway is virtual is still the way to go, hands down, especially when it comes to time efficiency and money efficiency for [00:06:00] a lot of the same benefit.

And that’s one of the biggest questions that I get when talking with lawyers is, is virtual good? Like, is it good? Does it work? And hands down, yes, absolutely. I mean, just looking at these numbers, I mean, that’s 44 lawyers, right? Versus eight lawyers, right? And those are also not to say that people aren’t doing a combination of the two, but what I saw with our in person focus groups, those were folks who hands down, Um, we’re past the point of settlement.

We’re going to trial. We’ve got to get this together and run through it a couple of times. And naturally the virtual focus groups are not in the same position, right? They’re building up, they’re getting discovery ready. They’re getting mediation ready. They’re trying to figure out what does this need to settle or does it need to go to trial?

And then of course we had some trial prep ones in there as well. So kind of a mixed bag, but just to kind of give you a little bit of a background on that. The other thing that I help folks with is testimony preparation, whether it be trial or deposition. A lot more folks going to [00:07:00] trials, but I did see a lot more folks that I was helping with trial.

That was about a 50 50 split on that. Doing a lot of that work virtually as well. Again, just a matter of convenience for lawyers and for people. You know, a lot of folks are working a lot more because that dollar does not go as far. And so a lot of clients that we’re helping just, there’s a convenience level, right.

To not having to take off work to working around things and using virtual. So lots of good folks that were helped this year. I really enjoyed us, of course, helping people with that. And that’s lawyers and clients involved. The other thing that I did was I spoke at five CLE programs. Always love getting on my feet to do that.

Almost every one of them was in person, so that’s, I really enjoy doing that. Podcasts of course. You’re here. So thank you so much, but we did 50 episodes. We did have just a few repeats, but the focus of this year was really about having guests on and, uh, I would say we definitely had a majority of the episodes that were with our [00:08:00] amazing guests and a big thanks to all those people who came out, uh, to do the podcast with me.

The other thing that I did is I worked with three amazingly strong women who helped me grow personally and in my business and I read about 30 ish books. I say ish because I did not track it very well. Uh, and I do. Repeat reading books, some of them every year, sometimes every other year. We’ll talk a little about the books in here a little bit, but I just love reading.

So I did a little more fiction this year than I normally do. All right. So in that full reflection, of course, I looked at really what was impactful for me, meaning what were things that helped me or things that didn’t help. One of the most important things for me is working with.

And that’s [00:09:00] really a dedication that I made to myself many, many years ago to always work with someone to help me see what I can’t see. And I’ve done masterminds, I’ve done, you know, business coaches, I’ve done therapists and psychologists and it has always helped me grow. And so of course continued that this year and have seen many helpful things.

So many things that would be difficult for me to talk about here on this podcast. But one of the things that I did spend some time, which was talking about grief. And the grief recovery method that I did and then the certification that I got. If you are curious about more in depth conversation about grief, there are three main episodes that were released about grief and I’ll put those in the show notes if you’re curious.

In addition, if you’d like to learn more about the grief recovery method, I’ll put a link to the show notes in that as well. I want to also jump to the books that I read this [00:10:00] year that really had an impact on me. And I read many books, but these were the ones that kind of stuck out to me in my journey this year.

I read the book, Never Splitting the Difference, uh, as a negotiation book by Chris Voss. It’s been around for a while, but there were so many helpful, applicable things. So if you’ve read the book. I totally suggest reading it again. If you’ve not read it, definitely as a lawyer, gotta read this book. I think it is so helpful to anyone who’s maybe just starting out in the PI world to have in their thinking in their mind.

See, when I went to law school, I didn’t take any classes on arbitration mediation because I want to be a trial lawyer who needs the rest of that stuff. Okay. Well, it would have been really helpful to have, but I didn’t. So this book is a very helpful fill in for a lot of the mindset, a lot of the thoughts.

Plus he’s a really good storyteller. So the book goes by really quickly. Another book that I just wrapped [00:11:00] up this year reading was Essentialism by Gary Q. And he also has a podcast, but. The book is very helpful in this mindset of, you know, just doing what is essential and not rushing around to do everything, which is a lot of what can happen when you are a solo, you rush around because you have to do everything.

Uh, that’s a lot of what I do. I’m trying not to do that. The other thing that he really talks about is rest and time to think as a way more important. Thing in our lives versus rushing around, doing that one extra task, reading that one extra book. And I really loved that. And I have painstakingly trying to put that into what I do on a regular schedule.

And this kind of came full circle for me because when I worked with Mr. Keenan, one of the things, and if you’ve spent any time with [00:12:00] him or heard anything, then you know, then he loves a very good cigar and he would always have. Stokey time where basically he would sit up outside and smoke a cigar and I understood.

He always explained like this. I’m just thinking like I’m going back through, I’m thinking back through this focus group or I’m thinking, or he would just have me read things like read the focus group transcript. But that was what he always told all the lawyers that we worked with is like, you have to take time to stop and just think.

I just think, think about your cases, think all the way through, think about how to tell the story, and really give time for your brain to do the amazing things that it does. So get a full circle here, you know, reading this again, but also just like, okay, we’ve got to build some time in to stop and think.

And then of course, time for rest. Cause then that makes our brains better. Another book that I read at the beginning of the year, which [00:13:00] was the big leap by Gay Hendricks. And I’ve talked a little bit about that on the podcast here and there great book. If you are looking to grow, it’s been out for a little while.

It’s not a newbie, but it’s really helpful in finding. Things that you may do that could be holding yourself back. And if you are all about trying to grow to the next level, whether it be business or, or professionally, that’s the same thing, by the way, whether it be personally or professionally. Great book.

It’s so small. It’s really simple. He’s a very wonderful storyteller as well. There’s all kinds. He’s got a couple of their books out as well, but I would say that’s a good one to start with. The other book that I reread was Loving What Is by Byron Katie. Very simple book. It’s the four step questions, but just always a helpful re reminder.

I’ve read that many, probably five plus years ago, and I always have it on my Kindle to reread, you know, whether it just be a piece of it. And that’s also why I like her book is because she’s jumped to the [00:14:00] section you need, right? You need to have that.

So if again, you may find yourself stuck in a thinking loop, which is a lot of my personality is thinking loops. And as, as lawyers, we have think all the time and thinking in loops that are not very helpful. That’s a great one too. And I’ll put links to all of these books as well in the show notes. If you’re curious, if you’re thinking about picking up some books, one of my big favorite Goals for 2024 is to read 40 business books.

So my, my push to y’all as my audience is if you have a great recommendation, please send it my way because I’m trying to set it up ahead of time. So I know all the books that I’m going to read and in what order, well, hopefully in what order, but to knock them down, but also, you know, take notes and be able to find the books that I need.

So if you have any suggestions, please. Let me know. You can email me my email up in the show notes, or if we’re connecting on LinkedIn, you can just send me a [00:15:00] message on LinkedIn as well. One of the things that I also played around with, I always try to do something technology wise, and I really try chat GPT and I use it for a lot of things, but I mainly used it for helping me start ideas for writing a blog or for.

thinking about a podcast topic or LinkedIn topic. It’s super fun just to ask it questions and see what the output is, especially as like from a lawyer’s mindset, right? Cause we have what we know people think about us. And so it’s, you know, that’s what’s filled in with chat GPT. So it’s super fun to get good prompts.

I don’t want to talk too much into this topic. There are many other lawyers have great Things to say and how lawyers should use it. I was approached by some folks who had an idea to have an AI generate deposition questions like during your deposition, which is a very fascinating, wow, what a great tool, but from a brain capacity, energy perspective, that would be so much.

I mean, you have [00:16:00] a lot of energy dedicated to. Your outline to what you want to accomplish, but then there’s energy from across, you know, the screen or across the room. Right? So there’s all sorts of stuff going on for our brains. You know, one of the biggest things I think good trial lawyers do smart trial lawyers do is use their energy efficiently.

Because we really don’t want to lose being present in that moment or being lost in emotion, which is very, very draining. So super interesting topic on how to use chat GPT. I know some lawyers have gotten in trouble for using it because chat GPT will make things up. So nothing is perfect. Uh, but I would say if you are Wanting to play around with it.

It’s, it is fun, like in the sense of having somebody don’t have anybody to bounce ideas off of, put it in a chat GPT, and it will definitely spit out some information for you. The other thing that I have always been looking for is a note keeping. [00:17:00] Uh, say a digital note keeping app or organization or website that would help me.

And I’ve tried a couple of different things. And so far notion, it has been what I have stuck with and it’s very easy to use. There are so many note taking apps that get really complicated. Notion has been super simple to learn. It doesn’t add too much in there, but if you want to get really deep with it, you absolutely can.

I’m sure that it. Syncs with other things and links up. I didn’t have any of that done. I just have it as a really simple place for me to keep ideas and thoughts for content, right? To think about how do I do this or how should we talk about X, Y, Z, like. I just put all those in there and go back in there and find them.

It’s a great way. And again, pretty easy organization wise. And there are other people who are using it. That basically it’s makes it very easy to copy and paste to me. It’s way easier to use than, than Google as well for our, for my Google lovers out there, the other thing I’ll [00:18:00] say that I just kept up doing that I’ve always done is just a real, you know, simple routine of exercise, meditation, and reading.

And I’ve read something today that I’m sure we’ve all heard a thousand times, which is like people with good discipline, like helps them when the motivation is all gone. And that’s totally what that routine is for me because there are definitely days where I wake up and I don’t want to exercise, which if I skip one step, generally the whole thing’s out the window.

So I always try to make sure I do step one and then three, four, five, uh, go right after that. But that has always helped keep stress down, keep my thoughts clear. That’s really why I enjoy exercise so much. And then meditation keeps it clear, reading, right? Spark ideas, but that’s something I’ve always kept up with every morning.

I’m not always perfect about it, but it has always stayed on board for, uh, I would say hopefully 80 percent of the time, but I did not look back and track that either. So looking back, reflecting, what are some of the biggest things [00:19:00] that came back to me whenever I was looking at 2023? And I would think the biggest thing was building space, building extra time to get things done.

It always takes you longer than you expect or plan. Building space for rest, building space for thinking, building space for growth. Because typically I just bump everything, it’s just one right after the other. And in that, having done that, I have a lot of Backups, meaning I’ve got written notes and digital notes everywhere, just so when I bump to the next thing, right, I don’t lose that thought versus following all the way through and finishing.

Right? So really want to teach myself, which lots of teaching moments this past year for building some space and I would encourage the same thing for you. When I talk to a lawyer who’s going to trial in two weeks and there is no availability for them or [00:20:00] for even me to do a focus group, I feel terrible.

I think, gosh, how did this happen that there just wasn’t enough space? And that’s because it’s so easy to let go. Our schedules rule our time. And I feel like, gosh, I wrote to help you. I want to give you the information that a focus group could give you, but there’s no time because there didn’t leave any space for that.

And so, you know, there’s so many people say, Oh, we’ll do this, do that. I mean, blocking on our schedule is probably the best thing we can do to protect our time. And I know when. We work with other folks, whether it be assistants or paralegals or other people in the office, right? Protecting that calendar sometimes is not even our job.

And so we’ve got to teach everyone around us to protect our time so that we can have space to think about discovery, to plan out that deposition, to think about that mediation presentation to say, Oh, I do [00:21:00] need to schedule a focus group for that. Let me go ahead and book that day on my calendar right now.

And then I can. Book a reminder. If what I’m saying sounds totally foreign to you, give me a call. I’d lovely tell you how, how either Gmail or Outlook calendar works, because I think it’s such a great thing to block timeout out and then be able to get to that time spot and be like, Oh yeah, this is where I just get to sit and think and do a strategy or think about questions or whatever, maybe building space.

That is really what 2020 Three has been teaching me. And so that’s what my hope is for 2024. And, you know, we talked a little bit about what this podcast is set to do, what I hope it will do. And if you are someone who’s listened for the past two years and you want to come on, or you have an idea, please don’t hesitate to reach out to me.

And that’s what my email is for. I’m like any other lawyer who lives and breathes and dies by their email. So I totally will check it and [00:22:00] respond. But we just want to continue what we’re doing with this podcast and helping lawyers get better by learning from other people, whether it be the good stuff or be the mistakes.

That’s what we’re here for. That’s what I’m here for to help you with. And if we’re not connected on LinkedIn, please send me a connection because I would love to reach out and learn more about folks who are listening and what they want to hear from the podcast. Um, and of course, as always, my goal is always to get better with this podcast and speaking more to what I’m learning when we’re running these focus groups or when I’m working with clients.

So thank you so much for supporting the podcast in 2023. I hope that you stay safe. Stick around for 2024 and, uh, keep those automatic downloads coming. And if you haven’t left a review, please take some time to do that because that helps other folks find this podcast or just send a link to somebody else so they have a chance to listen as well.

All right. Until next time. Thank [00:23:00] you.

Have you ever wondered how the best trial lawyers prepare for court? Join me as I sit down with Justin Starin of McKenna & Starin, to pull back the curtain on the strategic deployment of focus groups in personal injury law. Together, we venture beyond the traditional mock trial format, navigating the nuances of targeted sessions that dissect specific issues like causation and case framing. Justin’s expertise shines as we dissect how focus groups can not only unveil potential juror biases but also refine witness preparation and bolster plaintiff credibility—essential tools for any legal arsenal. 

We also delve into the art of simplifying complex legal arguments for the lay jury. From revising opening statements to rendering technical evidence understandable, we expose the trials of countering preconceived notions and managing inflated expectations set by the likes of CSI. For legal professionals aiming to cut through legal jargon and connect with a jury, this episode is an invaluable masterclass in strategic case management.

In this episode, you will hear:

• Using focus groups for causation
• Responsibility of testing security systems
• Challenges in investigating a death case
• Expert testimony for defense against blame 
• Focus groups in legal cases benefits (90 seconds)

Follow and Review:

We’d love for you to follow us if you haven’t yet. Click that purple ‘+’ in the top right corner of your Apple Podcasts app. We’d love it even more if you could drop a review or 5-star rating over on Apple Podcasts. Simply select “Ratings and Reviews” and “Write a Review” then a quick line with your favorite part of the episode. It only takes a second and it helps spread the word about the podcast.

Supporting Resources:

Justin Starin

McKenna & Starin

Justin@mslawmt.com 

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 I sent you.

Episode Transcript:

Elizabeth Larrick: Hello, Elizabeth here. I just wanted to pop in very quickly to tell you a little bit about my guest that we’re going to have on today, Justin Starin.

He is a partner in McKenna and Starin personal injury law firm out of Missoula, Montana. Justin and I met many moons [00:01:00] ago while doing a deposition preparation for some clients of his. Which we’ll actually talk about in the episode. Justin is a total nature lover, as you will also hear. Loves to go rafting, spend time outdoors with his family.

All of his contact will be in the show notes if you have questions for him or need to reach out to him about a case in Montana. Okay, let’s jump in. Hello, and welcome back to the podcast. I am your host, Elizabeth Larrick, and we have a brand new shiny episode today with a guest. I will say, Justin Starrin is joining our trial lawyer prep podcast to talk about focus groups and causation.

But before we totally jump in with Justin and just say hello for everybody here, Justin. 

Justin Starin: Hello. 

Elizabeth Larrick: Perfect. Justin’s up in Missoula and I met Justin and his partner, Sid. Several years ago, I want to say we met through the edge back in the day. It was called the [00:02:00] reptile and worked with these two folks. And we have been fast friends ever since.

And they’re so awesome that they get me a speaker spot at the Montana trial lawyers speaking pretty much every other year, which I’m grateful because I love going to Missoula. So Justin, thank you for getting me the speaker spots and welcome to the podcast. 

Justin Starin: Yeah, thanks for having me on. 

Elizabeth Larrick: Yes, and so focus groups.

Plaintiffs personal injury work, workers comp stuff. Why do you run focus groups? I 

Justin Starin: think we’ve evolved in our focus group stuff over time, but mainly we do it to find out the viability of our cases from a juror’s perspective. We do it to learn what is the most compelling case frame for any particular case.

We do it to find out problems with our case or problems with our plaintiff. And sometimes we use it in all kinds of ways that, in fact, I’m always fascinated that there’s [00:03:00] always some new angle that we develop that comes out of focus groups. Witness prep would be a good example. You can find out what the defense is going to say by the focus group.

So yeah, there’s lots and lots of uses for them, but those are the main ones. 

Elizabeth Larrick: Yeah. And I. So I’ve been talking, I did an episode on it, and so let’s just be really clear for anybody listening, maybe if you’re a new listener, hello, we’re glad that you’re here, maybe you’ve been with us for a while, and yay, welcome back, but we’re not talking about mock trials, okay, so Justin, when you are talking about focus group, in your mind, what are you thinking of?

Justin Starin: We did back in the day, a full mock trial focus group, and it was very time consuming, very expensive. And it led us astray a little bit. It’s too much to do in one big show. Anyway, so the ones that we’ve, been doing lately and some of them with you. We’ve been doing just like [00:04:00] an hour, maybe two hours with a smaller group of people and more focused on a particular issue.

Maybe it’s causation. Maybe it’s case framing. Maybe it’s finding out what jurors think of your client. So usually Oh, an hour, two hours at the most. 

Elizabeth Larrick: Yeah. Okay. So you said something that I want to follow up on. You said it led you astray. Can you elaborate a little bit? 

Justin Starin: Just to be blunt about it, we asked them for a number.

Elizabeth Larrick: Oh. 

Justin Starin: And so at the end of the trial, after the closing argument, we asked them what they thought a reasonable number was and then they gave it to us and it was higher than we ended up getting in the trial. 

Elizabeth Larrick: Oh. 

Justin Starin: So there might’ve been an opportunity to settle the case, but we were emboldened by the focus group number, and I think it was our first focus group, so we just didn’t have enough experience to really understand that.

And it’s possible we would do [00:05:00] another focus group that big, but I can’t imagine it in most of our cases. 

Elizabeth Larrick: Yeah. Yeah. And that’s, yeah, that’s exactly what I talk about is there’s such a big difference. And sometimes people think we’re talking about the same thing when we say focus groups, meaning it’s a mock trial.

It’s not because exactly for the reason you said, it’s really involved. It takes a lot of work. And most of the time you’re not going to do it until you were on the doorstep of trial when like things are set in stone and you’re just rolling the dice at that point. Do another thing to worry about is what comes in and what doesn’t and what people say on the stand.

Which no one can predict in a mock trial. Awesome. And you mentioned way in the back. So you guys had done in person before. 

Justin Starin: Yes, we did it with our friend, David Paley, who he played the role of the defense counsel. And I think we had experts. We had cross examination of the experts. We had an opening and a closing.

We might’ve had a direct examination of our client. I can’t remember. [00:06:00] It’s been about. 15 years ago. And I mean, it was fun, but it was a ton of work and probably not really that efficient in terms of getting what we wanted out of it. 

Elizabeth Larrick: Yeah. It can be really challenging and there’s a lot of data that comes out and it’s very hard to wade through it.

When you’ve just done it, cause you’re exhausted. And I know that you and Sid though have before the pandemic, you guys ran some focus groups in your office, right? 

Justin Starin: Yeah, we did. The biggest problem we had with them is getting the people. I never did develop a very good system for getting people to come to the focus groups.

We mainly used employment service. And I suppose there’s probably some problems with that. For me, it was fun to get on your feet and have interactions with mock jurors about cases, but then the pandemic hit and after that changed everything. 

Elizabeth Larrick: Yep, I feel you on that. So let’s talk about just overall, what [00:07:00] kind of cases are you using focus groups in?

Justin Starin: We use them in a variety of cases, med mal cases, we’ve used them in products liability cases, we’ve used them in car crash cases, we’ve used them in premise liability cases, maybe even an employment case. Yeah, I think we used one in an employment case once too. I would say mostly our bigger cases, we don’t use them in every case, but some of the mid sized ones too.

I’ll give you a good example. We had a case that was in a parking lot at a box store, and the person was assaulted, the plaintiff was assaulted by some bad guys in the neighborhood. And we focus grouped it and we just couldn’t ever get the focus group to. side with us. They just thought that it wasn’t the box store’s responsibility to police the parking lot.

And so we turned down the case, even though the guy was blinded by the assault. So right off the bat, we were doing a focus [00:08:00] group. And in retrospect, I’m glad we did, because we could have spent a lot of time and energy working that case up and have it. Either lose at trial or get beat into a low settlement.

Elizabeth Larrick: Yeah. And I think that’s such, I try to tell people that. Cause that could be a case you spend a lot of money on. You’d have to have a securities expert. You’d have to probably have just quite a bit of case expenses and depositions. And there’d be a lot of money that’s sunk in before you realize, Oh no, a jurors.

They’re never going to get with this. It’s always going to be like stuff happens. And this brings us to our topic today of coming to using focus groups for causation. And you may be thinking in your mind, listener, like medical causation, which is good, which we can. But I think what Justin and I are going to talk about is more about the mechanism of the event being the actual causation.

And one of the examples, which I think you guys, we did together virtually, Was a case that you weren’t really sure whether the focus group was ever going to put any blame. And so talk [00:09:00] about our 4th of July, tell me about your 4th of July case and what brought that to the focus group. 

Justin Starin: Okay. It was a tragic case.

There was a apartment complex and there was four, a small complex. There was only four units in, and there was two units in each side. And on the 4th of July, an arsonist had come to one of the upstairs apartments and had He used gasoline to light a fire at the door of one of the apartments, and the fire burned out, and there was a cursory investigation by the landlord, and then two days later, the arsonist came back, used more gasoline this time, and burned the entire place to the ground in record time, in a matter of hours.

The whole place was just, Completely burnt it to the ground and our client was in one of the upstairs apartments and she had to jump out of the window to escape the fire. And so the question really was, who’s at fault for [00:10:00] this? Who’s responsible for causing the harm? And is the jury going to put all of it on the arsonist?

Are they going to put some of it on the landlord? Are they going to put some of it on her? How do we work this out? And so that’s what we reached out to you to come in and. Do a focus group and try to walk us through that. 

Elizabeth Larrick: Yeah. Cause again, at any point that could have been, well, who could ever predict an arsonist?

Like why would a landlord ever be able to predict that? And I think the other thing that was so crazy about sticking out of my mind. And again, just so everyone knows this is something that’s been long is long gone. And we’re not worried about any confidentiality here. We’re not going to mention any names or anything.

What amazed me was like the pictures of the fire. There were, it was one. Entryway one set of stairs up to the second floor and the arsonist first go around. He said just a little fire and they got out the second go around. He burnt, he put so much gasoline at burn the stairs. So the people in the upstairs units could not get out.

And then there was all this [00:11:00] whole other, maybe there’s a conspiracy and the people upstairs. And Justin was very good about creating some visuals for us and using some pictures. But yeah, I think we ran it more than once, I want to say, just to secure and get all the questions and everything, but tell me if you can, what you remember about what kind of feedback did you, did we get about what happened there?

Justin Starin: I think it was a mixed bag at first, and it really focused our attention on how we were going to frame the case as a systems failure instead of. A one off and the more that we were able to learn from the focus group, the more we were able to build this idea or this frame that a landlord does have responsibility and.

We’re trying to get around some of these causation heuristics, where a focus group juror might just focus on one piece of bad conduct by the arsonist, and that would be the end of the analysis. And we tried to move it back in time [00:12:00] to what was their security system like? What did they do to prevent it?

arsons or other crimes on their premises. That’s where they fell down. And that’s where the end of the focus of the case shifted after the focus groups that it really helped us learn how to figure out what was the root cause of the problem from a focus groups perspective. 

Elizabeth Larrick: And I think one of the things that stood out to me that Kind of became a little bit very helpful, which was the expectation that the renters should have about being notified about things going on.

And I think that was one of the biggest facts that you guys found had a lot of draw to it, which was that nobody told anybody it was all this gossip between the renters. That’s how the rest of them found out. 

Justin Starin: Yeah, they didn’t. First, they didn’t have a very good system set up. In the first place. And then they really didn’t have a plan for when something bad happened.

How are they going to notify people? How are they going to fix the problem? So it didn’t happen again. [00:13:00] And yes, that ended up being the focus of the litigation that then led up to the resolution of the case. 

Elizabeth Larrick: Yeah. Anyone that’s it’s super easy. Yeah. How could you ever predict an arsonist? But it came once.

They definitely. Could have come again. And I think also, like you said, a cursory investigation, I think that was also something that kind of stuck out to them about what they would have expected somebody in the landlord capacity or the management company to do something other than what they did, which I think was pretty much nothing.

Justin Starin: Yeah, they didn’t do very much for sure. And I think the fact that The fact that the facts were egregious in the sense that the arsonist came and poured gallons and gallons of gas on a wooden exterior staircase, that then it happened so fast once the fire started. And we did go down and hire a fire expert to explain to us how the fire worked through the building and stuff.

And just a [00:14:00] wood structure exposed to gasoline is extraordinarily dangerous. Thank you very much. 

Elizabeth Larrick: And that was something I mean, regular people wouldn’t know as far as the, uh, how fast and what that really means and could it have been something else? And. I think also one of the things, maybe it was just my worry or my thought or my question, was like the fact that the arsonist was still out there, no one had really even tried very hard, I would say, to go do a second investigation or anything and just never got caught.

No punishment, no nothing. Once you’re able to get that feedback about the notice and oh, this happened, oh, this, they found it through gossip, then that kind of, that definitely helped. And I want to say for the second one, we changed things up a little bit to try and make sure we’re dialing in on the right parts.

Justin Starin: Yeah. Yeah. And that’s what I’ve learned over time is that sometimes you need to do more than one focus group because you need to learn from the first one so that then you can reframe the case and then [00:15:00] present it in the second one. And when we first got the case, we thought it was going to be more of an analysis, not of the security system, but of the fire suppression system that, you know, but it turns out that because it was a relatively small facility, they were up to code in terms of their, their Fire suppression and fire alarms and all that kind of stuff.

So 

Elizabeth Larrick: yeah, it didn’t even have to have a suppression system, right. They didn’t even have to. Yeah. Yeah. And I always find that super interesting where we have an idea in our minds, like what makes sense sometimes legally. And then it’s, Oh, what’s the simplest thing that could have stopped him? Get fricking ring doorbell.

That’s what a lot of them were just like, wait a second. This is easy. Right. You can go get a camera for 5 or something and put it up there. Even if it’s fake. And that’s. Still deters people. Like they had so many good ideas and I was like, Oh yeah, okay. This is way easier than trying to have a sprinkler system in a pretty low rent apartment complex.

Justin Starin: Your lawyer brain goes down that rabbit hole and it’s nice to have a focus group that kind of brings you back to reality. [00:16:00] Make your case simple, which is important because as we know complexity confusion and ambiguity are your enemy So 

Elizabeth Larrick: yeah, and my gosh, we love details lawyers love the details I’m always like let’s not overwhelm people with the details.

Let’s just see what they do with these facts Because yeah, there’s so much detail that we get into that we have to write We’ve got to dig through all the fluff and all the stuff to then put everything together But at the end of the day when you go to trial It’s really simple. You really want to try to avoid all the extra confusion and You got to plant your flag.

You got to pick your path. And if you try to have two paths, it becomes way too confusing because there’s always going to be extra evidence with almost for both ways. And it’s hard. Although I can hear people think listening, go, well, what if there is contrib and what if they do have to take some responsibility, that’s a little different than, you know, Like Justin is saying, was it a security system [00:17:00] situation or a fire suppressant?

You tried to go both avenues and you didn’t test out which was stronger. You could just be spinning your wheels and just confuse everybody to begin with. Which leads me to our second example, which was an even more challenging causation with our gun manufacturer case. So I know that one’s got a hairy lot of details, but why were we so hounded by doing focus groups?

Justin Starin: It was a very complex kind of factual scenario and there was no witnesses to the incident where a young person had a firearm and ended up shooting himself with it. And the question was, did he do it intentionally or was it as a result of a defective product? And there was so much emotion and there was so many factors that we felt like we had to do focus groups to try to.

Understand it. And it was a very challenging case for a lot of reasons, [00:18:00] but just even the simple scene was challenging to try to figure out. 

Elizabeth Larrick: And I think the causation of why it malfunctioned was difficult because there were. So many pieces like that part alone. Let me just tell you people, they sent me, how old was this video of the inside of a gun and how it works?

I don’t know, but I took it and I slowed it down so I could understand. And we could try and watch it together with a focus group. So they would be able to understand like, why this was something that could happen without the gun could go off for any, you accidentally drop it. You literally touch it. You don’t have to do anything to it.

And it’ll just go off all on its own. And it was just like, okay. And then add in this whole other complication of a very young person who the whole defense was this, this is really sad. This is just a case of suicide. And the amount of work they had done to basically put so many facts on that side of that defense and then us, you [00:19:00] guys trying to figure out like, okay, we’ve got to be able to really pinpoint this causation of how it malfunctioned and then put it into the set of facts of what happened that day.

That morning and it was just really, I’m complicating it just by saying it sounds complicated just by me saying it. 

Justin Starin: I think I drafted that part of the opening statement, maybe 15 or more times and I would get done with it. And then I would bring it back to the team and I would say, okay, here’s my latest attempt.

And then they would shoot it down and say, oh, it’s too complicated. It’s too confusing. You got to make it simple. Why do you have to pretend like you’re an engineer, blah, blah, blah, blah. And I just, it was, It’s probably the most challenging thing I’ve ever done as a lawyer was to try to figure out a way to simplify that level of complexity and not sure we ever really got there.

Elizabeth Larrick: Yeah. At the end of the day, they were the focus group and we, I think we did two or three, I want to [00:20:00] say, and the focus group was still just came down with a lot of confusion. And unfortunately it was just like, what’s the simple, instead of trying to understand or learn or. They, the simplest thing was for them just to blame him, which was of course not what we wanted.

And another thing, of course, which is so frustrating as lawyers, sometimes as you have, there were mountains and mountains of evidence and proof of all of this stuff. And it was going to probably come in. And that was like, the other hard thing was like, okay, how do we synthesize, how do you guys like siphon all this, like really good, hard proof.

It was a really, it was a huge challenge. 

Justin Starin: Yeah. It really was. That, that one would be just tough. 

Elizabeth Larrick: I know. And I’m glad we, again, this is another one that has been closed out, but just another one of those ones where it’s holy mackerel, like having to try that case. Cause you guys were coming up on the doorstep.

This is, wasn’t one where we, it [00:21:00] came and this was the beginning part. No, this was at the end of trial prep. Let’s run this opening. Let’s put these pictures out there. And I think the hard part was because again, coming at the tail end and getting ready to try it, there were so many pieces of things that just weren’t even available because at the time that that all happened, no investigation was done at all.

Justin Starin: Certainly not at the level that I think you would expect for a death. And I think there was just some assumptions made by the law enforcement. Officials that investigated the incident of what it was and they really didn’t take a deep enough dive into the cause of the incident and that ended up making it very difficult to try to reconstruct.

So yeah, it was a challenging case all the way around. 

Elizabeth Larrick: Because you’re going against what the police report says, and you’re going against what the manufacturer says, and you’re going against what [00:22:00] would be looked at as, oh, this seems like the simplest explanation, and respectfully, I don’t think suicide is ever a simple explanation.

I think that’s probably the more complicated one out of any of them, but it was a lot. And you guys were It’s getting ready to go to trial. So it definitely answered some questions for us, but I think this was a focus group that kept leaving us with more questions about, and also how to answer their questions.

Because just like you said, they had an expectation about where’s the ballistics, why didn’t do the powder thing they do on CSI for the gun residue, 

Justin Starin: right? That always seems to be the case. There’s always seems to be like a juror’s expectation that there’s going to be a lot of. Kind of CSI type evidence.

And as everyone that’s probably listening to this podcast knows that rarely if ever happens. 

Elizabeth Larrick: No. And you guys had tried that. Okay. We have pictures and it was still was not enough because it was just going to be, it [00:23:00] was just so close, you know, as far as like the distance and all the stuff that was just, they all of course expect that it’s like, whenever we do a focus group now, any, I don’t care what kind of focus group it is.

Like, where’s the video footage? I’m like. So everyone just expect your car is going to have some kind of video camera, the front door, the convenience store, which I think we get used to that. But at the same time, nobody’s, do you have video in your car? No. Why would you expect? Anybody to be at the video, but that’s just one of those things.

Well, where’s the ballistics? Where’s their gun residue and where’s the, whoa, you didn’t do the whole like recreation thing. Oh man. So yeah, there’s a lot of expectations people have out there. And especially in that particular case. And it was just like, how do you get around that? Because you were going to have to like have a little side.

Like a side tussle with the police while you’re in the middle of having this other case again with the gun manufacturer. So yeah, there were lots of issues for sure in that case. But do you feel like the focus groups helped the case resolve? 

Justin Starin: Yeah, [00:24:00] definitely. I think that’s definitely true. It certainly showed us.

What we were up against in terms of trying to persuade people’s preconceived notions of what the case was about or what a manufacturer’s responsibilities are. Some of the more preconceived notions that people have about these kinds of scenarios were just clarified for us to the point where we could then take a more direct approach.

honest look at our case and value it in a different way than if we hadn’t done those and we would have maybe got overconfident. And yeah, definitely. It always, I’ve never had a focus group that I didn’t think helped. Everyone that we’ve ever done helped in some way, some more than others, but I’ve learned something from every one of them.

Elizabeth Larrick: And he means some more than others. He means the first one we ever did together because Sid and Justin were my Guinea pigs. They were my very first. virtual [00:25:00] focus group in May of 2020. I was like, y’all, I’m going to try this out. Let’s see how this works. I think we had four people there. Do you remember we had four participants?

Justin Starin: Yeah. 

Elizabeth Larrick: What we ran, I have no idea what case we did, what we ran at all, but I think it was just, Is this possible? Is this going to work? Thank you for being the guest. Yeah, 

Justin Starin: absolutely. 

Elizabeth Larrick: I’m not even sure what we got out of that other than, okay, it’s totally possible. There are a ton of things we need to fix before we go forward with any more.

But, but yeah, I think folks groups of course are useful because they tell you just like you got clarity that, Ooh, maybe this is not one that needs to go to trial. And sometimes. A lot of times that’s what I feel like sometimes, like it, that’s what it helps you do decide, Oh, we can try this case. Totally fine.

Like the arsonist case. Yep. We can try this case. We know how to try this case. We’re going to get past those little things that they think. And then other times it’s, this is more than we can bit, bit off more than we can chew for sure. 

Justin Starin: I was thinking [00:26:00] about that one case that you helped us with the misdiagnosis of the cancer tumor.

After we did a focus group in that case, we learned that, and I’m going to give you the brief facts, so there was a young girl who had a growth on her arm, and the surgeon removed it, sent it to the pathologist, and the pathologist put it under a microscope and looked at it and said there’s no cancer. A few months later, the tumor came back, the surgeon removed it again, sent it back to the pathologist, this time, oh, yep, there’s cancer.

Oh, and by the way, that first specimen you sent us also had cancer. was also cancerous. So we got a problem. And what we learned in the focus group that really helped us in the preparation of the case was that they were going to blame the mom for not getting a second opinion. So mom, you should have taken your child to get a second opinion.

And So what we did when we started taking depositions is we [00:27:00] chose not to sue the surgeon, even though some of our experts thought that he may have been somewhat culpable, but we decided we’re not going to sue him and we’re going to use him to get around this. And so in the depositions, we went and said to him, do you rely on the pathologist?

When you make medical decisions about your patients, yes, and have you ever got a second opinion from one of your pathologists? No. Do you think it’s reasonable for you to rely on a pathologist? Yes. Do you think it was reasonable for this family to rely on the pathologist? Yes. And that really helped, knowing that, helped insulate our clients from the defense, which was that the mom was somewhat culpable.

Elizabeth Larrick: Mm hmm. And then it was like her deposition, like they couldn’t get her to do anything. She absolutely positively would not budge one inch and just gave them a run for their money, hardcore, [00:28:00] the epitome of a mama bear for sure. And terribly sad case. It’s so sad, but. You guys fought that thing all the way to the end.

I remember you were like, we’re going to have to go to trial. I was like, all right, let me come back. I’ll come back and help. Cause yeah, it was just like, you guys had been really with them for so long. And there were so many other extraneous things that were happening that were just like, Oh my gosh, we have to get this finished.

Like there’s a time constraint here. This girl, this woman is basically going to succumb to this cancer before we’re finished. Like Her whole, she was such a fighter, her whole goal was to hold, hold them accountable. But yeah, such a good way to use focus groups in the beginning, because you guys, that’s a pretty big case strategy thing to do, to not sue somebody.

Right. Most people would have said, oh no, you sue everybody and then they’ll pay you to get out, which can cause a [00:29:00] lot more problems than it does put extra dollars in your pocket. 

Justin Starin: And I think he was grateful to us for not suing him and it made it easier for him, I think he would have done it anyway but it made it easier for him to go to the deposition with less stress in terms of his testimony at the deposition and.

It really worked out very well because he was kind of a charming, you know, it’s, he was an orthopedic surgeon. They typically are people, persons, unlike a pathologist who’s behind the scenes. And they’re the nerds. 

Elizabeth Larrick: They’re one of the smartest people that come out of med school because they got to look at microscopes and do what that’s just all there is to it.

And you guys also had the primary care and doctor in there too, which had his own flavor of interesting issues, which. We’re not ever going to come into evidence, unfortunately, in any form or fashion. But yeah, those were good focus groups. Good example. I forgot about using that particular case. Let me ask you, because we got people who, from all over who listened to the podcast, what would you say to somebody who maybe is on the fence [00:30:00] about doing a focus group?

Justin Starin: I would say, do it and see how it goes. Like I said, I’ve learned something from every one of And they’re just not that much money. Compared to what you could spend just spinning your wheels about what the case is about or fretting over some fact that you don’t understand how it fits in the context of the frame that you’ve developed, or sometimes I’ve even thought that maybe they help with the briefing, you can understand that this is what’s compelling to people, and judges are people too, and if you got the first part of your brief and you’re trying to persuade the judge, Having some compelling facts help.

And if you know what facts are compelling and what aren’t, yeah, I think I would absolutely. Recommend doing them for sure. 

Elizabeth Larrick: And like I said, you guys literally bought a camera, used the room in the basement, and had some people come in. That’s how it, that’s how we all get started. That’s [00:31:00] exactly how I got started.

I borrowed somebody’s conference room. I bought a camera. We started advertising on Craigslist and people showed up and like you said, you’re going to learn something from every single one of these. And it’s only natural that we are stuck in our lawyer brains because that’s how we. Went through school.

That’s how we progress. We hang out with lawyers when we have questions, we ask other lawyers. That’s what listservs are for. But I always find that that then naturally creates blind spots that we’re just not going to see everything. And sometimes it takes an outside person for 75 bucks. A hundred bucks to tell us something, you know what?

And guess what? It’s worth every single stinking penny. That 75 opinion right there could go and save you a hundred thousand dollars or 50, 000 on that expert who you don’t really need. Or what I always tell people is we get really obsessed with experts and that’s such a good other place where it’s like, go learn what they need to know from the expert.

And then. Have the expert testify to [00:32:00] that, but don’t feel like you automatically understand what a juror needs to hear from an expert. And I got to tell you, experts don’t really like that because they’re like, I want to tell my whole blah blah. Okay, you need to get it for an expert because they clearly don’t get trial.

Like, you know, there are experts that you take to trial and there are experts that you take to get it settled. Right. And there are, I can think of a really good example in Texas right now where it’s, oh yeah, if I’m going to trial, that’s the guy I’m picking. If I just, I know I need one, but I’ll go over here to this pile of people.

There’s just a huge difference because they get that the jurors involved is not just about them and, you know, pontificating their opinion, total soapbox and sidebar. Sorry about that. All right, Justin, you’re in Missoula and folks, if you want to learn more about Justin and Sid, then I’m going to put all the contact information in the show notes.

Justin is also a river rat. So if you have any interest in. River stuff, and I’m going to say river stuff because if you live in Texas, you get it. We don’t have [00:33:00] rivers. We damn them up to make lakes. But anytime I’ve been up to hang out with Sid and Justin, I get to go on the river and I’m always grateful.

So thank you for my river trips. 

Justin Starin: Yeah. We’re going to, we’re going to turn you into a dirt bag by the end of this, for sure. 

Elizabeth Larrick: So the funny thing is another sidebar here. When we float down the river in Texas, we get a tube and a cold beer and we put our butt in the tube and you just float down the river.

Not so much in Montana. You’re going to get swept away, uh, got to get a whole boat thing, which is not even a boat. I’m not probably not even saying it right with the Justin gets out there. How many boats do you have? It’s not a boat. It’s a raft. 

Justin Starin: I have a couple rafts, some kayaks. Yeah. Lots of boats. 

Elizabeth Larrick: Lots of boats.

He even took the whole fam down for a couple, how many, was it a week? 

Justin Starin: A week. Yeah. 

Elizabeth Larrick: 10 days down the snake river. 

Justin Starin: The salmon and the snake. Yeah. Yeah. 

Elizabeth Larrick: Nice. See, I remember it. All right. If anybody wants to know about rivers or personal injury cases, and they still have workers comp in Montana too, by the way, we had Matt Murphy [00:34:00] on and he talked about workers comp, which doesn’t really exist in Texas anymore.

And other places too. Justin, thank you so much for joining us. 

Justin Starin: Yeah. Thanks for having me. 

Elizabeth Larrick: Until next time, thank you so much. And everybody, if you enjoyed the podcast, please rate and review on your favorite podcast platform. And if you haven’t done so go and follow and connect with me on LinkedIn. That link will be in the show notes if you weren’t already doing it.

All right. Thank you.

Communication is the heartbeat of every relationship, and the bond between lawyer and client is no different. Listen in as we discuss the challenges and strategies of managing client expectations in the legal field with Matt Murphy from Montana. Specializing in workers’ compensation cases, Matt shares his invaluable experience and emphasizes the importance of being upfront and honest with clients, even when the news isn’t the most favorable. We also tackle the complexities of managing expectations in personal injury cases and the pivotal role trust plays in the lawyer-client relationship.

We highlight the importance of keeping clients in the loop and seeking their feedback, no matter how uncomfortable it might be. Listen to how changes in judges or legal rulings can alter a case’s trajectory and the need to involve clients in the decision-making process. Get insights on the importance of transparency and the art of delivering difficult news. Matt shares practical tips on effectively communicating with clients and setting realistic expectations. 

This episode is a must-listen for anyone in the legal field looking to enhance their client communication skills and build stronger relationships. Learn about the importance of open communication, managing expectations, and maintaining a strong client-lawyer relationship. 

In this episode, you will hear:

• The importance of building client relationships
• Importance of communication and trust
• Challenges with accepting medical treatment choices
• Importance of documentation and contact information

Follow and Review:

We’d love for you to follow us if you haven’t yet. Click that purple ‘+’ in the top right corner of your Apple Podcasts app. We’d love it even more if you could drop a review or 5-star rating over on Apple Podcasts. Simply select “Ratings and Reviews” and “Write a Review” then a quick line with your favorite part of the episode. It only takes a second and it helps spread the word about the podcast.

Supporting Resources:

You can learn more about Matt Murphy & his practice by visiting:

Matt Murphy website profile: https://www.murphylawoffice.net/about-our-attorneys/matthew-murphy/ 

Murphy Law Firm website:  https://www.murphylawoffice.net/

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 I sent you.

Episode Transcript:

Hi there. Another quick introduction for our guest, Matt Murphy, who is joining our podcast. Matt Murphy is a lawyer in Great Falls, Montana. He practices with his dad and his brother and has basically grew up helping in the law firm in some capacity since he was 12 years old. He has a passion for workers’ comp and he is currently a co-chair of the workers’ compensation section for the Montana Trial Lawyers Association. If you have questions,

about Montana or workers’ comp law, please reach out to Matt. His contact will be in the show notes. Hello and welcome back to the podcast Trial Lawyer App. I’m your host, Elizabeth Lerner, and we have a shiny new episode today with a wonderful guest from a state that I have a very special place in my heart, poor Montana. Matt is joining us. We heard a little bit about his bio in the mini intro, but I wanted Matt to come join us because I met him.

multiple times at an Intili Montana Trial Lawyers Association seminar. And he has this great bubbly personality. I know that he loves what he does. And he has a true heart for helping workers and his workers comp, which I know a lot of folks that are listening, even my Texas folks are thinking, well, I don’t do workers comp. And that’s okay, because what we’re going to talk about today is client management and more specifically more about client expectations. And

speaker-0 (02:05.226)
This came up for me here recently where I was assisting and helping with a trial and there was some definite expectations that had been missed. And so the client had quite a huge expectation for this trial and their time on the stand, which was very different from reality. So we had to work with that. And so that kind of spun itself into an episode. And I thought, gosh, Matt would be great for this because I know he loves his clients.

He’s also a pretty good straight shooter. thought, let me get Mountain here to help us. So Matt, welcome to the podcast.

Thank you very much, Elizabeth. That’s very flattering. And I can’t really imagine a better compliment for an attorney than it being obvious to other people that they love their clients. Cause we do. And I’d say that we, cause I speak for all of Murphy Law firm. And I’d also like to return that. Thank you for all that you do. We’ve really learned a lot by listening to your podcast and attending your speeches at the Montana trial lawyers association. So thanks for everything that you do as well.

Well, pile it on now. love this set up, that’s why it’s part of the podcast and why this podcast is really made for people who are working with clients, first-hand clients, workers, comp, employment law, a little bit of business litigation stuff, because managing client expectations is really across the board. But where it tops up so often for people like us and like you is when we’re having our clients that are going to testify.

or they’re coming to a hearing or they’re going to mediation and understanding really what we need to be doing so that we kind of avoid some of these places where we need a lot of trust from our clients when it comes to handling a case and making decisions for that case. And when it’s their turn to come in and do testimony or be at a mediation and answer questions, right? We want to make sure that they’re going to trust our guidance and coming to trial as well. So just from the standpoint of like,

speaker-0 (04:04.074)
Why is this even an issue for us as lawyers? And my perspective is we go through law school. We’re super trained to think intellectually and be super logical about stuff. And sometimes managing expectations feels like stickier and a little bit more emotional when it’s straight work for us. So I know it’s hard to have the conversation with people. And has that for you, Matley?

practicing, has that been kind of a hard conversation or a little bit uncomfortable to help manage people’s expectations?

Absolutely. And it’s kind of shameful to say, but in Montana, work comp, that arena, you have a lot of that because the benefits that an individual is going to get in a work comp claim, that pretty much day one anymore, I will have the conversation that says, you’re not going to be in love with the result. No matter what I do, no matter what anybody does, the law just affords the remedies that it affords.

It’s a insurance policy written by the Montana legislature. That’s the Work Comp Act. And it just keeps getting whittled away, whittled away. It’s been on this downward trajectory for well over 50 years here in Montana. I know that’s not just true in Montana. I’m familiar with other state schemes. so you’re not going to be able to tell a Work Comp client, we are going to have our day in court talking to the jury.

about the human damages. There is no pain and suffering. There’s no loss of consortium. There’s no established course of life. So you’re limited to statutory medical, statutory wage loss benefits. Those are capped in all sorts of crazy ways. I could go on for days about it. We’ve challenged the constitutionality of those statutes. You we’ve had a case in every decade for over three decades, at least one, but those are hard. They take forever. You got about a 4 % chance of winning right out of the gate.

speaker-1 (06:00.588)
So anyway, you are in most of the clients that I represent having a conversation day one about the fact that the benefits that are available to them are going to be less than what they’re hoping for, certainly less than what they’ve lost. I mean, we are not getting made whole in a work comp claim. And I’ve realized that you kind of got to start on that foot because if you just talk them into

how well you’re going to do and how big of a delivery you’re going to have day one and then a month later or three months later or a week before trial, which would be terrible. Now you’re bringing this to their attention. You’ve already lost it. So they don’t want to hear it, but they can tell you’re being honest and they can tell you know what you’re talking about and that you’ve had that conversation before. So yeah, back to your question. Yes, we have that conversation. Unfortunately, it’s a little bit easier in the work comp context because you can

almost have this common enemy, the Montana legislature. And here’s this book and I’ll show you the exact verbiage, which is a little bit different than all the complexities of trying to explain why, you know, when you go before the jury, things might be a little bit different than what they hope, but that, you know, that only gets you so far. It’s still going to be on you to be honest and candid and establish that rapport with your client.

Yeah. And I think you kind of nailed it. It’s really about the timing of the conversation and how you’re presenting it because that’s a total intellectual like, you think this is what you deserve. This is literally what it says it like and why. And you can go talk to six other people. They’re going to tell you the same things. But a lot of times, I’m unsure you’ve had this in practice where you have somebody who comes to talk to you and they interviewed a lawyer and they say, well, the other lawyers didn’t say that. The other lawyer said this or that. Then it really kind of comes down to

how do you express yourself in the most honest way possible? Like, I’m just here to help you and here’s truly what it says, you know, I’m not making this up. I’m not just trying to get you to sign on. And I do think it’s really kind of one of those things where people…

speaker-0 (08:02.99)
It’s just a hard conversation sometimes to have and it’s hard to break people’s expectations and to know you’re not gonna be made whole. I that’s a great example. Like there’s this whole loss here of like, here’s where you need and here’s what the law provides. And I think even that happens a lot of times in car wreck cases as well, where it’s just like, you know, well, $5,000 is all they’re offered. And it’s like, that’s true. There’s not really a guideline for this, but that’s why we go to trial and why our litigation and all these other things. That’s kind of where

You have to constantly be talking about managing these expectations. You said, Hey, you guys do it right in front you. Are you doing it along the way as the case goes along? Or, know, when you guys are coming up to that making decision point, how else do you work in managing those expectations?

So with comp, you know, that’s easy for me to answer because I do it right off the bat, but it’s for specific reasons. That is the statutes that prescribed benefits are just, I don’t like them. And I can say that and I can say how we lobby and I can tell them all the stuff we do behind the scenes that are in their case to try to change that. Some of it works. All of it helps. Most of it doesn’t do a whole lot, right? But that’s an easy one for like say a car wreck case.

or really any personal injury claim where it’s not so black and white, you don’t really have that common enemy, the statutes that limit benefits. Instead, as we all know, oftentimes the enemy is some aspect of your client’s case, or in other words, some aspect of them. And I don’t think you’re going to be able to understand it well enough to really get into it day one. But what you can do and what I certainly do is day one, I mean, I do this before I hire.

In fact, if I’m thinking, I mean, I usually probably do this twice before we sign them up, just to ask them, what are your expectations? I find that most people and by most is probably a vast majority are reasonable with their expectations. want to get my car fixed because I’m missing work right now and this rental isn’t working out. My neck hurts. I want to get my medical bills covered. I’ve had to miss a month of work and I got a mortgage. I mean, that’s all totally reasonable stuff.

speaker-1 (10:17.728)
And so pretty clearly right out of the gate, you’re going to realize this individual has reasonable expectations that I shouldn’t be able to meet if I’m doing my job and I hope I am. So you’re going to have that conversation in the intake and then you’re going to have that conversation when you meet with them in person. Because part and parcel to all this is during your representation of clients in whatever realm, you got to be meeting with them in person and you got to be talking with them and you should be asking them, what are your expectations now?

as the case progresses and you’ve had a number of conversations with them where you’ve covered this item in this conversation, a development, now it’s Depot Prep. you know, as the case grows and your relationship with that client should be growing, if you’re calling your client for the first time the week before a deposition, I don’t know how you tell them anything. How can they trust you? How could you trust them? As it goes, I think most of time you’ll find their expectations shift a little bit and kind of track.

what it should based on what you’ve been telling them, based on what you know about the case that you’ve been communicating to them, based on the rapport that you’ve established by having really good communication and always shooting them straight. And you kind of mentioned clients that come in that have consulted with other law firms are almost like testing you. I find that the easiest and the only really solution to that, but certainly the easiest is just shoot them straight in plain English and let them know. And if they don’t like it, you’re doing yourself a favor, but

they’re probably going to like it because you might be the first person that’s actually, you know, shot them straight in, whether they have a law degree or not. People like juries can detect the truth and the credibility they got, you know, like Jerry Spence says, psychic tentacles. And they have that in your office. They’re looking at you. You know, that they know when you’re exaggerating, even just a little bit versus when you’re shooting them right down the middle. And that’s how you got to approach that.

Mm-hmm. I totally agree. And I think that’s kind of part of some place where we don’t sometimes as lawyers stop and ask that they open a new question. What are your expectations now? How do you think things are going right now? We’re really just stopping and listening and asking that open-ended question. Most of the time when we are calling and having conversations, it’s us telling them.

speaker-0 (12:34.456)
here’s what’s happening, here’s what the next step is, here’s these instructions, here’s this, right? And so that stopping and listening along the way, like you said, really helps to build that trust. And also I think it’s really important for us to also express what we expect as well. And that way you’re building that relationship together where it’s a tit for tat, like you tell me, I’ll tell you, right? So we’re constantly on the same page because what can happen if we don’t…

those conversations early and often is, I I’ve seen people get fired, I’ve seen people get sued, I’ve seen, honestly, like a client basically loses interest and it’s just like they’re like, whatever, I don’t want to do this anymore, let’s finish this out. And then, obviously, you never get a referral or a good review from that person when it was probably just a matter of having these conversations. And nobody wants that to happen, but…

What I saw in that case was basically what started as probably a small seed grew into this giant tree of anchor. And it was just like, how do we now manage this? Because now we have a whole different set. We’re not changing it. That is set and we’ve got to now somehow work and manage around this when we probably could have done that a long time ago and not have this.

giant ball of anger ever dealing with. So let me toss it back to you, Matt. What are some of the things that you’ve seen happen when we don’t manage clients expectations?

And that’s a really good analogy because if you represent people long enough over in complicated areas of their life, because I mean a personal injury lawsuit, as much as we try to limit the inquiry and as much as we try to keep as much of our clients privacy to themselves as possible, their whole lives get opened up, whether they like it or not. Regardless of what we do, it just happens. So you’re involved in all areas of their life. And when it’s that broad for that long, you…

speaker-1 (14:30.584)
You’re going to have, you know, we’re people, we’re people, there are people, going to, you’re going to have some issues that start as seeds. And I really do feel like you can at that phase intervene, salvage the relationship by doing so. It’s just like having your first fight with your significant other. You become stronger in your relationship with that person and hopefully you don’t have to have too many fights, but we’ve had plenty of clients that are extremely difficult that

Nobody else could help. And we have some excellent firms and we’ve had clients had to move on as well. Sometimes that is what is necessary, but we kind of pride ourselves on being able to take a problematic client, if you want to call them that, or someone who’s really difficult to work with and get through it by being honest, by counseling them, you know? So yeah, you got to keep asking the question, what are your expectations? But you also got to keep asking, how you feel? How’s it going? What do you think? Could we be doing anything differently?

The only reason you wouldn’t ask certain questions like that, I think as a lawyer is because you’re kind of insecure about what the client might say. And there’s no reason for you to be like that. You know the law better than them. You know the process better than them. You should not worry about what they’re going to say because whatever it is, it’s going to lead to the route that you need to address to get back on that same page with them. And you can’t forget your obligation to be a counselor of law. You’re their advocate. You’re staring up through the legal process. part of that

And as we all know, the part that pays massive dividends by the time you’re actually getting to trial or getting them through a deposition, if it doesn’t go to trial, is the rapport and the trust that you’ve established with them. So I think your question, I went off on a tangent there was, what have we seen? What are some examples of breakdowns or bad state developments that have to be communicated that lead to a disgruntled client essentially, right?

One that actually just happened to me last week was in Montana, we’ve had a work comp judge for well over a decade who I wouldn’t say trust more than the new judge by any means. It’s just, know this old judge that I’ve been trying cases in front of and had conversations with, listened to him speak. So I’m really comfortable predicting how I think he’ll approach certain issues. Now we have a new judge, you know, in the appointee process, there’s partisanship to his degree.

speaker-1 (16:51.788)
Not that I believe this new judge has that problem, but is an unknown. And so it has to change the advice that I’m giving to my clients. And it sounds like I’m saying something different than I said six months ago, because we’re still in the litigation process, pretty far from trial. That’s not what’s happened. It’s just a new judge got appointed. So things did change. And this isn’t a great example because this client wasn’t disgruntled, but the reason was they weren’t happy.

They didn’t like what I was telling them, but I’ve had enough communications with this person. I’ve put the time in, had enough interpersonal reactions and been able to actually bring them into my office and face to face enough. And they know me now. They know my paralegal very well. They know our secretary. You know, they just, trust us. So I was able to explain to them, show them. now we ultimately resolved that case for less than I probably would have advised under the old judge, but with the unknown and

some new issues, I do believe it was the right decision. So, you know, that’s one example. And then I can think of many more where due to a new fact or say a legal ruling, you’ve kind of had a lot of your eggs in a basket. You get a bad ruling. Now you’re telling this client, well, it’s not going to be anywhere near where we were hoping to get. But if you set that up right by explaining that at the outset, it shouldn’t be that difficult to say, see, remember when we talked about this before?

And now it happened. now we’re kind of in this camp A as opposed to camp B where we were hoping to end up.

Yeah. And I think that’s exactly because rulings change cases. We don’t have any control over that. You know, we can try and predict things. You may take a deposition and all of sudden you learn one of the claims that you thought was maybe pretty viable is now dead, right? Dead in the water. got facts that basically kind of obliterated, you know, not obliterated, basically take away your factual basis for the claim. And that’s sometimes where, like you said, it goes back to when you’re making a motion.

speaker-0 (18:52.462)
or you’re taking depositions, I think sometimes we forget we need to check back in and say, hey, let’s just do it, check it, and we took these depositions, here are the facts that we found out. This is it impacts what we’re doing. It’s gonna change things this way or that way. We can predict as best as we can, but I think that’s part of going back in and keeping that education going and keeping that conversation open because I think I’ve seen that happen quite a bit, like where it’s like, you take that opposition.

you find out something new that’s detrimental and it’s like, I dread, I don’t want to make that call or I have that equal client who I know is going to be really like, you know, and I think you made a very good point of like getting that person in person. And I think even just getting somebody in Zoom because that way they’re able to see your face and see how you’re expressing yourself and making yourself available. And it’s not that you’re saying, I’m sorry we failed because

We can’t control what happens in that position. The facts come out or how a judge rolls. And I certainly have had a situation where I had to call a client and just say, yeah, listen, this happened and it was a mistake. You know, and here’s what I can do to make up for it. And here’s how it’s going to impact things. And anytime I have like totally come to the carpet and just said, this is what happened. Everybody’s sure like, okay, like we get in a problem solving node and set it like.

fixating the problem. And that’s generally what I try to say is like, listen, this is where we are now. Like, here’s how I’m going to help. Here’s how we’re going to make up for it. But because at the same time, think like you said, you’ve done a good job of bringing people along in the relationship. And in that case, they’re going to have enough trust in backgrounds to know like, okay, this is what Elizabeth said at the outset. You know, this is what Matt said at the outset. But here’s where we are. And it’s okay to remind people the battles that you’ve been through to get to this place. It’s not, is not easy.

for you or for them. they, think sometimes they forget about like, it’s a battlefield all way through. So keeping that education open as well, I this is a huge factor in keeping people, cause that, think that surprise factor is the worst thing. That’s what I, I, it’s the worst thing.

speaker-1 (21:06.358)
Yeah, surprise coming after a massive gap in communication and they haven’t heard from you and then all of sudden you just call them with bad news. You can’t expect anybody to be okay with in any type of profession, right? You go get blood exams from your doctor and six months later they call you and say, well, yeah, you know what? You got a month to live. You’d be like, I kind of expected a call earlier or you bring your car into the mechanic and then they send you off on your way. And then six months later,

The car breaks down and they’re like, well, yeah, I mean, your engine was bad. mean, that’s would be unacceptable in any realm. It’s not acceptable here either in ours. And ours is very complicated and very interpersonal. So I think there’s even like a heightened duty on us to meet those client standards of trust and communication and relationship building. And you kind of mentioned, well, you often mentioned in the multitude of episodes that you have addressing depo prep specifically, but also trial prep.

One really good way to kind of keep your client in the loop that doesn’t necessarily require that you set up an in-office meeting is to just send them these developments in the case as you go. it’s almost like giving them homework, but it’s also keeping them in the loop. It’s also keeping them invested. So I will send them every deposition transcript, unless it’s, I mean, I can think of some examples that I wouldn’t, but any fact witness, their doctor, I will just send them and say, Hey, you know, if there’s a

Obviously big bombshell fact. I’ll point that out and call them in and whatever. But if it’s just pretty run of the mill tracks with more or less, but obviously every deposition does has some new information, maybe good, maybe bad, whatever it might be. Send it to him. Hey, give this a read and tell me what you think. Like just a quick little cover letter. Sometimes they won’t call you. I don’t, maybe sometimes they don’t read it. I’ll call them out later. If they don’t, Hey, what’d you think of that deposition? Did you see that part where Dr. So-and-so said that? it’s like, Hey man.

I send you stuff to read, expect you to read it just like I’m reading it and I’m there. And if you send me an email, I read every word and you can check them there. But it keeps them coming along. It keeps them apprised of developments. Oftentimes they’ll call you. Sometimes they’ll give you really good stuff. They’ll say, hey, that’s not, that’s not right. And here’s somebody that I know that can refute that. Or here’s why I know that’s not correct. A lot of times they’ll just say, man, Dr. Miller really kind of bailed on us there. He told me in the appointment that

speaker-1 (23:32.226)
He was a hundred percent sure this was causally related and now he’s saying that he doesn’t really know. And you’re like, right. And that’s his testimony and that’s going to affect the value and that’s going to be what the jury hears. And so now you have that conversation and it doesn’t have to happen in the mediation or they don’t read it in the motion in lemony or whatever it might be. So you can keep your clients involved with a simple letter and a transcript and email.

And they’ll get it. I mean, they’ll understand most of the stuff and when they don’t understand, guess what? It’s good time to have a conversation and get them on same page.

Yeah. And city people transfers is pretty intense. I’m not gonna lie. I it’s when it’s in your example was for their doctor, like you go take their doctor, like here’s your doctor set, you know, then reading or rep stuff, a little bit. And it’s just, you know, like some people get like super lost and they’re going to give up, but I like it. Even just giving a quick recap email or.

Yeah that one, yeah.

speaker-0 (24:37.326)
I love using, cause people love videos. Like I love using Loom, it’s free and you can make a five minute video for free. And they literally just watch, cause again, you talking like we love, we’re easy. Talking to us is like easy. So you can talk that out without having to write it. Cause if you’re like me, like when I write a client email or an employer email, like I write it and I leave it and I come back and I read it again. Cause I just want to make sure like, can I be clear?

How can I leave no ambiguity here? Like, am I covering everything versus like, I think when you say it, it’s five minutes, you can watch it again and speed it up. And so can they, and email will even do a transcript as well so they can kind of watch it. But keeping up with people that way, in a way they’re gonna read it in a page. And of course, I always ask myself, what’s the easiest way for us to communicate? and I know you’re gonna like, some people love email. Of course, I love email. We live and breathe email, but some people don’t. Like, well, can you just text me? Like, sure.

And you can do the same thing on your phone. Just text, talk, or do that little audio file really quickly just to let them know. And like you said, it’s like, do you want more? Let’s get a recall. Or are you good? Just making sure there is anything else. But I love that because those little changes from that position, that’s where you’re going to get an ideation and that’s where it’s going throw it at. You’re like, well, that’s not what they said that appointment, right? And then it’s like,

Okay, now we’re going to be in a huge deadlock because your client thinks that’s one way, but in reality, that’s just not how it out in demo. So that’s a good solid example. And why I really like taking the client demo a little bit later is again, so you have that ammo, like you know what’s in there. So you know where that client has to fill in those gaps. Then that significantly helps. And so they don’t have to get you down on the leads.

But okay, here’s where that gap is and here’s where the client can help or prepare and understand. then I think, like you said, the more we can kind of get them invested in what their role is, the better they are at meeting our expectations and for themselves and helping them kind of get through the emotional and psychological burden of being in this situation, being permanently injured at times, or there’s always going to be some kind of major impact to people’s lives when they’re injured.

speaker-0 (26:56.91)
Like that is such a huge component of giving them a role in the ability to do the rest of it.

precisely and everything we’ve been talking about so far is super important in establishing the trust and the ability to have those conversations with your client for better or for worse. The ability for them to be coachable because as you’re talking with them more and more and as you’re keeping them invested and involved in the case, they are becoming more and more coachable. I have not had an example yet where a client just can’t help but

eventually perceive, okay, this is a complicated situation that I’m not familiar with, that I need help with, or at least I would benefit from help. But what it also does is it enables you to do your job. I mean, it serves so many different benefits, but if you really want to be able to present the best version of your client’s case to the judge or the jury, especially the jury, you got to understand them, you got to know them, that’s going to take time.

And so you’re checking off all these important boxes when you’re doing these trust and relationship building activities, like going to their house. I mean, you want to get on somebody’s level. I, again, I think, you know, obviously this isn’t my idea, but I read this in the first Jerry Spence book I ever read. I mean, you go have a meal with your client in their house. mean, so that you’re going to, they’re going to trust you. They’re going to like you and they should. mean, it’s a special thing to be able to do that and for people to invite you in.

It’ll build that trust. It’ll allow you to have honest communications with them. It’ll give you access to the inner circle in their mind and in their heart, but it’ll also give you the tools that you’re going to need to present their case. So you don’t have to think of it like you’re only doing this so that someday if you need to give them bad news, you’ll be able to do that. It will help with that, but it’s kind of necessary to enable you to do the job if you end up in trial and everything in between, even writing the settlement brochure.

speaker-1 (28:57.71)
or the mediation brochure. mean, you will do a much better job having an intimate understanding and relationship with your client versus not really of having had much communication with them up to that point. And it, sure as can tell, so can attorneys, so can mediators. They know.

Absolutely. I would sell people what they’re going to go to trial. Do you your client? Because if you, who cares about the jury things, because they’re going to know right off the bat, you don’t want to post. But I think there’s also this occasionally when I’m talking with lawyers about preparing and bonding and people would say, my personality is just not necessarily very warm to that bonding perspective. And that’s where like, like the just having

open conversations, asking them about their expectations and constantly talking with them and listening to them is still, oh my gosh, goes leaps and bounds to that bonding and that trust relationship. Even though it feels like you’re still very much seeking to like an intellectual place, like checking in and keeping those lines of communication open, that’s half the battle because bad facts can happen anytime. They can be at the beginning, they can be in the middle, like…

depositions can change things and like avoiding conversations that are difficult because you’re busy or your skill letter apparently will take care of it. Like all those things just totally lead to trouble because it just kind of alls up. And then like I said, it can just lead to maybe having to take an avenue to your client really isn’t happy with or sometimes what I’ve found is even if you do everything right, you’re going to learn a lot about your client who…

will never have their expectations met. But you know the front end and you know how to manage it. Like, okay, like you said, difficult clients, we’re all gonna have. But as long as you’re doing your half a load on what expectations are and educating and doing all that, then you can at least tell them, hey, listen, we’re talking about this. I’m not hiding anything. You’re being upfront with how you feel and I’m being upfront with what the facts are. So we can work through this together or if you think somebody else do better. Because again, like you said, there are some people that you just

speaker-0 (31:11.502)
My arch-eye-eye-eye-eye-eye-eye-eye-eye-eye-eye-eye-eye-eye-eye-eye-eye-eye-eye-eye-eye-eye-eye-eye-eye-eye-eye-eye-eye-eye-eye-eye-eye-eye-eye-eye-eye-eye-eye-eye-eye-eye-eye-eye-eye-eye-eye-eye-eye-eye-eye-eye-eye-eye-eye-eye-eye-eye-eye-eye-eye-eye-eye-eye-eye-eye-eye-eye-eye-

Yeah, absolutely. And the obligation is not become their best friend. In fact, I mean, that happens. mean, I’ve become friends with my clients and I don’t think there’s anything necessarily wrong with that, but that can be a problem. And that’s not, again, that’s not the job description or requirement. This doesn’t have to be a relationship where you’re going to be best buddies with this person. But if you’re considerate and I say considerate because I mean, you don’t just get to be so busy that you’re blowing off.

their feelings or you’re not taking the extra steps to make them feel good. mean, you need to polish and do that. And then just being honest, you’re going to develop mutual respect. That’s what’s important. That’s what the jury needs to see. And they will. We talked about how, well, the insurer and the defense attorney will know that the jury will definitely know whether you like your client and what your client thinks of you relatively quickly. And that’s critical. I mean, if your client doesn’t trust you, how’s the jury going to trust you, right?

And that’s if you get to trial, if you don’t get to trial, there’s definitely a reality where you could end up in the same spot result wise, but depending on the route you took to get there, one being that you had a good relationship with your client the whole way, their expectations are met, they’re satisfied, they’re a happy customer, they give you good reviews. Nothing gets you off on a better foot than when your client comes to you because their best friend or their brother or someone that they really trust is the one that sent them to you.

So just having good referral sources by maintaining that standard is probably the best thing you can do for yourself, but you can get to the same result that way, or you can go the way where, you you still get them the money or whatever it is, but you didn’t have a good relationship during that period of time. They’re not happy. And I definitely have seen that every client’s different, but in my experience, it’s more often than not how they feel about you and how they feel like you’ve been doing their case.

speaker-1 (33:08.32)
et cetera, then the ultimate result that’s going to factor into how happy they are with you. And again, I mean, with work comp, I’m already in my mind going, wow, there’s all these examples where no matter what, they’re not going to be happy necessarily with the result. But knowing that at the outset, okay. And then taking them through and showing them and being really communicative throughout seeing this is what I was talking about. This is what we talked about on day one. And then after this, whatever it is and

going forward and this is that lie I told you about, now this what we’re saying to the judge. They will be a lot happier and ultimately they’ll know you did your best. They’ll know you knew what you were doing and that you did a good job. And they will put the blame where it’s supposed to be, which is on the law, on the legislature, not on you. You can have a very happy client after the fact, even if they can’t get full justice, like you’re not getting in a work conflict.

And I think what you’re saying is absolutely true for car cases. I mean, I definitely think of many examples of percentage cases where, especially in men’s males, like anywhere you practice men’s male is going to be like, there’s just not going to be generally, there’s not going be enough quote unquote justice to go around because it’s just, that’s the sway of the laws, right? And I think you’re right. You can take two pads. can take the…

The path for, yeah, you’re going to have to spend some time on that relationship and expectation. And that means you and your office, like you said, it’s always a team effort and always have everybody communicating, or you can make it difficult and have less communication. Yes, you’re getting the job done. Yes, you’re going to get to that finish line, but at end of the day, like where’s it going to end up? And I think what people understand is people.

They may not ever understand why a law is written the way that it is. Like they may never understand people at that capitol are making decisions that really truly impact them. They may never get that, but they will totally get how you treat them. How you treat them as a lawyer is how they will believe any lawyer will treat them. And we sometimes are the only lawyers they have contact with. And I always try to keep that in mind because when I was growing up and along the way there were lawyers and

speaker-0 (35:27.47)
To me, they just had all this power over my life and other people’s lives. And it was just like, wow, what an impact they’re making. I don’t know that anybody will feel that way. They have that same expectation of like, what will you do for them will totally impact their lives. And it’s true, even if you get the best result, which is still not the greatest, you’re still making an impact on their life. And I think we always should be keeping that in mind. It’s like, okay, I know what I do as a lawyer is pretty normal to me because I do it every day.

those people like it makes a huge difference and how I really is how they’re going to proceed all years and I want that to be a good thing.

Absolutely. mean, how many of us have heard about, have had examples where clients are going, I just don’t trust that doctor and I don’t want to treat with them anymore. And you’re going, Ooh, that’s a really good surgeon for sure. It’s just a bedside manner. And so that doctor with the little charm school, I mean, they’re the best doctor in the Northwest, but it is a necessary part of the job. And more so, think with us than, you know, the surgeon who can show up and do a good surgery, but it contributes greatly to your client satisfaction.

their impression of attorneys. We kind of talked about at the outset, I mean, when the client comes through the door, they have expectations for their situation, their injury, their claim, but they also kind of have a preconceived notion of you. unfortunately, a massive, and even clients who walk through our doors, a massive portion of that is tort reform and just schist lawyers and whatever you want to call us. mean, they all have that.

And my brother is a general contractor and he’s always got about six to eight blue collar construction workers with him, whether it’s in his living room, whether they’re out getting a bite tea, whatever it is. I just, that’s my focus group. That’s my down and dirty focus group. Cause that speaks for Great Falls, Montana, especially. I’ll just run, float the ideas by them in all regards. They’ll just…

speaker-1 (37:27.23)
almost dial it in in five minutes, what I’ll spend thousands of dollars and hours doing with a formal focus group. But one of the things we will periodically discuss is lawyers in general. And those are the guys that I represent, guys and gals. mean, they get hurt in that construction trade. Those are the people we represent and they’re going to have that initial impression. They’re walking in and their whole lives, maybe they’ve been kind of degrading us in just cheerful conversation. All those lawyers. You’re starting on that slide.

And what will immediately kind of immunize that problem is honesty. It’s that simple. You just shoot them straight and simple and they’ll pick up on, they know how to read. Yeah.

And I think trade bleeding that over, it’s the billboards, right? It’s the billboards with the millions and millions, the commercials with the millions and the millions. And most of the time, there’s a lot of clients that I would deal with because I’m like, well, okay. I always ask people like, what do you think happened to that person that they had to get millions and millions and millions? Like, right. And that’s kind of perspective, not necessarily expectations, but let’s keep ourselves in a perspective where we kind of got to do that.

helping with some comparisons. But yeah, I mean, it can be super frustrating because people do come in with that. And doing it day in and day out, like, you eat what you can. Like, we got to keep that will be all we got to keep people coming in. And I think sometimes we forget to like stop. And what’s your experience? Hey, what do you expect of me? And just to make sure that we’re checking in and doing that and in the correct way. And because you never know and you just you can, something can totally creep up and you just like, you don’t know until too late. And all of there’s you me and you’re like,

don’t know, like when is it that they’re upset about? Like, and you just don’t know. And that’s kind of like getting that whole hidden surprise thing. It in, we’re just like, or you get really upset about something that they’re doing. And it’s like, okay, if these things are happening, like just stop, conversation.

speaker-1 (39:23.68)
Yeah, bring them in, get them in. The minute it bubbles over, get them in. Just, just stop call. You got to, we’re setting up an in-office appointment. That’s it. Come on in. mean, that’s, found that to be one of the most effective tools in the toolbox. Just immediately. Once it’s officially passed the boiling point, just, okay, we’re going to postpone this and we’re going to talk again when you come to my office or I’ll come to you, whatever, but we’re going to meet in person.

I mean, that cures the majority of those issues in my experience.

I agree. And I think people want your attention and then it’s by the attention and then it’s really difficult to stay really upset. When someone’s sitting across and you like literally just listening, it’s like, I can’t really be like upset with you while you’re just sitting or listening to me. And then we’re pro-assaulting. And it’s not like everybody has to say, of course, well, I’m sorry. And like, that’s not what we’re talking about. Cause sometimes it’s just the job. Like we can’t be sorry about a judge’s ruling. We can be disappointed in it.

Like that’s for sure. Like I’m just flying here and this one here’s how we pick up the pieces. And I think sometimes that’s where like we think, somebody has to apologize. It’s like, no, sometimes we just have to get together, talk about whatever it is that’s upsetting, figure out if it’s really something we can control and then let it go or work with it.

Yeah, that’s what they want. They want a problem solver. come in, they’re coming to you to fix this problem, to make this situation work for them. mean, so you’re right, but you can’t, like you said, you can’t just jump there. You got to start with the, just the same stuff you’d start with anybody, any human about when they’re going through a tough time or a difficult situation, the same exact rules apply. And it’s easy to put on the professional.

speaker-1 (41:11.938)
face and just not want to go there and not talk about emotions and not talk about disappointment for fear that you might be admitting that you’re the one that disappointed them or for fear that they might blame you. Don’t be afraid of that. mean, talk about it and allow them to talk about it and express themselves. They’ll feel better. They just having them re-explain the story in their own words will dispel some of that.

trauma, if you want to call it that. It’s the psychological facts. And then you can get to the problem solving, which is of course where we want to go right away. And in that realm, you know, have options and obviously have a plan, know your stuff. I mean, you generally will and certainly probably more so than them by leaps and bounds, but still don’t wing that part. When you’re delivering bad news with a follow-up of now what should we do? Don’t wing it. Have a good plan. Have thought it out yourself.

And I find that given them options, mean, as much as you might say, look, man, you know, there’s a really ought to do option A, but still, if that’s the only option you present, it’s a little bit suspicious. I would be suspicious of that if someone was saying this is all you can do. You only have one option. No, no, that’s never true. I literally can’t think of a circumstance in life where that is true. mean, and so right away you’ve activated their.

The part of their brain that’s going, Ooh, Ooh, I might want to get a second opinion here. So give them some options. You know, here’s some different choices. mean, my recommendation is they’re going to probably go with your recommendation. Obviously you’re the professional. That’s why they hired you. But they like choices. I like choices. Everybody likes choices. These are the potential consequences. Shoot them straight on that because if there is an obvious option, the potential consequences are going to make that obvious to them too. So.

I mean, there’s definitely a way that you can structure that conversation without them blaming you, maintaining trust, in fact, strengthening it, dispelling some of that trauma for them, and then getting on the same page and making it their choice to be going down the road that we’re now going down.

speaker-0 (43:16.428)
Yeah, perfect advice. Because anytime you try to just tell someone what to do, here’s what, this is the only option. Like I’m telling you what to do. Like the inner two-year-old and I, it just pops up, you’re not going to tell me what to do. Like you said, I’m always awkward. So it’s like, okay. That’s why like, anytime you like try to just give someone a list of instructions, like people are always going be like, well, you know, I’m going to do it with my, cause again, our inner two-year-old. I think that’s.

super advice, is prepare yourself in that conversation, have options, know what those consequences are, each option. And then also I think going in knowing you’re going to first listen, let them invest, let them tell what’s upset with them and their own words. And so trying to go in and recap and say, okay, so I know that you’re mad. And so let’s just like hear them hear the options. Nope. You got to take that first step.

Listen to them, let them get it out and then move through like kind of with that, move it into that auto-solving area and having those things ready and set and go for you and have thought up root even just five minutes.

It’s probably, not going to take you that long depending on if the legal issue is really complicated. You probably already briefed it and that’s why you’re having this conversation. I mean, it’s not like that takes a massive time commitment, but you should be polished in part of the presentation because that is what you’re bringing to the table.

Absolutely. I think most of the time we have options, a lot of them lead back to leaning more on the client to get something forced. Like, okay, this is what the doctor said. So that means we need more before and after witnesses now. So I’m to lean on you now. That means we’re going to do this instead. Or we heard this, like, okay, that probably is going to close our claim. But I’m going to go talk to one other person. I’m going to talk to our ex, right? This person who could actually the judge may listen to and…

speaker-0 (45:09.678)
can throw feedback on it then I’ll get back to you, right? So there should always be some kind of plan of action and always a follow up. Here are the options. You don’t have to decide today. I want you to think about this and then we’ll come back and read this.

yeah, yeah. Great. you, right. You all, I make them sleep on it. I say that, right? Like just like you don’t go to a car dealership and walk away with a car. You go home and go to sleep. You wake up in the morning and then you decide, you don’t buy a house the same day you walk through one. You shouldn’t come into the lawyer’s office and have the lawyer say, okay, but you got to make your decision. No, no, that’s, everybody resists that type of pressure as they should. So right. You let them sleep on it. You say, Hey,

If your wife or husband has any questions for me, let’s have another conversation where between the three of us, or they can call me directly. If we need to have a couple more conversations before you make a decision, that’s fine. This isn’t like we got to have this answer in by Friday at five. And if it is, then you better be on Monday.

Yeah. Yeah. And I would say, because we definitely, and you and I are talking about this, when we have that factor, we got to come in and manage expectations. But if we’re talking about time conversations, like if you’re managing expectations and keeping communication lines open, when you do have that time, when you do have that, this is our deadline of deciding to go to trial or take that settlement.

they know you’re going to get in space and time and options to think about it. And they’re going to be able to make that decision much quicker than somebody else who hasn’t had as many car stations with you and discussions and knows much is going on in the case.

speaker-1 (46:49.07)
Exactly. And kind of the typical example is mediation. mean, they got to make a decision, which really we all know is you can ask for an extension and you should, if you have an indecisive client, that’s kind of what you should do for their sake. But I don’t really have that issue. And I don’t often, because I think you’re starting that conversation weeks before the mediation, or least a week before the mediation by copying them with the settlement brochure. Obviously you call them to go through it before you send it.

Talking to them again a couple of days before the morning dog. So that’s how you’re approaching virtually everything. Deposition prep, the direct examination at trial. And in doing so, you’re never actually putting them in that pressure cooker where they have a time limit. And I mean, I know I won’t accept that, know, clients will, they’ll jump off the cliff before they’ll climb down if they feel like it’s their only choice and you’re not giving them any other options, you know? So to their own detriment, I mean, I just have a client right now who

She’s got a chronic illness and there is a treatment for it. It’s terminal. But she’s holistic and she doesn’t feel comfortable with modern American medicine and for whatever, you feel about that is irrelevant. This is a human, it was a life that’s worth saving. And the doctor’s saying, this is your only choice and if you don’t do this, I swear to I’m going to get rid of you and you’ll never get treated. I’ll tell every other doctor not. I mean, he’s going crazy. But what he’s really doing is saying this is your only choice and that’s that.

So, she’s exploring all this other stuff. It’s not working and I’m sure her doctor’s unsurprised by that. But what she’s not doing is engaging in lifesaving treatment. And I think a huge part of the reason is because she was given one choice and an immediate, better get on it right now. And it’s like, that’s a mistake. That’s a professional mistake. You might be able to save that person with a different approach. And all it is is your words and your attitude. Why would you not adjust?

So I’m obviously this at the doctor, but I’m also on his team. mean, I agree with him. It’s just the way that he’s delivering it.

speaker-0 (48:54.71)
Yeah. And I think, yeah, that type of alice is deliberate for sure. And I think you can yell at me, human type, all of it is. You can’t tell me what to do with one option. Right. That goes for anything. you call my CPA, they tell me there’s, nope, you got one option and you got a pale, that’s like, my daughter tells me there’s one option. Like, well, you know, I’m pretty sure that they have more than one way to solve problems. that, you have been so awesome. Let me just.

Yeah.

speaker-0 (49:23.926)
Make sure there’s not anything, any other tips or tricks or things that you can think of that would help those as far as when we think about like, okay, products will advise for managing client’s expectations before it gets too late.

I we hit the majority of the stuff that I wanted to get out, but I really feel like I ought to just bounce that question right back to you because I’ve gotten more from you on client preparation than anybody I can think of. So I really appreciate the opportunity to discuss this stuff with you though and learn from you and hope it has some valuable information for your listeners who are, I know there’s a lot of them and they’re all excellent trial attorneys. So thank you very much.

Yeah, and I think we definitely nailed it and I think sometimes it’s just, we all need a little refresh, right? So maybe this episode is just a refresher for everybody who’s listening. I’m like, yeah, like I do need to make sure and like checking with people and that’s all it’s about. And for me thinking about managing expectations, doing it a major pin at higher, at major decision points, at litigation.

filing litigation, a deposition point, making sure we’re communicating those things because those are pivotal points checking in. And that’s really all you got to do. And when you get the bad news, just pull the band-aid off. The festering is like the worst. Because sometimes you just can’t. Then you really have to manage a whole different problem and like literally crossing your ears and hoping for the best. And that’s never what you want to do with a case or a client.

I couldn’t agree more. And everybody knows that. The only reason you don’t do that is because you’re trying to avoid it because you don’t want to have to that conversation or you’re worried or you’re insecure. But that’s the same rule that applies to any relationship you have in life. You got to address those issues before they turn sour and the virus spreads.

speaker-0 (51:25.486)
It is absolutely true because most people, they’ve already made a commitment to you. They signed a paper, they’re with you. But it’s still a relationship we both have to do work in. It’s not a one way street, no matter what relationship it is. So yeah, you need to have expectations. They need to know what they are. They have expectations and you need to find out what they are. Because that communication line is sometimes half about with folks. then the only thing I would add is like,

And I most people have some kind of case management situation that helps them document all our case notes and call notes. I used to just literally use a Word document that had like a date and action conversation. So I always had everything in one place. That was super simplistic take on it. I’m sure there’s lots of fancy case management software out there, but having that documentation and having those emails with us is really helpful too.

just to make sure sometimes you got to have that timeline to remind people like we covered this in the beginning. Here, I’m going to remind you one more time. And here we are. We’re now having this impact on you. Hard to see that impact a year ago, but here it was along the way. So just another little fine tune point, but.

Matt, again, thank you so much for joining the podcast today. Hey folks, if you want to learn more about Matt or you want to get in touch with him or you want to go to an interview in light of it, or I will tell you, if you want to pick his brain about Worker’s Comp and what the lobbying efforts and what they’re doing there, this is your guy. He literally is the point guy. So please reach out to him. He is in wealth of knowledge on that stuff. All of his contact information will be in the show notes. So if you want to contact him.

Actually, Matt, let me ask you, what’s the best way for people to get a hold of you or they want to learn more about you? What’s the best way?

speaker-1 (53:14.924)
Yeah, absolutely. can, anybody can shoot me an email at mattmatt at Murphy law office.net. So M-U-R-P-H-Y L-A-W-O-F-F-I-C-E.NET or call my office at 406-452-2345. Like you said, I’d be happy to talk with anybody regarding anything, especially Montana work comp or any other states work comp. love to collaborate on those issues and find it to be very valuable. So thank you again, Elizabeth.

Awesome. All right. I think that we’ll get all those contacts in the show notes. And if you enjoy the podcast, please read and review it on your favorite podcast platform. If you’d to connect with me, go to LinkedIn. I’m trying to get more folks to connect with me on LinkedIn. And so that’s what I would ask for you today. And otherwise, thank you so much for listening.

Prepare yourself to embark on an enlightening journey into the realm of traumatic brain injuries (TBI), where science, law, and humanity converge. With Kenny Berger, a seasoned plaintiff’s personal injury lawyer from South Carolina as your guide, you’re guaranteed to gain a deeper understanding of the human elements in each TBI case. Kenny’s insights, drawn from his extensive experience representing TBI clients, will help you comprehend the far-reaching effects of brain injuries on all aspects of a client’s life. 

In this episode, we’ll navigate through the intricacies of building a case for TBI, discussing key elements such as documenting symptoms like confusion, dizziness, and altered mental status and the significance of eyewitnesses. Kenny emphasizes the importance of establishing contact with individuals who the client may have been in touch with within 48 hours post-incident. 

Moreover, we discuss the timeline of brain injury recovery and explore the value of sensitive imaging. Kenny also generously shares invaluable resources for those keen on learning more about brain injuries and neuropsychology. Get ready to embark on this enlightening journey as we unpack the complexities of traumatic brain injuries.

In this episode, you will hear:

• Exploring traumatic brain injuries with Kenny 
• Understanding brain injuries and memory loss
• Understanding the impact of brain injuries
• Timing in court cases and brain damage
• The importance of neuropsychological assessment

Follow and Review:

We’d love for you to follow us if you haven’t yet. Click that purple ‘+’ in the top right corner of your Apple Podcasts app. We’d love it even more if you could drop a review or 5-star rating over on Apple Podcasts. Simply select “Ratings and Reviews” and “Write a Review” then a quick line with your favorite part of the episode. It only takes a second and it helps spread the word about the podcast.

Supporting Resources:

To learn more about Kenny Berger visit his website: https://www.bergerlawsc.com/ 

To listen to Kenny’s podcast, Best Practices with Kenny Berger, listen here: https://www.bergerlawsc.com/reports/berger-law-best-practices-podcast.cfm

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 I sent you.

Episode Transcript:

Elizabeth Larrick: Hi there, it’s Elizabeth. I wanted to pop in very quickly to introduce my guest, Kenny Berger.

Kenny Berger is a plaintiff’s personal injury lawyer. He operates his own office over in South Carolina. He’s got an office in Columbia and Myrtle Beach. His [00:01:00] office operates with many personal injury areas, including workers comp. So if you have a case or questions about South Carolina, be sure and reach out to him.

His contact information will be in the show notes. Hello and welcome back to the podcast. I’m lawyer Pratt. With me, your host, Elizabeth Larrick. Today, we have a special guest joining us all the way from South Carolina, and we are going to talk about traumatic brain injury clients. Now I know most folks through your tuning into this podcast have a litigation docket.

And if you don’t have a TDI client, because I know there’s a lot of employment law and transaction law and other things. This is still a really good podcast to tune into if you have a case that comes your way. So you can kind of identify it, get it to the right place. And a lot of times, I think what is coming out as well is that the more we learn about TDI, the more we recognize.

We’ve all probably had some kind of concussion in our lives. So [00:02:00] always helpful to learn more about that. But enough of my jib jab, Kenny Berger, thank you so much for joining the podcast and welcome. 

Kenny Berger: Thank you for having me on. It’s great to be here. 

Elizabeth Larrick: Fantastic. So Ken runs a personal injury law firm down in South Carolina, and I want him to come and talk specifically with us today on this episode about.

traumatic brain injury. Now, we’ve never super dived deep into a specific type of damages. So, I’m excited to have you. Kenny, I know that you talk a lot about this at CLEs, Continuing Legal Education. There’s a couple of those topics I know on your website. So, I’m just going to throw it over to you. Kenny, tell us a little bit about TBI and how you got interested in helping these folks.

Kenny Berger: Yeah, thank you. So you’re right, if you do any type of personal injury, or even if you don’t, the likelihood of coming across somebody in your lifetime, friend, family member, colleague, [00:03:00] who has suffered a traumatic brain injury, these things are all just good to know, but especially folks who do personal injury, I think you just, you’ve got to be familiar with traumatic brain injury, and my goal today isn’t to, to do a deep dive in the science and kind of learn anybody, um, um, what As we go deeper into some dark abyss, but more just to point out some of the, what I think are real keys to unlocking what I call the power of your TBI case.

And by unlocking the power, what you’re really getting at is the dun da da dum, the truth, right? Getting to the core of the matter, the quote, what’s really going on. Yeah. And the way I got interested in these cases is neat. And there’s a connection here, Elizabeth. So 11 or 12 years ago, something like that.

I was out in Las Vegas at a reptile depositions. Seminar and this was in, I think maybe 2012 and I’m in line and the 2 guys in front of me looked familiar. We’re going to launch on 1 of the [00:04:00] breaks and the 2 guys look pretty familiar. Turns out there are a couple of lawyers from South Carolina who ended up becoming good friends.

My guy named David Yarbrough and William Applegate, and they’ve just. It’s been tremendously successful, great guys, but we ended up eating lunch together and there was another attorney with us, a lawyer from California whose name I can’t recall. But at lunch, the three of them, William, David, and this attorney from California gets talking about brain injury cases.

And as they’re talking, I’m realizing, wait, a friend of mine had just called me about a case that sounded very similar to what they’re describing. So after lunch, I got into the hallway and I called my buddy and I said, Hey, that case we were talking about, what are they offering you? It’s like they’re offering 50, 000.

I would, I’d take 60. I said, how much coverage is there? He was like half a million. I was like, whatever you do, don’t settle your case. I think it’s a policy limits case. And he was like, well, how so? And I was like, I think your client has a brain injury. I’ll tell you all about it when I get back from Vegas.

Well, what I then proceeded to do over the next couple [00:05:00] of days, in addition to going to the deposition seminars, I was learning as much as I could as quickly as possible about brain injury cases. And the fellow he was representing absolutely had a brain injury. There was just no doubt. He was different in terms of personality.

He was different in terms of memory. And attention and concentration. He was different in terms of his mood and his ability to control his anger. He was just a different person. And that’s what so many people describe. So I ended up representing that young man. And along the way, what I learned is. You had to know the medicine.

You had to know the science. That was true, but it was just such a human story. It impacted every part of his life, every relationship he had. And along the way, you know, I really got to know him and care about him and care about this family and his life. Elizabeth was a mess, a mess on the way. Up to Columbia from where these folks live down in Aiken, South Carolina.

And he and his wife had an [00:06:00] all out fricking world war three kind of argument. It was just, they show up and when they get here, he’s red face, she’s crying. It’s like, what’s going on? And it was exactly what people with brain injuries and their spouses experienced, and we had to take, luckily we’d prepped them and we sat down and again with them where the deposition started and more than anything, just worked to get everybody calmed down.

But that was again, 11, 12 years ago, something like that. And, and over the last decade and a little bit of change, we just took a real interest in, in not just brain injury cases, but the brain injury population. That’s one of those things where it’s the type of injury kind of like other ones, but it could happen to any of us.

Right. And I’ve watched what people go through from folks who would be considered kind of just working class. Hard Scrabble background all the way up to corporate executive lawyer types with brain injuries and everyone in between and to a person, they’re all [00:07:00] impacted just in a full scale, often hidden, often very apparent kind of way that certainly calls for help, perhaps above all else.

And yeah, that’s the short skinny on how I first got involved in it. I guess it wasn’t that short or skinny, but that’s how I got involved. 

Elizabeth Larrick: Yep, those deposition seminars, like, I still remember, like, those were my first reptile seminars. I still remember all the people that I met. I’m still in contact with them.

But it’s so amazing, like, you mentioned all the backgrounds of people, and just, I think what also is so different is every TBI is so different. You named off some pretty traditional symptoms, but having worked in the field, like you see so many different flavors or symptoms and it’s just like, wow. And like you said, it’s hidden, but it’s apparent, like the people around them can see it, or maybe just a little bitty small things that I think the science and the recognition [00:08:00] when we run focus groups.

People are much more familiar with it. And like, there’s definitely some language that people can talk about it a lot better, but I still feel like there’s a pretty big gap in knowledge for people having an in depth understanding about what it is. Is that kind of the way that you feel too? 

Kenny Berger: I think that the challenge is helping people understand that what may have started with a, quote, concussion could have these kinds of ramifications.

So one of the things I think you absolutely have to do is show that the mechanism of injury was sufficient to cause something terrible. Because what you’re showing is kind of the snowball effect, or at least you’ve got to show that the mechanism of injury was enough to light the match. very much. Right.

I think if you’re dealing in a case where you’ve got to get a biomechanical expert, or you’ve got a car accident case or car wreck case with no property damage, [00:09:00] and you’re claiming millions and millions of dollars in damages based on a TBI, I think you better be darn certain that something can be shown that if on the one hand you’ve got this raging fire That people understand that whatever caused that raging fire again was at least enough to get the match lit.

And what I tell folks a lot for me that the absolute start point is establishing that the client suffered a traumatic brain injury. Like just that’s kind of an easy elementary point. It’s like we have, of course, but I think that opens the door. To, to so much else. And when we talk about a brain injury, the person doesn’t have to lose consciousness.

The person obviously doesn’t have to have findings on a CT scan or an MRI scan. What you need to have based on the Brain Injury Association of America or CDC or the DSM 5 or really anything again, not to go too into the weeds, but it’s real simple. There has to be some alteration in brain function.

There might be [00:10:00] confusion. There might be some amnesia surrounding. The event you just have to show there was some alteration and brain function. And a lot of times it’s like, well, how do you do that? Cause you’ll see a medical records. They didn’t lose consciousness. And then later on, they say they did lose consciousness.

Well, most of the time asking someone if they lost consciousness is like asking what you forgot yesterday. I don’t know, I only forgot. So there are ways to deal with that and one of the really simple ways to deal with it is to say, all right, what’s the last thing you remember before the, we’ll just say impact.

Do you remember the impact itself? What is the very next thing after that? And the very next thing after that, the very next thing after that. And typically what you’ll find is there are pretty significant gaps in someone’s memory, which is again, by definition, post traumatic. Amnesia. And a lot of times by the time the EMTs get there, by the time someone gets taken to an ER, they’re alert.

oriented, [00:11:00] but before the EMTs get there, they may not be. So if they had a passenger with them, if somebody came up to their window, we hear that a lot, right? What’s the next thing you remember? I remember somebody at my window. What do you remember between the impact and someone at your window? I don’t remember anything.

Well, you get in touch with the person who came to their window. What do you remember about them? Ah, they looked a little dazed. They were kind of out of it. Again, you start checking off those boxes where by definition, even if you can’t document the loss of consciousness, you can certainly document the dizziness, the confusion, the altered mental status.

The fact that on some level, their brain function was altered due to trauma. It could be a rear end collision that knocks their brain back and forth real quick, which is known as coup contrecoup. It may be they got hit in the head directly by something, but just remembering that if you can simply, and you must, I believe, establish by definition that this person had a traumatic brain injury, it really opens the door and kind of lays the foundation [00:12:00] for whatever other damages may be costly related.

Elizabeth Larrick: Sure, and I think like that’s that whole causation and like you mentioned the mechanism of injury mechanism of event that forward and backward that is true battleground right there and that’s most time when you have a TBI case and the ER records are pretty much unhelpful like that’s the battleground that the opposing counsel is going to go after which is it’s fine it’s great you know they didn’t have to go to the emergency room or if they did so I think that’s really probably one of the hardest parts And I’ll just speak for myself, when I did have a litigation docket, like, I would get cases that, like, they did probably have one, but nothing was documented.

And so there’s this gap where they’re having all these symptoms, but Nobody’s marking it down or the chiropractor marks it down and it like that’s as far as they get. So you did such a good job going through like at the scene and like trying to get that particular type of information and symptomology, but yeah, [00:13:00] what else would there be?

Kenny Berger: And I’ll tell you, we try to get people to tell us everyone they talk to. Or came in contact with for like the 48 hours following. Because again, a lot of times the EMS records suck. The ER record sucks. And they suck because the person’s life isn’t in danger. They’re going to live. They just want to rule out a brain bleed.

They rule out a brain bleed. They send them home. And one thing to know is in the ER record, it says, or the discharge paperwork, it says, Hey, if you get worse, if any symptoms persist, go see a doctor. So that’s one thing, if they come to see you and they haven’t seen anybody, you can be like, Hey, did your ER records say if your symptoms persist, come back to them or go see someone?

They’re like, yeah. I’d be like, wow, that’s probably a good thing to do. But we always want to find out who did they talk to, right? Like, did they call somebody from the scene? A lot of times they’ll call the spouse or the parent. And so you want to talk to the spouse or parent. And we had a case recently where the spouse was like, yeah, Joanna kept calling me.

She called me. Three times she [00:14:00] called me. I’d hear some stuff. She’d be gone from the line. Call me. And I got real worried. And finally, I got in touch with her and she sounded kind of garbled. She didn’t really sound like herself. I couldn’t tell what was going on. And I was able to make out that she gotten in a wreck.

Does that win your case? No. Is that great evidence? It’s not great evidence, but it’s just one more thing. One more person who can testify to the fact that from the very outset, right? Like from the very outset, this person was not the same mentally. Something happened. Their brain was not working the way it did before they were struck.

They meet the definition of brain injury. And here’s here are things we know about brain injuries. And you can go down a whole litany of things about brain injuries. And the fact is, when it comes to concussions, which is just a type of brain injury, when it comes to concussions, which are known as mild traumatic brain injuries, that’s just a crappy medical classification.

for the initial injury. It doesn’t mean the consequences are mild. It doesn’t [00:15:00] mean the symptoms are mild. It doesn’t mean the impact on someone’s life is going to be mild. There’s nothing mild about losing a marriage. There’s nothing mild about losing your job. There’s nothing mild about falling into depression, becoming suicidal, all these things that are often consequences of someone having brain damage are not mild.

So you can kind of, you can work to disabuse people of the whole notion of mild. But the fact of the matter is a lot of people. You know, substantial percentage get better, make a full recovery, and that’s wonderful. What we often look at, though, is what are the similarities between people who don’t get better and what type of symptoms do they have?

What type of consequences do they live with? So rather than comparing a population of people who didn’t get hurt to people who did, we want to show the population of people who did get hurt, what the similarities are. And in that setting, you find some textbook presentations, some classic presentation symptoms.

But like you said, there are also some [00:16:00] individualized aspects because everyone’s lives are different and oftentimes TBI’s affect every area of a person’s life. And because of that, the impact on individuals varies. One of the added challenges in TBI cases is obviously that people typically look okay.

They talk okay. If you spend two hours with them, it doesn’t really seem to be a problem. If you spend two days with them, the problems become very clear, very pronounced. Because of that, we found over and over, the people who are best positioned to tell that damages story are the waywitnesses, right? This is stuff that David Ball was talking about.

15 years ago or more, but the people in a person’s life who are best positioned to tell the damage of the story, typically it’s not the person with the brain injury. Oftentimes they’re in denial. There’s still stigma that surrounds head injury. So in our experience, we want to go through a typical day and a typical week [00:17:00] and find the people that our client interacted with and talk to them.

We want to go on Facebook and find out, Hey, who’s that person on Instagram? Hey, who’s that person you’re doing that with? If someone says they loved going. Fishing. That’s a common one in South Carolina. Okay. Who’d you used to go fishing with? Get in touch with that person. Find out what’s different.

Obviously the more removed you can get from the financial interest. The better, but if you’re just hanging your hat, I think on the client to tell their brain injury story, you’re in a really tough position because it’s kind of a no win either. They sound so bad that it’s hard for someone to really wrap their head around giving.

That person money in the sense that they’re so bad, they can’t describe or substantiate what’s going on with them, or they sound pretty darn good leaving jurors think, well, heck, why is this person getting a bunch of money? So, if you want to know what they were like before and after, I’ve said it a bunch of times, the person with the brain injury is typically the last person you want to ask.

Elizabeth Larrick: Yeah, [00:18:00] 

Kenny Berger: they just, they don’t typically have the types of insight in a day in day out way that the friends, family, coworkers, neighbors, associates. 

Elizabeth Larrick: Yeah, absolutely. And I think you mentioned a couple of things in one was like concussion. And I hear a lot of times in focus groups, Google say, well, that’s not a brain injury.

They just had a concussion. Right. And so it’s like, there’s still this like loose. Oh, it’s different. I would, that gets better. I know this does it. And that sounds so serious to say brain injury. And I think that’s kind of where a lot of times having the before and afters. really solidifies, oh, like that, there’s so, that’s very relatable, but I think also the leaps and bounds that we have had in understanding like what it means in the brain and like having some really good, I’m not going to say animations because I think illustrations are, are wonderful.

And I think being able to describe it well also [00:19:00] is very helpful. I want to ask you a real specific question though, because I know DTI imaging has come into popularity and some people are yes and people are no. So like, how do you feel about like that kind of evidence? 

Kenny Berger: Yeah. So what’s funny before we came on the podcast, I was saying, we’ve done this.

The CLE, where we go through and we talk about like, all right, establishing the injury, using lay witnesses to tell the damages to where the very next point in that is determine whether there’s physical evidence of brain damage and if there is show it to them. So, I think DTI is fantastic for the right case.

Zooming out a little bit. I think that imaging, especially. More sensitive imaging. I don’t like the term advanced neuroimaging. This type of imaging has been around a really long time. It’s just not used clinically as much because from a clinical standpoint, whether or not there’s axonal sharing, whether or not they’re tears and the brain’s wiring may be relatively [00:20:00] insignificant in terms of prognosis, diagnosis and treatment where it has application, though, is improving that there’s physical evidence of brain damage.

Most notably, And in the litigation or forensic setting DTI, I really like for the right case. If, again, if you’ve got someone, um, we’ll just say over the age of 15 or 18 and under the age of 65 or 70 DTI is wonderful. And again, what you’re looking at in a sensitive way is whether or not there’s any damage to the brains.

Wires and the brand’s wires are known as axons. Diffusion tensor imaging or DTI looks at the damage to those axons and can spit out a real pretty picture that may show almost looks like color out spaghetti noodles and on one side, you may see some long strands will say of yellow. And then you look at the other side, which should look pretty damn similar, if not identical, and those strands are missing.

And what that helps establish Is those strands which represent axons or the [00:21:00] brain’s wiring are no longer there. They’ve been sheared. In other words, they’ve been torn or ripped open. And when they’re ripped, they connect a lot of brain cells. And when that happens, the brain cells die and the brain doesn’t function as well.

So, I like DTI another type of imaging that’s not as flashy and not as many people maybe talk about, but I think can be really effective is another type of MRI. And that’s something for folks to know. DTI is just a type of MRI. There’s another type of imaging again. It’s a separate MRI setting and it’s called S.

W. I. which stands for susceptibility weighted imaging. S. W. I. The same way DTL looks for tears in the brain’s wiring, SWL looks for little micro hemorrhages within the brain. Where have there been low tears, bursts? Where is there a little bit of microscopic blood on the brain, not that would pop up like on a CT scan [00:22:00] to show a subdural hemorrhage, but where they’re just tiny little markers where there used to be little blood spots and SWI can show that.

And again, that’s evidence that’s consistent with brain injury. DTI can provide evidence that’s consistent with brain injury. You can’t say because The DTI findings were positive, or SWI was positive. That means there conclusively was a brain injury. What you can say, kind of like an x ray, if you see an x ray of a broken leg, you can’t say based on an x ray alone what caused it.

But if you give someone the information, you say, hey, they got hit by a drunk driver two hours before the x ray was taken, got thrown off their motorcycle. And when they showed up at the scene, EMS had a compound fracture, you’d say, Oh, in that case, yes, I would say the broken leg is related to the crash.

Well, if you look at the clinical history and the clinical history, someone suffered a 10 foot fall, hit their head and was unconscious for 5 or 10 minutes or wasn’t, but was [00:23:00] disoriented. Uh, and confused and you do a DTI or SWI and you see again that there’s damage to the axon or their micro hemorrhages in the brain.

It’s consistent with, with the faults consistent with their being brain damage and based on the clinical history, you’d most likely correlated a neurologist or other neurospecialist would with the actual TBI. One thing to know about that type of imaging, they’re not time stamped. Okay. Uh, so SWI can’t tell you how long ago the blood was there and left an iron deposit.

DTI can’t tell you how long ago the axons were torn, but it’s part of the larger picture. And what you know at the end of the day is there was a person who woke up one way. When they woke up that morning, they were one way. Then let’s say we got a case right now, the storage door came down on their head and knocked them out.

And after the storage door came down on their head and knocked them out, they haven’t been the same. [00:24:00] Imaging shows the imaging is consistent with traumatic brain injury. Their friends and family talk about how different the person was before and after in the following different ways in terms of their mood, personality, behavior, and cognition.

What do we think the most likely cause of that is? Well, Occam’s Razor tells us the simplest answer is usually the right one. The defense wants to overlook the fact the garage door storage door came down on the guy’s head, but it did. And when it did, it knocked him out. And ever since his life’s been different.

And that’s the reason that we brought a case against the storage door company, right? Like, so yeah, so I’ll say all that to say that, that I’m a big fan of imaging. Uh, And if you get positive findings on imaging, show them, show them through illustrations, show them through animations. But I’ll also say all this with one caveat, be weary of anyone who’s trying to sell you DTI, be weary of anyone who’s trying to sell you any type of [00:25:00] imaging, PET scans, functional MRI, SWI, the imaging, And the results really are only as good as the technicians doing the work, the normative data set that it’s compared against and the radiologist or other expert who’s analyzing that data.

So just be careful and make sure. Not that the technology can pass Daubert, which it can, but that the expert that you’re choosing to use is sufficiently qualified. 

Elizabeth Larrick: Yeah, I know that there’s lots of people. When it first came out, I was like, Oh my gosh, we’ll use this people and use these people. And as happens with a lot of things that are like new and exciting for evidence and animations and that kind of stuff.

It’s so true. Like, you really want to, you want to pick somebody who, you know, knows what they’re doing and is not just going around to every lawyer convention and sponsoring everything possible. It’s just true because I think there are probably a lot of people listening who’ve been like, yeah, I did that and it turned out either I couldn’t use it or it just, it didn’t turn out to be what I needed, [00:26:00] what it needed to be.

Kenny Berger: For someone to say. Your client’s brain is abnormal on DTI, for instance, there has to be a normative data set to compare it to also, you want to be careful about what else may better explain those findings, right? Like you need to be careful on the age side that it’s not an aging brain, an atrophying brain.

That the person isn’t older and has small vessel disease, that they’re old enough, that the axons and the parts of the brain that DTI is really kind of looking at for normalcy or abnormality are properly developed. You know, it’s a great. Tool. It’s not the end all be all, but it’s a great piece of evidence kind of in the old, like we learned as kids show and tell if you can show the jury the injury, if you can show them the brain damage, right?

Like, a lot of times we’ll talk about. Look, what happened to them was a traumatic brain injury. What they’re left [00:27:00] with is brain damage. And now we’re going to show you the brain damage. So if you can show them the brain damage and show that the parts of the brain that were damaged are consistent with and medically correlate.

Great. With the changes in their life, which is something neurologist or someone else can explain, then you’re just, you’re further layering the evidence again and also utilizing those lay witnesses. So it becomes a situation where you’ve got a TBI to start with. You’ve got people who are talking about how different they are.

Now you’ve got imaging that shows why. They’re different. So you’ve got how they’re different. Now you’ve got the why they’re different and you’re able to show it to the jury, which I think kind of leaves you more to how much you’re going to get setting versus whether or not you’re going to get a result.

Elizabeth Larrick: So let me ask a question about timing because you said not every case. It needs to have like this kind of imaging, like, when are you, like, when are you thinking about this? And when are you making that decision? Because I know again, playing this person, [00:28:00] your lawyers were pretty cost conscious because we’re, we got it.

So when are you kind of making these decisions and when do you pull that trigger? 

Kenny Berger: That’s a great question. The classic, it depends, right? Typically in my experience, people who are going to get better, who are going to recover, do so within about 10 or 11 months. Okay. The rule that most people follow is 12 to 24 months from what I’ve seen over and over.

People are pretty much as good as they’re going to get it at 10 or 11 months. With that said, I’ve seen a lot of people make substantial improvements between 6 and 9 months. I’ve seen people who are. Messed up as a football bat after a month or two, and you’re thinking, my God, their life’s pretty much fricking ruined and it’s six and nine months, they’re 95 to 99, maybe 100 percent better.

Be careful. I typically wait until kind of that nine to 12 month mark, unless we’re pretty darn certain [00:29:00] the results are going to be positive. I’ll give you an example. Let’s say a client has positive findings on CT. Right. And, and they’ve got, uh, subdural hemorrhaging, or they’ve got subarachnoid hemorrhaging, but they’ve got, they’ve got blood on the brain.

Right. In those situations, depending on one’s kind of a better idea on coverage and some of the other moving parts of your case, uh, in a case like that, we’d probably send them a little sooner to show not only was there an initial finding of a brain bleed, because the defense can be like, well, they had a brain bleed, right?

Yeah. And it got better. Correct. Correct. And when they came back in and on this MRI, this caught MRI, the brain bleed had resolved. Correct. Correct. Yet they were still complaining of their symptoms. Isn’t that true? Yes. Despite the fact that the brain bleed was no longer evident on imaging. Correct. Because what they’re trying to do is say, because the blood [00:30:00] had been absorbed, the person’s no longer hurt, which is crazy medically.

But in those situations, again, if you’ve got good coverage, good viability, likeable client, compelling story. We’d send them out for more sensitive imaging, including DTI, to show what else was going on inside the brain that, again, is consistent with the initial skull fracture or brain bleed. Because then you can say, look, their skull got fractured, their brain bled, and they have permanent brain damage.

Now let’s look at the ways their life has been altered and what’s been taken because of the brain damage. And again, the brain damage all goes back to when the defendant chose to do X, Y, and Z. 

Elizabeth Larrick: Yeah. Yeah. That makes a lot of sense. And I know the other, the third option there is people just wait way too late in litigation.

And then it’s just, then it looks like it’s a little bit more manufactured. Like you fall into a different set of problems. Sometimes we wait too late. 

Kenny Berger: A big time. And with that said, if it hasn’t been done, you know, [00:31:00] cause sometimes we won’t get a case until a year and a half, two years into it. And in those situations, so long as there’s Enough medical evidence along the way or enough other people besides the client and their spouse to talk about what’s been different over the last 18 months or two years.

We won’t rule out doing the more sensitive imaging, but it does come with it. If the only thing we have is they treated for 2 months. Then they came to us and then the lawyer referred him to somebody and lo and behold, there was, you know, an alleged brain injury. That’s a tougher sell. I’d be more wary of that.

Elizabeth Larrick: Yeah. Yeah. Well, Kenny, you’ve been super generous with your time, but I know there’s a lot of people who are like just learning about it and obviously there’s lots of different, what is a good resource for them? Like what’s a good book? I know that there are lots of books out there on concussion and stuff, but what are some that you would recommend to people or.

Maybe they’re just learning or people [00:32:00] who like maybe want to get their knowledge just based a little bit further down the road. 

Kenny Berger: That’s a great question. Before I answer it, I just I want to I’m going to answer that. But before I do, a lot of people may be wondering, like, what about neuropsych? You know, what do we do about neuropsychology?

Which neuropsych do you like or not? Like, personally, I don’t like neuropsychology. I try to stay away from neuropsychology if I can. I don’t think it’s necessary. If you’ve got an initial injury, I You’ve got people from the human beings life. You can talk about how their life changed at the exact same moment in time.

Their brain was damaged. If you’ve got a neurologist who can clinically correlate those things, and especially if you’ve got, uh, imaging, traditional CT, traditional MRI, or some of this more sensitive imaging we talked about at that point, you get a neuropsychologist. So the defense gets a neuropsychologist.

And then there’s a day of testimony about the MPI to just like, [00:33:00] what, what are we doing here? That’s not a knock on neuropsychologists. That’s not a knock on the field of neuropsychology. It’s just in terms of case presentation and persuasion. I just, I don’t know that we need the Wisconsin card scoring test.

If you can point to an image and show where their brain is damaged. Uh, but if someone wants a good resource, I here’s what I’d say the best resource I’ve found. Is a traumatic brain injury litigation group? It’s the seminars that this group. I’m not talking about age. A is an entity, but specifically within this litigation group, you’re going to meet a lot of the what I think are just the best of the best.

Uh, you’re going to meet a lot of, I think, the best cutting edge doctors, lawyers, really being at the forefront of, of what’s going on with the literature with the medical and scientific advances with the techniques on, on being able to. Best present these cases [00:34:00] in a common sense way. So I’d say from a resource standpoint, the absolute best thing that someone could do is join a chase tbl litigation group and start coming to some seminars.

If there was a specific. It’s funny, I just mentioned how I don’t like neuropsych, but because it comes up so frequently, I think the neuropsychological guide to assessment or evaluation guide to assessment, 5th edition, a doctor who passed away in the last year or 2, Dr. Lezak, L E Z A K, was one of the co authors of that book.

It’s just the nurse like fifth edition that you got to have that because you’re going to deal with neuropsychologists, be it from the defense from cases. They’re referred to you in certain cases that we have. We use neuropsychologists. There are some great ones out there, but you just you got to know that stuff.

And here’s what I’d say about neuropsychology. If neuropsychology is being used to assess deficits. A deficit is the difference in how [00:35:00] someone was before and after the injury. You can’t know the difference between how someone was before and after the injury without getting an accurate baseline. So a lot of times I’ve seen plaintiff friendly neuropsychologists talk about, Oh, this person has these impairments these deficits.

Well, hey, they might’ve had those same fricking, uh, and low end skills and abilities before the injury. By the same token, I’ve seen plenty of. Defense folks basically try to claim that, that there is no difference, but they’re still average or high average. Well, fact is, before they may have been quote superior in, in some of these domains and there’d be massive deficits.

So you really got to know to, to an accurate standpoint or to really precise point what they were like before. If you’re going to be able to speak intelligibly and honestly about whether or not there’ve been any changes in their life. And I just don’t see a lot of neuropsychological exams that do that.

Elizabeth Larrick: Yeah, and we could spend a whole [00:36:00] episode just talking about psychs and it’s definitely, like you said, best way is just to kind of educate yourself, especially because you’re going to go up against one for sure with the opposing counsel hiring one, but we will put a link in the show notes to that particular title so that everybody can find it and a link to the AJ TBI litigation group.

Kenny, thank you so much for coming. I know that we’ve just barely touched the surface on TBI stuff, but I appreciate you just come and give us a little, a light touch, and I think what we focused on is probably the most important thing for people to walk away with, which is. Go to that scene, go to that exact place and find exactly what is happening in those moments right afterwards.

And that 48 hours afterwards, because that’s going to be the best place to find the evidence you need to, like you said, strike that match, right? To light that fire. Kenny, if people want to get ahold of you, if they have questions or thinking, you know what, I would love to have to come to my podcast or come to a CLE for my group, what’s the best way [00:37:00] for somebody to get in contact with you?

Kenny Berger: And just for reference, it’s Neuropsychological Assessment, 5th edition, again, LESAC. Best way to get in touch with me. The easiest way is probably just on my cell phone and that number. We’re in South Carolina, but we, like other folks, go all around. My cell phone number is (803) 360-6267, and then my email address, it’s on our website.

It’s Berger with an E-B-E-R-G-E-R law, SC as in South Carolina. And my email address is kberger at bergerlawsc. com. So folks can feel free to shoot me an email or like I said, call my cell 803 360 6267. 

Elizabeth Larrick: And I will put a plug in here since you didn’t talk about you have your own podcast. So if people just want to come and learn a little more with the same [00:38:00] your podcast.

Kenny Berger: Yeah. It’s a good one. It’s called best practices with Kenny Berger. Elizabeth was a recent guest. Other Texas folks. We’ve had Russell button, Chris Hamilton, who got that 7 billion with a B dollar verdict. His was excellent. Russ has been excellent. We had Amy with a right, come on and talk about kind of more from a business perspective.

I’m trying to think, I don’t want to miss anyone we’ve had from Texas. It seems to me like there may be one or two more, but. Again, we’ve had some great guests from TBR stuff to truck stuff, uh, openings, clothes, case selection, all in between. 

Elizabeth Larrick: Yep. Well, it’s a great podcast and I encourage everybody to go like, review it for Kenny and support the download that always helps more people find the podcast, which is what I’ll say as well for this podcast, but I will say another great way to connect with myself or with Kenny is on LinkedIn.

I know there’s always going to be some dialogue there. [00:39:00] Lawyers as well. So again, thank you so much, Kenny, for joining the podcast today and we’ll put all that good good stuff in the show notes so people would know how to find you and find that podcast. All right. Well, this is concludes our episode.

Thanks again, Kenny. Appreciate it. 

Kenny Berger: Thank you so much for having me. 

Elizabeth Larrick: All right. Well, if you like the podcast, please rate, review on your favorite podcast platform, follow on LinkedIn and until next time, thank you.

Are you ready to redefine your understanding of focus groups and mock trials? Let’s dive into the subtleties and key differences between the two, as we expose the secrets behind effective case preparation. With exclusive insights from expert attorneys, medical illustrators, and visual aids specialists, we’ll be enriching your knowledge and honing your skills. 

Don’t miss our intriguing foray into the world of legal jargon as we dissect the merits of focus groups over mock trials, shedding light on the importance of creating an open environment for participants. We further delve into the strategic use of background checks and surveys in your practice. Bring in your queries and join me on LinkedIn as we start this thrilling journey into the realms of trial preparation.

In this episode, you will hear:

• Focus groups vs. mock trials
• Early focus groups in lawsuits
• Dedicating time and resources for learning

Follow and Review:

We’d love for you to follow us if you haven’t yet. Click that purple ‘+’ in the top right corner of your Apple Podcasts app. We’d love it even more if you could drop a review or 5-star rating over on Apple Podcasts. Simply select “Ratings and Reviews” and “Write a Review” then a quick line with your favorite part of the episode. It only takes a second and it helps spread the word about the podcast.

Supporting Resources:

Let’s connect on LinkedIn, or send me an email: elizabeth@larricklawfirm.com 

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 I sent you.

Episode Transcript

Elizabeth Larrick: Hello and welcome to trial lawyer prep. I’m your host, Elizabeth Larrick, and thank you so much for joining us. I’m going to call this the official episode 100. Well, I know we did a replay. Last week, I want to make this the official 100 [00:01:00] episode and say, cheers. And congratulations.

Cheers to you for listening for pretty much two years now. Podcasting. Thank you so much. I couldn’t do this without you. And congratulations to me for putting it together. I know that here lately, it’s been a little hit and miss, and I appreciate everybody hanging in there with me. We’ve making some changes over on my work side of things, and that has translating now to some changes for the podcast.

And so what I want to talk about really quickly is some announcements. Before we get to our meat and taters of the episode changes would be, we’re going to move to a format of every other week. Now what we’re going to do though, is have just a little bit more meatier. episodes. Okay. What I want to do is start flavoring in some specific case study episodes.

Now, these may [00:02:00] be with the lawyers who are actually involved with the cases, or sometimes it’ll just be me talking about the case, you know, the outcome, but more specifically the preparations, right? And how maybe those things helped what was learned. Of course, if we can’t our lawyers on, we totally will.

To talk about that, kind of dive into that and really kind of get into the how to’s, you know, pulling this lever equal this, you know, pushing this way equal that to really kind of give y’all the audience very much a how to, right? That’s what this podcast is about, is really talking about the how to preparation for cases.

We’re going to continue to do interviews with lawyers, of course, and folks who help lawyers. So I know that I’m going to have medical illustrationist, Annie Gao, come back. We’re probably going to do a couple episodes on illustrations versus animations versus a couple of things that she has up her sleeve to help y’all.

I know that [00:03:00] we’re going to have other folks that help for visual aids beyond medical and probably some other people here and there just to help maybe with thinking about business wise or things that we can delegate people to help us with that. Also, of course, I’ll be here doing some solo episodes, you know, lessons learned and how to’s.

So, as always, I just want to talk about who this podcast is for, and it’s for folks, trial lawyers, people who are litigating cases, pretty much plaintiffs, lawyers, personal injury, employment lawyers, and also business litigation. Now that’s not to say I, family lawyers cannot also gather up a lot of this thing, a lot of these things that we’re talking about, but I do know having dabbled in family law is just a little bit different style of practice, if you will.

Of course, there are some people that this podcast may not be for, right? So this is for folks who are curious, who want to learn more, who want to see something, try new things. And so for folks who may [00:04:00] be down the road a little bit in their practice, who feel like they got a pretty good handle on things, not so sure, certain about trying new stuff, this may not be the podcast for you.

Of course, you’re welcome to hang out and listen, happy to have comments and feedback as well. My email will always be in the show notes for that, as well as I’m going to ask that we all start connecting on LinkedIn together. I’d love to hear more from the audience in this next year coming up. And so I will ask for that, that we connect on LinkedIn.

So with all those announcements down, let’s get to the meat and taters of this particular episode. So I do speaking quite a bit. And I always enjoy going to talk to a trial lawyers association. Got to talk to Montana this year and have brought some of those things that I talked about here on the podcast and probably bring some more along the way.

But recently I went down and spoke to the San Antonio trial lawyers association, which is great [00:05:00] organization full of wonderful folks. And we talked about. DIY virtual focus groups, a topic that I have talked about here on the podcast several times and you know, kind of can collaborate those episodes and put them in the show notes for you.

But what really kind of came from the conversation in this discussion with these lawyers was very much more about focus groups versus mock trials. Now, a lot of times when I talk about things, I’m talking about focus groups, but in lawyers minds they’re thinking mock trials. This kind of impasse or miscommunication happens often.

And that’s because my mentorship and my learning came through the avenue of focus groups. Not the adversarial style, the mock trials where [00:06:00] we’re getting, you know, basically a group of people and we’re having, you know, sometimes even having a judge there and having the opening statements, you know, showing some witnesses, having some closing statements, voting, you know, maybe having deliberation along the way.

That’s a mock trial to me versus a focus group. And. That’s why I want to talk a little bit about that today for people to know that there is a really huge difference here and what I advocate as you’ve heard if you’re listening here very often is for focus groups because and a lot of do it yourself focus groups, especially when it comes to virtual, but before we Jump there.

Let’s just stay really quickly with our focus group concept. People talk about doing focus groups along the way. If you’ve read, and I’ve mentioned on this podcast before, winning case preparation, understanding jury bias, they [00:07:00] talk about doing concept groups. That’s a word for them. I just sometimes call them, you know, neutral focus groups, but basically you’re taking a very small approach.

Either maybe it’s just an issue, a very digestible approach to getting feedback from potential jurors. And then that’s why I call them participants because I’m not going to ask them all to agree to one point of view. Rather, I’m going to go through and get each of their opinions and then dig a little deeper as to where that may be coming from.

Right. So it is very much a quantitative, right? Am I saying that right? No. Qualitative, right? It’s not about the numbers, right? Because there are people who do that too. And they do it very well, by the way, like great groups out there that do a very big number of people, good sample size and push everybody through and give you some great metrics.

That’s not what I do. I’m much more qualitative, right? So [00:08:00] we’re going to work with the group and really understand and get each of their opinions and go through that when it comes to these smaller issues. Right. So again, it becomes this very digestible format where we’re maybe spending an hour. Maybe sometimes it’s even 45 minutes on an issue or a neutral fact pattern or a visual aid or witness clips and just mulling through impressions and thoughts, assumptions like really just kind of diving in what their opinions and thoughts are without any advocacy, right?

Very much a neutral base. This can be difficult for trial lawyers because we advocate. However, with a very smaller digestible approach, with a neutral approach, you can do it or staff can do it. I know a lot of lawyers are incorporating staff, paralegals, legal assistants that can run focus groups for them because they Again, come from a unbiased place.

[00:09:00] They’re just there to ask the questions and get the feedback. And so it becomes a very different, I consider it a very big difference between a focus group and a mock trial. When people come to me and they want a focus group, I’m assuming you want a focus group that you don’t want a mock trial. And so we have that conversation.

But what I love about. focus groups for plaintiffs, personal injury attorney, for employment lawyers is a smaller, digestible, cost effective way to start talking to potential jurors, start understanding their attitudes and their backgrounds. Again, the, it’s a lower, Smaller time, you know, we can have smaller groups and of course, this is why I always push for virtual because that is an extremely cost saving convenient for you and for our focus group participants that they love way to get this feedback.

And if you do it [00:10:00] earlier, right, traditionally mock trials are left for the very last stages. Like you’re going to trial, no possible way of settlement or the possibility of settlement is so low that you want to make sure you’re ready. So then you’re doing a mock trial. You’re at the end stages versus a focus group because again, smaller in nature, different kind of style can be done virtually.

You can do it in person. You can do them more often and earlier. I always advocate, you know, six different spots, but I’m going to say for sure, no matter what two, Gots to do it spots. And the first one is before you file. Now, you may be thinking, well, I don’t have all the information and I don’t have this and I’m not sure what people are going to say.

You got a pretty good read on the situation before you file. If you have enough information to file a lawsuit, you got enough information to run a [00:11:00] focus group. And the cool thing about when you run it this early in their case, you get a lot of mileage out of that feedback. Because you’re going to, See it over and over again.

Also, you’re going to get a blink read, a blink reaction on Settle vs. Trial very, very early on, and that can really significantly help you shape and style your case expenses, your effort. Your energy in a case before things get too far. The other place that I say absolutely run a focus group is after you have key deposition of testimony from key witnesses and facts, fact witnesses.

So that would be our parties and a corporate rep. Going beyond that, like we probably don’t need it unless we’ve got like a super complicated so we need some managers in there or something like that because then you’re able to basically truly take clips and give. The focus group, [00:12:00] more information just through those clips.

You can always read them. This is what someone says. This is the testimony. You could even show, hey, here’s the black and white testimony on a screen. But actually having them watch even a five minute clip of somebody talking, they’ll gain so much more information. We, we know that just humans in general, we gather information from nonverbal, verbal, it’s more nonverbal, but that really will help you then see how things are lining up.

If you put all those key witnesses in a focus group, and then just. You know, ask them, what do you think, who’s, who’s right, who’s lying, you know, all that good stuff. Very general opening questions. You are really going to help significantly continue to shape your case and the themes and what works, what doesn’t work, find the holes that maybe still be missing.

So those are two really key spots. Now again, you can run these yourself. I encourage people to do that. I go to the website. There’s a download that I give away that [00:13:00] has. Information about how I do them for virtual confidentiality sheet questionnaire that I use because it’s just the return on the dedication of time and money in a focus group is exponential, like exponential, right?

So let’s say you, you spend 1200 bucks on a one hour focus group. And you learned three things. Those three things could be case saving information, right? They could save you 50, 000. They could add 100, 000, right? So that return on investment is fantastic. The only other place I think that we get A return on investment that is as good as a focus group is a background check.

That’s only because in my line of previous practice, I learned like as much as people try to [00:14:00] remember, we can’t remember everything. And it’s not that people are lying to us, but they may not have remembered that bankruptcy that they had 25 years ago, but you gotta know. So that’s what a background check helps you with.

Um, and is a great return on investment, by the way. If you’re not doing them, start doing them, you’ll be so glad that you did. So okay, back, back to this. So you may be thinking, well, but with a mock trial, I’ll already know like, no, you could learn a bunch of stuff in your mock trial that you can’t change at all.

Like you’re at the point of no return. That’s, that’s a problem. You may get a lot of graphs and a lot of charts and a lot of. emotional information. And that’s great. Totally great. I’m not discounting mock, mock trials are great. I love doing them for people, but I’m again, this episode is about their differences and that there is a big difference.

Sometimes you just want to hear them talk. You [00:15:00] just want to hear what they have to say. And when you have a deliberation where you just. You know, you get to actually watch them deliberate, make decisions. That’s great. But when you’re able to moderate and you’re able to give everyone a question and give them space and set the rules so that everybody gets to have their own opinion, one person can say it’s purple and the other person can say it’s green.

As a moderator, I mean, I get to follow up and ask how come right, but sometimes you can’t do that in a deliberation. And sometimes you can see people getting stifled and that doesn’t happen when you have moderate when you’re moderating in a focus group, right? You get to take time for each person and learn more about those opinions and create a very open environment for it, even if people are disagreeing and that’s kind of the hard part.

Sometime with deliberation. You, you can’t necessarily do [00:16:00] that. And then you kind of lose out on that person’s feedback and that point of view. And you, you want to get everybody’s point of view because you may have somebody like them that shows up on the jury panel. And that’s just good to know. You want to hear as much as you can or possibilities because once you get up for jury selection, you will have heard some of these things before.

There won’t be a shock factor, but also you’ll kind of know how to navigate it. And that’s again, just one of the other main differences between. mock trial versus focus group, you, you get so much more, and I’ve talked about this before, you know, what have I learned? Like you get really good at hearing bad stuff when you do focus groups, because people will just tell you, you know, they’ll dump all over it.

And that’s one of the fears that lawyers have. And I think one of the reasons why people are not running focus groups is because they’re going to hear bad stuff. And we get so invested. Trust me. I was there. You’re investing your time, your [00:17:00] energy, your money, your hopes that it’s hard to overcome that.

Lay it out there in front of a focus group to hear the bad stuff, like, been there, done that, tried to run more focus groups to get different outcomes. It, it was, you know, hearing it over and over again, does that necessarily, you know, then you come to a little bit like, okay, got to come to the truth that this thing needs to settle.

I do not need to try this case. Also, I’ve run way too many focus groups, which was another thing I told people in San Antonio. Like, Hey, trust me. If there’s somebody who’s run too many on a small case, that’s me. I’ve been there. I’ve done that. I don’t want you to do that. I know how to avoid doing that.

Okay. So if you have questions, call me about that or schedule a time on the calendar. All right. So that was, again, one of my major takeaways from talking to the San Antonio trial lawyer association was. There [00:18:00] is a difference here between focus groups and mock trials. There is. an expansive way that we can, as trial lawyers, start using this tool earlier in our cases.

We can set up our own system to do it, and we can start getting information to make better decisions in our cases. Learn if we need to settle it. Learn if we’re going to need to try it, right? Find the holes that are there, and do so at a level that makes more sense for our practice, right? Whatever your practice may look like, we all have to be cost conscious, right?

Especially when we’re taking on the risk as plaintiff’s lawyers. So let’s look at how we can better dedicate our time and resources, learn early with this tool so that we can use all that information and get as much mileage as we can out of it. All right, lots of mock trial versus focus group here today on this episode, and I hope that it was [00:19:00] helpful.

I hope that, like I always say, we’re just kind of opening the door just a little bit when it comes to, Oh, we’re not talking about mock trials and focus groups are not the same thing. They are not. They’re not the same thing. They’re different and they’re wonderfully different and they’re great in different ways.

So if you have questions, please don’t hesitate to email me. And like I said, please join me on LinkedIn, follow me, make a connection request and let’s connect on LinkedIn until next time. Thank you so much.

Imagine being able to improve your trial practice by utilizing DIY focus groups – well, that’s exactly what our guest, Clint Schumacher, has been doing. As an attorney specializing in eminent domain cases, Clint shares his fascinating journey of implementing focus groups to enhance his practice, and how Zoom has become an essential tool in facilitating them. We also take a deep dive into recruitment strategies, discussing the importance of finding the right participants and sharing the tips and tricks Clint has learned along the way.

When it comes to condemnation cases, people’s emotional reactions are often at the forefront. Clint and I discuss the complexities of these cases, the inherent bias against the government taking property, and how to gauge the emotional value of a particular property case in order to better communicate with the jury. We also explore the scaling question, which measures how much people care about the case, as well as the importance of communicating facts clearly in focus groups.

Setting up a virtual focus group may seem daunting, but we cover everything you need to know, from the geographic area to be sampled to the recruitment process and the electronic confidentiality form used. We also discuss the challenges of finding participants in rural areas and how Clint and his team have been successful in using Facebook ads and Google forms for recruitment. Finally, we touch on the challenges of virtual focus groups, the strategies needed to handle them, and the undeniable importance of focus groups for trial lawyers. Don’t miss this engaging and informative conversation!

In this episode, you will hear:

• DIY focus groups for trial lawyers
• Measuring emotional engagement in focus groups
• Virtual focus group process and challenges
• Managing remote meeting disruptions
• DIY focus groups for lawyers

Follow and Review:

We’d love for you to follow us if you haven’t yet. Click that purple ‘+’ in the top right corner of your Apple Podcasts app. We’d love it even more if you could drop a review or 5-star rating over on Apple Podcasts. Simply select “Ratings and Reviews” and “Write a Review” then a quick line with your favorite part of the episode. It only takes a second and it helps spread the word about the podcast.

 

Supporting Resources:

My interview on the Eminent Domain Podcast – https://www.eminentdomainpodcast.com/118-witness-preparation/

Clint Schumacher

DAWSON & SODD, PLLC

8333 Douglas Avenue #380

Dallas, Texas 75225

Email:  clint@dawsonsodd.com 

Phone:  214-373-8181

Fax:  214-217-4230

Licensed in Texas and Oklahoma

The Eminent Domain Podcast – http://www.eminentdomainpodcast.com/ 

 

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 I sent you.

Episode Transcript:

Elizabeth Larrick:

Hi there, Elizabeth here. I wanted to pop in before our episode begins to introduce our very wonderful guest, Clint Schumacher. Clint practices in the eminent domain area. Specifically, he helps individuals and companies who are having problems with [00:01:00] the government taking their property. So Clint has been doing this really specialized work for the past 20 years.

He has his own podcast. If you were interested called the eminent domain podcast, Clint reached out to me about focus groups. He started his own focus groups and had some questions and I was happy to help him. And then I said, Hey, why don’t you come on the podcast? So I hope you enjoy this interview with Clint.

Hello and welcome back to the podcast. My name is Elizabeth Larrick. I’m your host for Trial Lawyer Prep and this is a podcast dedicated to lawyers preparing for trial or preparing cases better to get better results. We generally like to talk about focus groups, and so I’ve brought a guest on here who has started his own DIY focus groups, which I know I encourage people to do.

If you’ve been tuning in here lately, the past couple episodes we have really been trying to talk about focus groups, setting them up. I heard from my recruiter, we had a replay about like when to do focus groups, six good times. So I hope this is helpful, but I really wanted to bring Clint [00:02:00] Schumacher on because he has started his own DIY focus groups.

And I thought it would be great to bring him on to talk about it and see how it’s helping his practice. Hello and welcome to the 

Clint Schumacher: Well, Elizabeth, thank you. Thanks for having me join. I have been a avid listener to your podcast. They’ve been extremely helpful to me. So hopefully I can pass something along to your audience that may be helpful to them.

Elizabeth Larrick: I appreciate that. Now, as you all probably heard in the intro, Clint has his own podcast. It deals with property, which was one of my worst classes in law school. So I can’t quite say that I can help with that at all. But I know that you are here to give some good advice and some sound feedback on doing your own focus groups.

But Let’s get started from the very jump. What even got you interested in doing focus groups? How does that mesh? 

Clint Schumacher: I do have a really specific practice niche. We represent property owners that are having their property taken by the government condemnation or imminent domain cases. And so early in my career, I had some excellent Mentors [00:03:00] who, when the case was right, encouraged using a jury consultant and have had a lot of experience working with jury consultants in the past and have done focus groups and mock trials with jury consultants.

But Elizabeth, as you and your audience know, that can be very expensive and not every case warrants that expenditure. And so I have seen the value of it, but have often shied away from it in all, but the largest cases. Because of the expense associated with it, then during the pandemic, you know, everybody’s life changed a little bit.

And as I started networking and listening to really personal injury lawyers who had very good practices, I listened to them talk about how they were doing their own focus groups. And. That you could do it a lot more economically and get tremendous feedback. And then as the country started figuring out how to use zoom and lawyers started to [00:04:00] incorporate using zoom in their focus groups or a similar tool, Microsoft teams, whatever, into their focus groups and the added.

Convenience the additional shaving off of cost. I was intrigued and I figured out this is really powerful. You get a lot out of it. And if I can figure out how to do it at a price point, that makes sense for cases that I might have and be able to do multiple of them, then wow, that could be really impactful to the.

Practice and really helpful to the clients. And so as we, and my team are starting to figure out how to do that, we’ve actually found your podcast and listen to some of the tips that you had for doing it yourself and they have been enormously helpful. I think we, and my team reached out to you even, and you’re very helpful to give us some specific tips and that’s been very helpful to us.

Elizabeth Larrick: Yeah, we reached out about recruiting and that’s probably one of the number one questions that I always get, which is like, how do you find these folks? Always happy to help. And I’m excited to hear that. I think a lot of people learning zoom in the pandemic [00:05:00] was already a challenge. That was already new for lawyers.

So then. Learning the second layer of doing focus groups online virtually is a whole nother one. So how do you feel like you’re doing? How do you feel like the team’s doing as far as putting on the focus groups? 

Clint Schumacher: So definitely a learning curve. As you said, I think recruiting is probably the most intimidating part of it.

Figuring out how do we find people that are qualified and helpful. We started. Really do and do it yourself, I would say a year ago, and we’ve gotten better as the year goes at figuring out, okay, what works, what doesn’t work, how can we get the right people in? And I think we’re obviously we’re still continuing to learn, but we’re really starting to hit our stride.

And we try to do at least one a month. I know there’s probably people that do more, but one a month seems about right for us. And we’re starting to get it figured out. It’s not as hard as it may seem. 

Elizabeth Larrick: It can be a little scary. I can remember my first one. We had three people 

Clint Schumacher: understand. 

Elizabeth Larrick: But we did a short one.

We just did two hours, I want to say. [00:06:00] And it was like, okay, that felt a little painful because you got to get through. It’s not just, okay, get them in there. Like it’s navigating the technology and keeping people engaged and keeping the flow of conversation going as well. So you’re setting up a system, but also you’ve got to learn moderating and putting stuff together too.

So how is, as far as. Do you normally do the moderating or do somebody else in your office do it? Or how do you guys split up that work? 

Clint Schumacher: So when I was coming up watching jury consultants do it, the jury consultant would do it. So that was the model that I was used to when I first started trying to do it self focus groups, I was doing it in tandem with another lawyer here in town.

I practice in Dallas, and there was another lawyer I was having this conversation with. He’s, yeah, we’ve been doing these for a while. I would love to moderate yours. You can come participate in mine. And so he moderated ours. For a bit, we’ve tried it with kind of another, there’s another, I would say, jury consultant that works remotely that we’ve had moderate one [00:07:00] recently, but I’ve gotten to the point where I feel like it’s best if I moderate them because I know what questions I want to ask.

And I can hear what the. Focus group is saying and direct questions into things that I know are going to tie into the case. The obvious downside to doing that is remaining neutral. And I don’t always do that perfectly, but I’ve gotten to where I’m most comfortable just moderating them myself. And I know that I can get it.

If something comes up in the focus group, that’s unexpected. I can adjust a lot more easily than if there’s another moderator that’s involved. 

Elizabeth Larrick: Yeah, I would say when I was talking to another friend of mine about focus groups and one of the gems of doing focus groups consistently and. Even if you are just listening, right?

Being moderating helps, but you get into a really good habit of taking bad news. Because you’re inevitably going to get, like, you, and you get to where that fight, that, that real, that fight, that defensiveness [00:08:00] that comes up, that urge to convince, it just goes down and goes to a point where you can listen, stay curious, stay curious.

And not get completely, Oh, I want to, I want to convince this person, but yeah, you get used to hearing bad stuff every time. And I’ll 

Clint Schumacher: tell you the last time I did a Vordire and forgive me for all your non Texas residents, but Vordire is how we say it here. So forgive me if I am not sounding, that doesn’t sound correct.

I noticed that I was a lot less, I’m going to say inflamed. I’m not sure if that’s the right word, but when that juror is giving you something that you know is not going to be good for your case, I think we probably all feel our temperature start to rise and the anxiety start to rise. And I noticed the last four dire I did, I was a lot Better at keeping that feeling at bay.

And I think it was because I had moderated some groups before then. And as you say, you get used to hearing the bad news. You’re not taking it personally. And you learn, gosh, when you’re doing the board, are you that that’s gold? If somebody is [00:09:00] going to tell you they don’t like your case, that’s gold. And not being able to get overly passionate and to remain dispassionate, to be able to hear with them, deal with that, figure out who else feels the same way, that was a big help.

Elizabeth Larrick: Absolutely. It’s a very good skill to learn because in litigation, you’re always going to hear the bad news from the other side and sometimes it can be legit, but you’re such an advocate. So I always think focus groups help you prepare for hearing bad news, being able to listen to it. Stay curious. You don’t have to take it like you said, don’t take it personally.

But then when jury selection comes, it’s like, Oh, cool. I’ve heard this before. Oh, cool. Another one of those people. Cool. Weird. Tell me a little more about that. Like you said, 

Clint Schumacher: do you, do you moderate your own groups? 

Elizabeth Larrick: Oh yeah. Oh definitely. 

Clint Schumacher: Okay. 

Elizabeth Larrick: Yeah, and I, of course, it’s been several years and I do several months, but yeah, so it just got to where it was just like, oh, okay, okay.

You know, like I hear bad stuff all the time, and what I always strived for when I started [00:10:00] was just staying curious and also. You got to nail down that poker face. You’ve got to nail down that. Okay. 

Clint Schumacher: Oh 

Elizabeth Larrick: yeah. Okay. And then you just kind of like, okay. You know what I mean? And it’s, you start to, okay. And you can always tell somebody who, and again.

I’m just saying, throwing this out there. If you’re having this issue, just so you know, this is kind of where it’s coming from is I’ll have people who come in and I’ll set a focus group and people will come use my space or we’ll do the virtual focus group and the followup that always gives the little cringes, what if you heard, and you’re like, Oh, like your bias immediately comes out.

So it’s just a skill to learn. And I think it really makes you. Such a more well rounded lawyer just in practice and just probably in life to hear like, Of course people are gonna disagree with you and do you really need to try and convince them of your But tell me a little bit about, let’s get back to yours.

So how, tell me about [00:11:00] how has focus groups or how have focus groups helped your practice? in particular. 

Clint Schumacher: So probably not anything that’s earth shattering. But gosh, what I’m going to say is not earth shattering. The information we get sometimes is, but it helps me see things that I’m blind to. Right. So I inevitably almost every time they ask questions or think about things that I had not ever focused on or thought were important.

And so that’s always a big takeaway to hear their feedback on that subject. But then a lot of times, if there’s a key. Issue in the case or two or three key issues in the case to get their feedback, not only on how they feel about that, which is obviously important, but if someone were to present evidence about that at trial, who would you expect to talk about it?

In other words, Is this going to be a fact, is this going to come out of a fact witness or is this going to come out of an expert witness? And what is their expectation about that in what we do, which is very heavily expert [00:12:00] driven, that’s been a really helpful thing to hear that, Hey, that’s something that really our client or whoever the fact witnesses needs to cover as opposed to having our expert evaluation person talk about that.

So that’s been a big piece of it too. 

Elizabeth Larrick: I would assume, and again, this is my assumption because I don’t know any, that a lot of what you’re trying to understand is what do people even know about condemnation and what are their kind of attitudes about it, and have you found any kind of universal assumptions people are making?

Clint Schumacher: Absolutely. So there is generally a bias against the government taking property, and There are a fair number of people in the population that don’t think that’s even allowed or permitted. So they’re surprised to find out that can even happen. But then inevitably, one of the things that we always try to gauge in our focus group is how passionately do they feel about it in this particular circumstance.

And so if you’re taking property from a family and that land has been in the family for four [00:13:00] generations, you can imagine people. They have a sense of emotion that’s tied to that, and it’s very different from, say, a commercial piece of property that someone has owned for 10 years and their business is on it, or they rent it out to someone else.

Those can elicit different sets of feelings, and so one of the things that we or I say, should say I, I kind of subscribe to the reptile theory even in our property cases, and inevitably if we can communicate with the jury at an emotional level. That’s going to help us and one of the things I’ve got to gauge in every case is how emotionally connected does this group feel to this set of facts in this particular piece of property.

And so that’s always helpful to us to see, do we have a case that really drives that or is this one that they’re like, eh, it’s not a big deal. Are 

Elizabeth Larrick: you scaling that or are you? Doing a word association with that, give us a little bit more. And I’m happy to share how I gauge emotional, the emotional value or the emotional engagement, if you will, with folks [00:14:00] group, 

Clint Schumacher: actually, I really want to hear your feedback about that.

Cause I don’t know that I have a good system to do that. It’s really, I feel right now it’s just my field, like how involved are they? So how much feedback are they giving me? And we normally will do a two hour focus group and we’ll have two different cases. And you can tell they’re a lot more emotionally connected to one than to another.

But I don’t know that it’s systemized. And so if there’s a way to do that, I am all ears. 

Elizabeth Larrick: Yeah. I did not create this by the way, to totally did not create this. It’s just a scaling question on a scale of one to 10. How much do you care about what happened here? 

Clint Schumacher: Oh, that’s a good idea. Yeah, that’s a good idea.

Elizabeth Larrick: And you can always follow up with people. I love doing it online or doing it virtually with zoom and having a chat, having them chat it to you, and then just saying. Hey, Ralph, you put nine. What does that nine mean to you? And there, here comes a little more gold coming in there. Now it also helps you really decipher.

Occasionally some people will say, just what happened, this person was just so sympathetic. [00:15:00] Yeah, that’s not always going to push the boulder, right? We need to, we really wanted them to be impassioned about what the government is taking from people, what the defendant’s action was. So it’s helpful, but yeah.

And I do you care your Carol meter on a scale of one to 10 generally helps. Decipher and you can just do a follow up. What does that nine mean to you? What does the two mean to you? But like you said, a lot of times people will just have heated, very heated reactions, or you can always check the words people are using as well.

Clint Schumacher: So where, that’s a really good idea. Where in your focus group do you do that? 

Elizabeth Larrick: At the end. 

Clint Schumacher: At the end, okay. Mm-Hmm? . 

Elizabeth Larrick: It’s generally the last question I ask. 

Clint Schumacher: Okay. That’s a great idea. 

Elizabeth Larrick: After they have everything, right? You’ve got nothing else to give them or no other questions. And how much do you care what, what happened here?

And you can tweak it. I don’t, this was given to me when I learned focus groups and I’m sometimes of the, I may not make something better. Okay. This may be good. Okay. You don’t have to add [00:16:00] to it. I always tell people like, you don’t need to create everything on our own. Yeah. You need to create a focus group system that works for your office.

But there are some questions people want to, you know, why would I put my own twist on this? I’m like, why? Another thing that we get from doing so many focus groups is how to clearly communicate. Because the way that we communicate things can get so confusing to them. And so it’s really, focus groups help you, you give it to them and they’ll give it back to you in a much clearer way.

Generally, every time versus what the way you’re describing a fact pattern or how something happened. So, yeah. 

Clint Schumacher: How much time do you say for that last question? How much time do you need to, 

Elizabeth Larrick: Sometimes we’re running out of time. That’s why I love it’s a scaling question. Just throw it out there. Blink reaction, put it in the chat for me.

Or if we’re live in person, I just go around. I say, I’m going to ask every person individually and then just go around the room and popcorn it. And if we have time, somebody is a one. And do I really need to follow up with the one? I’ll follow up with an eight or a seven or a nine. [00:17:00] Something that I really want to figure out.

Why was it a nine for that person? 

Clint Schumacher: Interesting. Okay. See, I’m learning stuff. This is good. 

Elizabeth Larrick: Some people are super passionate about their case. Most people are, right? You’re building it. You’re creating it. You believe these people. Your heart and soul is in what we do. Most of the time, I say most of the time, sometimes it’s not, and you want to help everybody else is just as passionate about it as you are, and sometimes they’re not.

And you kind of want to know that before you start, like you said, getting those experts in there and pushing more money into that case, expensive column that people care about what’s happening here. 

Clint Schumacher: Absolutely. Yeah, absolutely. 

Elizabeth Larrick: Okay, so let’s get down to the nitty gritty here because I know there’s a lot of folks who listen who haven’t tried virtual focus groups.

And so let’s talk a little bit about your system. Kind of. Pieces of it, how you guys like to do it and set it up. 

Clint Schumacher: Sure. I think you, you had a recent episode where you have a remote person that helps you. [00:18:00] And I would start there. My paralegal does it because she’s got the capacity to do it and she enjoys it.

But having somebody to help do all that backend work, I think is absolutely critical, unless you just are blessed with. More time than I have, and you know, we’ve kind of decided in our practices all over the state, and so we’ve got to be able to make it work in different jurisdictions. And sometimes because of the nature of our work, we might be in a very rural jurisdiction.

And so we’ve got to decide, can we sample inside that county without? Running the risk of ruining a potential jury pool. And so we start with figuring out, okay, where are we going to draw people from? What’s the geographic area that we need to draw from? Can we sample inside the County or do we need to hit surrounding counties?

And if it’s surrounding counties, can we match the demographics of the County that we’re in? So we go through that process and then she really starts recruiting. And our process right now has principally been in Facebook ads. We do a little bit of. Craigslist, but probably we’ve had the most success doing Facebook ads.

And I think we’re [00:19:00] continually trying to get better at doing that. I don’t think we’re far as long as you are with regard to your Facebook page for your jury consulting business. And that’s probably something ultimately we would. Like to get to just because it’s a, it seems to me to have the effect of having a common anchoring point that you can bring people in, but we’re mostly using Facebook ads.

And then she has a Google form that we can use pretty much for every case that helps populate the information from the various consultants or various participants. And as you have pointed out multiple times, one of the challenges is to make sure you’re really getting somebody from the jurisdiction that you want to pull them from.

And we have figured out a few helpful questions to let people that maybe are not in the right jurisdiction. So that we don’t have them included on the panel. And so that’s, that’s largely the process that we’re using. Although, as I say, we’re continuing to tweak it and hopefully continue to get better at drawing people in.

And the other thing that we don’t have, you’ve got a great advantage, I think, just because you’ve been doing it longer and you’ve got [00:20:00] more participants. And so we’re still at the point where we’re. At the genesis of not having a huge group of people that we’ve worked with in the past, we don’t have a lot of repeat participants yet, but obviously my hope is, as we do this more, we’ll have people that we can go back to and use every twice a year, three times a year is probably not too much.

So we’re still working on that. 

Elizabeth Larrick: Yeah. Yeah. So do you guys do an electronic confidentiality form? 

Clint Schumacher: Yes. Yeah. So, yes. So she’s got an Adobe form that people can assign that we use. And as I think you’ve suggested, I think we’ve do it just exactly like you guys were talking about on the show the other day, your kind of entry into the zoom is you sending that form back the morning of you send the form back, we send you the zoom link and then we’re good to go.

Elizabeth Larrick: Yeah. Yep. Yep. It’s all building in the hurdles. I always feel like it helps your people are going to be there. Cause that’s always my fears. Two people are going to show up to talk to me. It’s a long [00:21:00] conversation. 

Clint Schumacher: And I think my guess is that anybody that does this has probably had that situation. And I think we had a panel or we had a focus group is in the last couple that we’ve done, where we had three people, we were having trouble drawing, we’re in a small county, we’re having trouble drawing.

She told me at the outset, she’s like, I got five people. Two of them are really, I’m not sure they’re going to show. And so we had three and you know what, Elizabeth, even with those three that I got a lot out of that, cause we got to get really deep with what those three people thought. And so it probably wasn’t as statistically valid, but.

Because we had that small number, I got feedback at a deeper level. And so I really got a lot out of that, even though we didn’t have very many people. So it’s not, it wasn’t the end of the world. Yeah. 

Elizabeth Larrick: It’s, and it’s not. And I think that if you end up with three folks who want to talk to you, you’re good.

If you end up with three that. We’re the folks that don’t talk very much. It’s 

Clint Schumacher: brutal. [00:22:00] No, you’re correct. These were three talkie folks. So that helped a lot. 

Elizabeth Larrick: Yeah. And it’s, have you had the situation where you’ve had to let someone go yet out of a group? 

Clint Schumacher: Yes. Yeah. Yeah. So that was a learning moment. So yeah, the person who won’t turn their video on or the person who gets in and you figure out they don’t know how to speak English and we needed to, we had to put something or some.

Guardrails in place that helped us tell them, Hey, here’s our expectation. We expect you to have your video on. If you don’t, we’re going to boot you off. We’re not going to pay you. So yeah, that was, yeah, we learned the hard way on that. 

Elizabeth Larrick: We expect you to, we’re doing a zoom focus group. You’re we’re going to need to see you, but some people just, they don’t, you got to just line it out there every chance you get, and then we’ve just gotten to where it’s like, and that’s the other thing too, I think.

If you don’t have that talking to everybody out there listening, you have to have a way to say it to where you’re being polite and [00:23:00] it’s okay, but you’re kicking them out. Yeah. You don’t want to disturb anybody else. You don’t want to become like the taskmaster because then people won’t want to share who are left.

They’d be like, wait a second. I don’t, I don’t, that wasn’t nice. But I’ve had it one time where this person was just. I mean, off the wall answers, they’re making people uncomfortable. And so I just had to like, politely kick them out of the meeting, and just paid them for their time, but, and then just moved on.

But yeah, it’s a challenge sometimes. 

Clint Schumacher: So my paralegal will sit in on these and she’ll handle, not the person who’s rude and out of sorts, right? That, that one’s probably on me, but if you’ve got somebody whose camera’s not on or whatever, she handles that. Is that how you do that or how do you approach that?

Elizabeth Larrick: Yeah. So she’ll start the meeting or we’ll both be there. We both start the meeting and then we have kind of a 30 minute check in period where we got check the IDs and then we check the technology. And the goal is to get all of that done in that. 30 minutes [00:24:00] before. And so if she’s struggling with somebody and because I’m generally there at work, like technology wise, and we just can’t get it to work, then I’ll come on and say, Hey, I can see it’s not working.

Can we just reschedule you? I apologize. We got to have you. And we have all the backup, right? We need to see you. So blah, blah, blah, whatever may be. And then generally people are like, okay, I’m sorry. I’m like, Hey, no big deal. But I generally come in as the second, like reinforcer of that. So that it’s. Like people understand it, but yeah, we had, we, and then, and the fun thing is what this is when you know, you’re going to have a good focus group.

It’s like somebody gets on and like, they’re having a glitch. Let’s say it’s their video. Or we had this poor person who had flipped his video. So he was upside down and we were, I couldn’t keep a straight face because he was upside down and I’m just like, Oh my gosh. And another participant like put in the chat, like, Hey, here’s how you fix that.

And I was like, okay, we’re going to have a good focus group. People are trying to help each other out. So we did get a fix, but it was like. [00:25:00] Everybody wants to help and figure it out. So it’s, we’ve definitely had hurdles. She generally tries to go first go around, but I’ll come in second and see. And if there’s something specific, for example, we have to ask people, hey, we can’t really see you, can you turn a light on?

Or, looks like that you’re on a cell phone, do you have any other device? You’re not gonna be able to see the presentation. It’s gonna be too small. Oh gosh, we’re gonna have to get you rescheduled. It’s really important to see what we have to show you. If they can’t get it worked out, then, then we’re just gonna reschedule.

Clint Schumacher: That makes sense. Yeah, that’s good advice. 

Elizabeth Larrick: Yeah. And we just, we’ve just gotten to where, I think I’ve just about run into, I know, Knock on some wood here. I’m sure there’s probably something else that’s going to come out there and impress me, but I’ve had people do some very interesting things with the camera on.

I’m just like, Oh, baby, turn your camera off for that. But 

Clint Schumacher: yeah, I can’t say that we’ve had that. So, yeah. 

Elizabeth Larrick: Yeah. Just [00:26:00] get, just in case, 

Clint Schumacher: just get ready. Okay. 

Elizabeth Larrick: That’s right. That’s right. All right. So what advice would you give some folks out there who are thinking about it? They’re on the cusp. Most people, we know it’s important, but we know it’s this expensive thing.

So we can’t necessarily hire someone to do our focus groups. So what would you, what advice would you give folks are on the fence about getting started doing their own focus groups? 

Clint Schumacher: That’s a great question. I think, and you prefaced a part of this, but I think it’s the place you have to start, which is, I have never left a focus group, including the ones we’ve done ourselves, and go, that time was not extremely well used.

And because we always learn something about our case, it’s some of the best, it’s some of the most valuable time I spend on a case. And it’s hard to put. A price tag on that place that takes your case from a C case to a B plus case, it’s hard [00:27:00] to figure out what that is worth. And it’s worth a tremendous amount.

And so the amount that we spend, I know, is coming back to us and more importantly, our clients many times over. And so I think you start with, if you have something that’s that helpful to your case, okay, now you just got to figure, now you got to find a way, right? How can I figure out? How to do this. And that was finally the point that pushed us over the top, which is I knew it was important.

I knew it could be valuable, but it just seemed too big a hurdle to get over. And once you thought, okay, there’s from a time standpoint, I can figure out how to make this make sense and be efficient. And from a money standpoint, I can absolutely figure out how to make this work and be efficient and then just get in there and not be afraid.

To screw it up and just know, Hey, these first couple are probably going to be screwed up and that’s fine. And just the sense of learning and continuing to get better. That’s ultimately where we got to and where we’re going to. And like I say, it’s, uh, it’s not as hard. It’s like most things in life, probably.

It’s not [00:28:00] as hard as it seems is that first step’s the hardest one. And once you take the first step and you go, okay, I’m going, I’m going to do this. Now I just got to figure it out. There are resources out there. Yours being very helpful to me that have helped us get down that path. 

Elizabeth Larrick: Yeah, so not telling us your numbers, how are we talking about with our value proposition here, right?

Our return on investment here, we talk about five times, sometimes 10 times, like how would you equate that one hour focus group that expense you may have to the case as far as value and return of investment? 

Clint Schumacher: Yeah, so we try, I’m not sure I can answer that question specifically. So I’ll give you, I’ll give you a, I’ll give you a story.

So we tried a case in February. And it was one of the first cases we had focus grouped ourselves. We did a zoom focus group and then two weeks before trial we did an in person focus group. And we did both of those were do it yourself. We found the people did the whole vineyards. And my, the jury came back and gave us [00:29:00] 880, 000, I’m sorry, jury came back and gave us 680, 000, which with pre judgment interest turned into like 880, 000.

I really think that There are probably 3 key things that we learned in the course of those 2 focus groups that took that case from a 350, 000 jury verdict to a 660, 000 jury verdict. And so, I don’t know, maybe we spent 5, 000 doing those 2 groups, probably not even that much, but let’s be honest.

conservative. And you know, whatever that math is, that’s what I think happened on that particular case. Maybe not all the cases have that same effect, but I think I would guess we’re seeing 10 to 15 to 20 to 25 times return on what we’re putting in to the focus groups on our cases. 

Elizabeth Larrick: That’s awesome. That’s what you want.

And I think You nailed it with your example, which is, and that’s what I hear all the time from people, even if they just run one focus group, they’re like, we heard this one thing that turned [00:30:00] Our case into a million dollar case, right? And it was this one thing. We didn’t even know about good friend of mine example.

They had a propane gas leak in a house and they never even thought about clearing the air that no one was a smoker in the house. And it’s the 1st in the folks group said, and they said, oh, my gosh, thank goodness. We never would even said a word about that. And the jury would have gone back and assume just that 1 like you said, those 3 nuggets.

Doubled the case back. 

Clint Schumacher: Yeah. And in this case, there was one fact that scared us that we thought was potentially the outcome determinative facts. It was a bad fact for us. And in both of those focus groups, not a single person cared about it. Could not care less, which completely stunned us. But that helped us then figure out how to try the case and we realized we don’t have to be afraid of this fact.

We don’t have to make a big deal of this fact. We need to explain it and then the jury is good with it. And the ultimate jury felt the same way. 

Elizabeth Larrick: Yeah, that’s awesome. And I think again, having some [00:31:00] confidence to know I don’t have to spend so much time on this. It was my worry only, not their worry. Awesome.

I, Clint, I really appreciate it. Is there anything else, any other resources you would suggest for folks who are listening, who are thinking about doing focus groups, any other resources that you would suggest that focus. Lawyers go check out. 

Clint Schumacher: Yeah, sure. The other place that we’ve learned a lot is a lawyer in Las Vegas named Sean Claggett.

Sean does DIY focus groups too. They do, I think he does one every Friday in his office and he’s got a lot that he’s written about and has put out there for public consumption about how they do it and what they do, and that’s been very helpful to us as well. 

Elizabeth Larrick: Sean reptile and edger as well. Yeah. I think they have a whole company as well.

They do. They have a pretty, they have a pretty cool space too. I’ve gotten to go to that space before. 

Clint Schumacher: Oh, I haven’t seen that. You’re a step ahead of me. 

Elizabeth Larrick: Yeah. This is well before the pandemic, so many moons ago for sure. Awesome. I think no matter where you get the information, please just start looking. I think that’s step number one is take a look [00:32:00] around.

It’s not nearly as complicated. And I think the beauty of it is so many people are used to zoom. It’s not a foreign concept for participants who are out there trying to find some extra money, gas money or whatever, maybe. 

Clint Schumacher: Absolutely. 

Elizabeth Larrick: Clint, thank you so much for joining the podcast. I hope that you enjoyed your time here with us.

Clint Schumacher: Elizabeth, I did. It was a great pleasure to get to visit with you. And like I say, we owe you a tremendous debt of gratitude for what you put out there publicly and then what you’ve helped us with when we’ve emailed you here over the last several months. And so thank you very much. And I hope I was able to return that favor just slightly by sharing something with your audience.

Elizabeth Larrick: Absolutely. It was a pleasure to have you. And I hope that everybody else enjoyed Clint. We’re going to put his. Contact information, the show notes. If you have questions for him about his DIY focus group system, or if you have an imminent domain case, am I saying that right? Condemnation case. 

Clint Schumacher: You got it.

Elizabeth Larrick: Definitely puts all that information there for you to contact Flint for anything. Thank [00:33:00] you all so much for listening. If you enjoyed the podcast, please like and review it on your favorite podcast platform. So other folks can find this as well. Until next time. Thank you.

Elevate your understanding of deposition preparation with a unique focus on Spanish-speaking clients in our latest episode. We promise you’ll gain valuable insights on the role of translators in this process, offering your clients a deeper layer of comfort and preparation. With firsthand experience from the field, we share how employing a translator for role play during deposition prep can drastically improve your client’s understanding and readiness, setting them up for success.

Venture further into the world of legal translation as we highlight the importance of hiring certified court translators. We unpick the ethical code they adhere to, nuances of regional dialects, and the potential risks of miscommunication. We also address the significant challenge of translation delays and suggest ways to keep this process as concise as possible. By the end of this episode, you’ll be equipped with a new perspective and practical strategies to effectively utilize translators in your deposition prep process, ensuring no stone is left unturned.

In this episode, you will hear:

• How a translator can help Spanish-speaking clients prepare for deposition
• The importance of hiring certified court translators
• Ensuring confidentiality and comfort of clients
• Understanding the importance of brevity to avoid delays

Follow and Review:

We’d love for you to follow us if you haven’t yet. Click that purple ‘+’ in the top right corner of your Apple Podcasts app. We’d love it even more if you could drop a review or 5-star rating over on Apple Podcasts. Simply select “Ratings and Reviews” and “Write a Review” then a quick line with your favorite part of the episode. It only takes a second and it helps spread the word about the podcast.

Supporting Resources:

If you have questions or a particularly challenging client preparation, email Elizabeth directly for assistance: elizabeth@larricklawfirm.com.

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 I sent you.

Episode Transcript:

Elizabeth Larrick: [00:00:00] Welcome to Trial Lawyer Prep. What if you could hang out with trial lawyers and jury consultants, ask them about connecting with clients and juries more effectively, then take strategies, tactics, and insights to increase your success? Each week, Elizabeth Larrick takes an in depth look at how to regain touch with the everyday world, understand the emotional burden of your clients and juries, and use focus groups in this process.

Elizabeth is an experienced trial lawyer, consultant, and founder of Larrick Law Firm in Austin, Texas. Her goal is to help you connect with juries and clients in order to improve your abilities in the courtroom. Now, here’s Elizabeth. Hello and welcome back to the podcast, trial lawyer prep. I’m your host, Elizabeth Larrick, and I’m glad you’re here.

This is episode 99 and I’m celebrating already before a hundred because it has been a journey and I’m so glad that you have been here with me. If you’re new to the [00:01:00] podcast, welcome. This is a podcast dedicated to lawyers preparing cases better, getting ready for trial. We talk about Preparing clients. We talk about preparing for trial focus groups and a few little tidbits along the way.

I like to have guests and join us and next episode, which is a hundred. I’m going to do something totally different, but I want to talk a little bit about how we’re going to do the podcast going forward. And I’m going to change a few things up, test some things out and you guys can let me know whether you like it or not.

But my hope is that to give. More context to what we’re talking about. So today’s episode, we’re going to talk about deposition preparation specifically for clients who do not have English as their first language and using a translator in preparation. So this episode is for folks who have clients who don’t have English as their first language.

And in my experience, most of the folks that I have or have [00:02:00] worked with are Spanish to English. Translation, but this is not limited to that. I mean, I think what we’re going to talk about as far as the problem and the translator helping with this goes to any translator, any kind of language that we are working with, mainly because there are so many different variations of Spanish and best example I can give you is, of course, I know book Spanish, but when I go to speak with somebody who is a native speaker from Mexico, like we’re kind of lost.

Now, let me just. I don’t speak it. I can, I can understand what they’re saying enough to know that we are lost in translation. So what I want to dig into today is how to take your preparation for these particular clients to a whole nother level and to really gear them up for using a translator in the deposition.[00:03:00] 

So I always suggest to use a translator. Or hire a translator, somebody not in your office to come in and help during deposition preparation. And particularly if you’re going to, when you do the role play session, definitely get that translator in there to help in that session, because there’s so much that has to be learned extra on our clients in this situation, because they’re having to be very patient for our translator.

They’re having to be very patient, listening and waiting for their turn. You know, if there’s objections and understanding all those things, which is normal for a client, but then knowing they have to kind of wait for the translator and most people, most clients that I have dealt with know enough English to know what’s happening and going on.

They’re just much more comfortable. They want to testify in Spanish because that’s what they understand very well. So, I’m working with some folks right now, and we’re using a translator during preparation, not just during the role play. [00:04:00] And it has been such an eye opening experience because of the vast difference between the translator’s version.

of Spanish to English and then his version. And it’s not that either one is wrong, but it has been such a education for me in the words that we may say in a question and how they get translated and then given over. And then there’s this huge block and it’s a car wreck case. And so we’re talking about, you know, navigating the road and passing cars and getting around cars and Of course, there’s a thousand ways to say it in English, but there’s only so many verbs in Spanish.

And so that’s why, like, we just kind of got lost in translation. So it’s been so helpful for him to kind of understand, oh, like this. It’s the word that I use here is, is so important. And they were also, you know, kind of lost with this [00:05:00] translation of easy versus better. And so he kept saying easy when he was intending to say better and she was just translating it that way again, you know, nothing wrong with the way she was translating it, but that’s just the way, you know, from the book Spanish, that’s what it says.

So, I know that when we use translators in deposition prep, it gives them a whole nother layer of what to expect and how to teach themselves to be patient, to wait. But also, what I tell them is like, this is really. This is helpful because you are going to have a lot more space to understand no, you’re going to have to work with the translator, somebody you have no idea with, but that also sometimes when we have this.

Translation chain, a lot of the times translators don’t translate tone. Some do. I don’t know if you’ve ever had that experience where you’re sitting in a deposition and [00:06:00] opposing counsels asking your client question and the translator is actually translating the tone, which doesn’t need to be done because we all understand tone.

We don’t really, as kids, we know what a bad tone is, a good tone is, so we don’t really need the translator to, to do the tone, but you know, hopefully. You get the impression, the tone of the question and it’s translated and hopefully that gets a little bit minimized right by the time they get the question to them.

But it’s been so helpful to have a translator as somebody outside of your office because there’s always a comfort level with speaking with somebody in your office or even speaking with you. If you, if you speak in Spanish or another language with your clients, they’re, they’re Is a whole other layer of preparation that you can give them by bringing in a stranger and having them go through that experience.

And this is another reason why we always say, bring in a different lawyer or bring in a new face to do that role play no matter [00:07:00] what, because they need that experience of a complete stranger asking them questions, you know, hammering them on the details and giving them the answers. You know, what happens in a deposition, a real life experience, and it bringing in a translator significantly helps because they’re going to realize, Oh, wow, I’m not only do I have to answer this question, but I’ve got this other person who’s translating who may get it wrong.

And I need to work really hard to make sure I understand that question the way that they’re doing it. with the words they’re using. And so that’s my little tidbit for today. You know, I’ve always suggested, I’ve done this myself in cases and I’ve, I’ve, anytime we’ve used a translator in preparation, I’m always glad that we do.

And in this particular instance, the, why I’m talking about it with you today is we did, we had a translator for more sessions and it just has been So much more helpful to get that help and assistance and know, Oh, here’s this challenge with like talking about [00:08:00] what happened in the crash because of all these different verbs.

And let’s get, what is the truth? What is it that you want to say so that we make sure it’s, it’s, it’s translated correctly in English. And the concern that I had, of course, because not having had somebody there for such an extended amount of time was, well, what is, what is the ethical concern? Like, does this break confidentiality?

And so we talked with a translator with quite a bit about it before we felt comfortable and she said, no, no, that’s, that’s fine. You know, that’s an ethical code that we have, like as an official, you know, court certified interpreter translator, like it’s, it’s confidential. We’re not breaking confidentiality by, by translating, being here and translating.

So if you had that concern pop up like I did, she assured us, nope, that’s, you know, she would never be able to reveal anything, you know, she’s translator and that’s kind of the code of ethics they have for a translator. certified court certified interpreter. So be thinking of that. If you’re going to go get someone and hire someone, you want to go basically get, get some money.

[00:09:00] from a certified or court list, not just maybe the other person who speaks Spanish down, down the hallway in your office, or, you know, some, somebody not, I’m not gonna say off the street, but somebody else that’s like in your home with a friend or family that, you know, you, you really want to get somebody who’s going to be stuck with this very, and I call it book Spanish because that’s really what it is.

And when I’m using Spanish as the example, but there are same thing with, I mean, people who, Speak Russian. There are so many different flavors of that. And when you kind of understand the flavor that your client is speaking or that your deponent will be speaking, it’s going to benefit you tremendously to also learn what are some of those differences.

In that, in that specific dialect, because then you can ask questions in that way to make sure you’re hitting those verbs that you want, we’re hitting that translation that you want. So it’s [00:10:00] helpful always to do this in your clients with, with deposition prep, but always be keeping that in mind when you are going to go to post somebody where they’re from regionally and how that may change the questions when you’re going through a translator.

And yeah. Again, English, we’ve got a thousand ways to say one different phrase. So, you know, keep that in mind when you’re asking questions. And I’ll just add one other little story that I had come up again with the translators running a focus group, getting this case ready for trial. And we’re running a clip from the deposition and the client is a Spanish speaker and there’s translator and opposing counsels asking these questions.

And it’s about speed, you know, how, how fast were you going and, you know, he testifies he’s going 60, 65, which ultimately we know from black box data and [00:11:00] reconstruction, like he could not have been going 60, 65. But what was interesting was we played this clip and we did some other things. And then one of the participants said, you know, That translator was using a different kind of Spanish than that speaker.

That speaker, that, he, he’s from somewhere in Central America and that translator, he wasn’t, he wasn’t translating it 100 percent correct what that guy was saying. And it was like, oh, wait a second. Like, because this whole, of course, speed thing is, It’s kind of a hang up in the case if you couldn’t tell already.

And so it was like a light bulb when I was like, Oh, wait a second. Like that is probably, there’s, there’s probably something lost in translation and that’s kind of what she was trying to say was, I don’t think that he actually was saying that. I think the way that question came off, we understood as English, but he got a different version of it and then he came back with a little bit of dialect and then it got translated with book Spanish.

[00:12:00] And, and so it was. And so it’s like, wow, I’m so glad that she mentioned that. Again, what a nice little gem from a focus group that really hadn’t been thought of, like because the case had come along and gone through, uh, you know, a different set of lawyers and then this is the trial set, right? Lawyers are going to try the case.

So super important to always be keeping that in mind when it comes to, um, uh, uh, uh, Like translating and dialect and regional stuff. And if you’ve got a deposition in your file that has a translator, like go back and look at that, go back and figure out like, you know, maybe there’s, there are definitely some places where it just doesn’t translate the same when you have got dialect versus kind of that book, you know, kind of Spanish or whatever the second language is.

All right. This is a short and sweet episode on purpose. So thank you all so much for listening. I hope that this was helpful, you know, just keep it in mind. It’s a little bit of an added expense to bring [00:13:00] someone in to translate during depo prep, but. I guarantee it will tremendously help the client and probably reduce a little bit of time and tension in the actual deposition because they’re going to have had that process and that patience that they’re going to have to build in more so than English speakers.

I know we always tell them, let’s wait so I can object. Well, my gosh, they have to sit there even longer waiting for that translation. So anyhow, keep this in mind, use it a little bit, but just think about using. Somebody else for that to help get that little edge on translating. All right. I hope this was helpful.

I can’t wait until next episode, which is a hundred and I hope that you tune in or catch it later on, on your favorite podcast platform. If you enjoy this podcast, please rate and review it wherever you are listening. And until next time, thank you so [00:14:00] much.

Ever marveled at the power of a compelling narrative on a jury? Ever wondered how those narratives are crafted? Hillary Carls, a dynamic trial lawyer, joins us in a riveting conversation about the role of focus groups in crafting winning narratives. We recount our experiences and share how these groups have altered our approach to even the most complex cases. Hillary shares her journey to becoming a trial lawyer and how focus groups steered her to victory in a challenging sexual abuse case.

The power of visual aids and focus groups in trial cases cannot be overstated. Hillary and I dive into this, sharing our insights on creating visual aids for arguments and understanding your audience. If you’re looking to refine a story and turn a complex narrative into a compelling argument, this episode is for you. Hillary reflects on how a focus group’s input was pivotal in her sexual abuse case, and together, we emphasize the necessity of focusing on causation in trial cases.

In this episode, you will hear:

• Exploring focus groups in challenging cases
• The importance of visual aids and focus groups in trial cases
• PowerPoint presentations and the “show me yours, I’ll show you mine” strategy
• Preparing mediators in advance

Follow and Review:

We’d love for you to follow us if you haven’t yet. Click that purple ‘+’ in the top right corner of your Apple Podcasts app. We’d love it even more if you could drop a review or 5-star rating over on Apple Podcasts. Simply select “Ratings and Reviews” and “Write a Review” then a quick line with your favorite part of the episode. It only takes a second and it helps spread the word about the podcast.

Supporting Resources:

Would you like to learn more about Hillary or connect with her on a case?

Email her directly at: Hillary@carlslaw.com

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 I sent you.

Episode Transcript:

Elizabeth Larrick:

Hello and welcome back to the podcast. It’s Trial Lawyer Prep with your host, Elizabeth Larrick. I am excited here today. We have a guest joining us. A good friend of mine from Bozeman, Montana, Hillary Carls is here. Hillary and I met, gosh, it’s been a couple of [00:01:00] years. I’m always excited and blessed to get to go up to Montana trial lawyers and talk at their CLE, but we met there have become friends and have done a little bit of work together.

So I thought, you know what? It’s time Hillary needs to come on the podcast. So welcome to the podcast. 

Hillary Carls: Elizabeth, thank you so much for having me on. I’m delighted to be here. It’s such an honor. 

Elizabeth Larrick: She is kicking ass up in Bozeman, y’all. We’ve done some focus groups together, so that’s what we were going to talk about here today.

She’s always working on something different and fun and exciting. Hillary, just for some background, what got you into, let’s just go back. Why are you a trial lawyer? 

Hillary Carls: I’m a trial lawyer a little bit by accident, but it was a fortunate accident, my first job. After my clerkship in back in Montana was with a firm that was doing a lot of work in court.

And so I really cut my teeth just doing a lot of criminal defense and personal injury, just some car accidents and stuff. And my practice [00:02:00] really has just evolved over the last 18, 19 years into solely plaintiffs. Civil litigation practice. And it really right about the time when I met you is when I was making the complete transition to plaintiff’s work.

And I was on the Montana trial lawyers board and really starting to get involved in kind of that focus. And it’s just blossomed from there. I will definitely say what we got in focus groups was because of the trial lawyers. I was talking with colleagues and I’m learning how they were approaching things in our, in our practice.

Friends, Sig McKenna and Justin Staren sold me on just the great work that you guys were doing with focus groups. And frankly, I walked away feeling like I was an idiot for not doing it before then. So I have some tricky cases. I do take easy cases when I get them, but most of my cases have like a tricky component and I had some in particularly tricky ones when you and I started doing focus groups together and it really just changed my whole perspective on how we can approach difficult stories and get it right.[00:03:00] 

Elizabeth Larrick: Yeah. First of all, you’re not an idiot. Okay. Focus groups are challenging. Whenever I was practicing and going to CLEs, I would hear about it, but I didn’t really know what it was. We didn’t really get to see what they were talking about. It would just be like, Oh, we did focus groups and they told us X. And it was like, well, is it that easy?

Do they just say that? And sometimes it is that easy. Sometimes it’s not. So I appreciate you saying sometimes we just gloss over it, but it’s. Something that I think everybody should be doing, but it doesn’t mean you’re an idiot for not doing them. I may just not even know about them. So Justin and Sid, who are up in Missoula, who I have tried to get on the podcast and if they’re listening, then they know now they have to be on the podcast because you called them out.

So you had a couple of tricky cases. What kind of cases did you use for focus groups? 

Hillary Carls: So I think I, the first case. When I was thinking about coming and chatting with you, I was thinking about the first case I think you and I worked on, and it was a sexual abuse case. And generally [00:04:00] speaking, my, the allegations were I represented a fifth grader who had alleged that she was digitally penetrated by her fifth grade teacher and the police department had investigated it.

They hadn’t found any wrongdoing or that her allegations were credible. The school district had investigated it and found that there wasn’t any credible allegations. And so I knew, but there was something very credible to me about this girl and her story. And I found her credible. And, but I knew I was working against I guess good judgment and judgment of a lot of other people.

And so after I learned about this process that you guys use and focus groups, I just reached out to you and we actually did. And when I say the deep dive, I think we did, you did help me with some witness prep for depositions and then we focus grouped it. And, and so that was a really difficult case, difficult situation.

The focus group in particular though, just blew my mind in terms of how a jury or an audience could really hook on and link to my [00:05:00] client’s story and believe her, even though all the prior audiences hadn’t believed her. So it was really, it gave me a lot more confidence going in, certainly into settlement conversations and prepping for trial and all of that.

Elizabeth Larrick: Yeah, that was a kind of a, it’s a hard one, but I feel like we get cases like that all the time where we hear the client and it’s okay, that makes sense. But then everybody else, the police report, the employer, the other car. So it’s sometimes it’s really hard to have a lot of confidence in what the story is and tell Okay.

We tested it. These folks are humming in. Yeah. And that was a kind of a tricky case beyond just that whole like story thing. It was, I think sexual abuse cases can be a little bit difficult. And you guys also had a lot of other factors too. We’re glossing over, which was conservative area, like small towns, like what kind of mentality is going to, it’s going to show up.

And again, testing it with focus groups. I’m glad gave you some confidence. I know that. Cases since resolved luckily, but helped you learn some [00:06:00] things. I know there’s another case we did too for focus groups. And I feel like do we do that one twice? 

Hillary Carls: Are we talking about on the last one really quick? I don’t know if I ever shared this with you, but I will tell you, I think the most impactful thing about the focus group was when we recorded it and I played it for my client and they were so on her side.

That was like such a healing and validating moment to see a group of strangers hear her story and believe her. And I don’t mean to jump back to it, but it was just a different way of thinking. I mean, it wasn’t a litigation tool in that way, but in the human experience, seeing her scene, her story told.

And it was just a different way of thinking about it. And people saying, yeah, I believe her. And that’s horrible. It was just like amazing. Though. That’s 

Elizabeth Larrick: awesome. I don’t remember that. What a wonderful tool, because I know that she did not, it didn’t advance and there wasn’t a trial. And so many people get a little hung up on like their day in court.

Now. Obviously she was not hung up on that. [00:07:00] She was just hung up on not, not being felt heard and understood and that people believed her. And so good on you. What a like quick thinking on your feet thing that I think some people would have missed that moment. And when you’re so like when your client Ford.

And you’re really trying to think of how to help them. Sometimes we forget we may have a tool available and it’s not money. Okay. It’s just this other thing that we may be able to, so good on you for being creative and Hey, that’s a good use for a focus group. 

Hillary Carls: I always try and do it to your goals and help the people that we have the opportunity to work with.

The net, the other, I think we’ve done a couple of other focus groups, but the one that I’m really thinking about is the one where it’s a discrimination case, is that the one you’re thinking about? I 

Elizabeth Larrick: was going to put that one aside, but that one was super interesting too. So here, let me just give a little background for folks who are listening.

So Hillary has been such a good, like. Very open to, Hey, let’s try this. So sometimes people, it’s hard to feel [00:08:00] creative or it’s hard to be like, this is what I need. So let’s just do the focus group this way. But Hillary was like very open to being creative and let me be creative on several of her stuff.

We’ve done different styles for almost all the focus groups, especially the one that you’re talking about. We did. Witness clips in preparation for deposition. So a lot of times people want to do the witness clips after and like getting ready for trial. You want to make sure, Hey, what are people going to think and how should they be talking to the jury through their deposition?

So that one was definitely eye opening. 

Hillary Carls: And I think it gets back to kind of something you were talking about is what are the most surprising things? That you learn in focus groups or something we’ve talked about and it was like Approaching it in a creative way because you can learn you every time you have the opportunity to get feedback from an audience you just learn so much more about how to present the next time and improve upon it and whatnot and I do a lot of discrimination work it seems like these days and [00:09:00] these are nuanced conversations and so finding out about what a group of strangers thinks about these very fine lines and moments is really important, really important.

Elizabeth Larrick: Yeah, we got a lot of good what they expect out of this particular discrimination testimony and hey that’s what you want and what they expect. 

Hillary Carls: It just then threw me to that as a case I just tried that we focus grouped before we did the plaintiff’s opening and then a focus group on the defense’s opening on it.

And that was a really, I lost the trial and I now know what I wanted to focus group it next time when I get a new trial. 

Elizabeth Larrick: It was close y’all now don’t, Hillary’s not giving herself enough credit. Like it came down to the wire, tell them what the jury actually, what the jury verdict came back with. 

Hillary Carls: Yeah, so it was like, it’s a negligent intersection case, so it’s a tough case, but my, my client had walked 90 plus percent of the road [00:10:00] across the roadway and got hit as a pedestrian by a suburban going 45 miles an hour.

But our case was about the design of the highway. and causing this accident. And 11 to 1, the jury agreed with us that the state was negligent. 11 to 1, excuse me, 10 to 2, however, that negligence did not cause. My client’s injuries, which is a tough pill to swallow, but a 

Elizabeth Larrick: little bit, yeah, that’s when people say, Oh yeah, we won and we got a thousand dollars.

Like that’s the cringe or they gave us 1 or no dollars. 

Hillary Carls: And actually I do think it was 11 and one 11 to one on both votes. So it completely switched. After we talked to the jury or someone talked to the jury on our behalf, we found out they had gotten to damages. They had gotten past causation and one juror pulled them back and it changed the whole conversation on causation.

So we’ll see. We’re on appeal and hopefully I’ll Best focus group ever, jury trials, [00:11:00] followed by yours. 

Elizabeth Larrick: First of all, good on you for appealing it, but yeah, it’s, and good on you for talking to the jury. I know some people do, some people don’t, some jurors just won’t even talk to you at all. Sometimes it’s hard to get.

Information like that, but in those focus groups, we had done two and the nice thing about those focus groups we had done, we looked at your timelines, right? And we fashioned those one, what they wanted. There was a lot of visual aid work on how to look at this particular intersection that I think you guys did fantastic listening to the focus group and making those changes, even though it may not have been like what We as lawyers intuitively would have thought that’s what they need to see.

Hillary Carls: You know, if you haven’t had the opportunity to work with Elisabeth on a focus group, this case is a great example of just what an asset she has on it. Because this exhibit thing that we’re talking about. Is exactly it. Not only did Elizabeth put together this whole focus [00:12:00] group and lead it and guide us on how to like best present the evidence or the, our story to the focus group.

But you had such an, you really were engaged about our exhibits and helped make them better. I was like, Elizabeth is my co counselor right now. I 

Elizabeth Larrick: really love visual aids. Like I just get so excited when people, oh my gosh, if they’re doing it, And anyone who’s probably worked means, yeah, she’s going to say you want a timeline.

I get so excited about them. I have forms for them. I have templates. Like I get so excited about timelines and visual aids. And I, I use Canva a lot and just sidebar. Canva is a great resource. You can get a free account. There are so many things like cool things you can do like bar graphs and all kinds of stuff.

So if you are interested and want to just play like canvas, a good place to play, but, but yeah, I was totally into your visual aids 

Hillary Carls: because I love that. Yeah. Yeah. No, but it’s so important because again, it’s just another way. We’re all trying to win our arguments, right. Or persuade our [00:13:00] audience. And I guess when I, since we’ve gotten into focus, you’re being, uh, It’s really forced me to put aside the, recognize my own ego in my storytelling.

And just because I think the story is this way, or this is the best way to talk, communicate what happened to our clients from it. Who am I to think that I’m like, could see it the clearest. And you just learn so much from what the 10 people that you, that are more reflective of actually what people will think about this story or the facts than, and certainly me.

And my computer, 

Elizabeth Larrick: that’s just what we do. We have a lot of experience and we put it together, but I do think sometimes those focus groups just help us kind of fine tune. And a lot of times it comes down to the order and that’s where you figure out where the, Oh, That’s all of a sudden that’s the highlight now.

It’s okay. How do we use that? Or in that particular case with that visual aid, what we found out was they love the backstory, but they were getting lost in it. So then [00:14:00] that’s where our timeline came in, of course, but it really then helps solidify like all these available points of data that they, you’re engineer minded, there it is.

You’re whatever it is. It was in black and white. They could not have ignored it on that timeline, which I think. You guys did a great job putting so much focus on that timeline and the complaints and all those things that people want to see and know versus sometimes you guys had, again, great. And I said, this sounds terrible, but this is what happens when you become a plant installer.

The injuries were just darn horrific, just astronomical. She had some great visual aids for that, but it was just like, you don’t need to worry about damages because those are taking care of themselves. It’s going to be getting the hook on there and making sure that they had the ability, the knowledge and whatever kind of funky.

Montana statute you 

Hillary Carls: guys had. What’s interesting about that is talking about what different groups go. And it’s certainly the difference between an [00:15:00] hour long focus group versus a week long trial. We had picked out some of the key damages, like pictures that really show just how broken my client’s body was.

And after the week, I think one of the lessons learned in the jury trial that you’re hoping to get a new trial on is that the jury, those were seen almost too much because they did get it. They saw the damages, they knew the damages, and that was an important lesson thinking about when we go into the next time is focusing more obviously on causation a whole lot more because the damages were pretty clear.

But they were pretty gross. I think I grossed them out by it and seeing it so often. 

Elizabeth Larrick: I’ve never seen it. I like one of the injuries this guy had was like his skull completely broken half. I’ve never seen that in any case. So of course I’m like, show me the picture. You had the x ray. So it was just like, Because if you tell somebody [00:16:00] and we do a lot of visual aids and I encourage a lot of people to do, even if it’s just a graphic, just the MRI, like you’re giving them something.

But whenever I hear we show a visual of a broken knee and exactly how it broke, or this guy’s poor broken face. And I hear from from a juror. I don’t need to see that picture. I know it’s a broken bone. I’m like, you don’t give one toots about this poor person. Is everybody else? Whoa. Cause saying, oh, you broke your knee.

Oh, I broke my face. Okay. But how it happened. And like the whole thing separated, like your mind goes to a thousand other places versus just saying it. 

Hillary Carls: Cause yeah, the name of that fracture is Laforte fracture three. And you’re like, What does that tell you? Nothing. But then when you see the top and the bottom of the skull separating from each other, you’re like, that hurts my actual eyeballs right now, and my nose, and the whole thing.

And you, it makes sense why his whole face is numb and when he can’t, he bites his lips [00:17:00] and can’t breathe out of his nose and all the all the things. Yeah. But that is that’s the one it’s when it’s a that case in particular I was listening to you interview another colleague of ours Lucas Faust another Bozeman, Montana attorney Gosh, however long that goes and listening to his focus group regiment or routine.

I would say on his cases Again, so enlightening and I was like, I really got to do this more often like you got to do it early but I keep doing it and refining these themes because The difficult cases are one of the, the great cases in my view, they require finding that sweet spot and that how to best tell the story.

And on my case that I lost, I’m looking forward to my do over because I’ve certainly learned a whole lot and look forward to the challenge. 

Elizabeth Larrick: I think statistically you’re more likely to win the second trial. I always tell it to people who have new trials and that doesn’t help me, Elizabeth. I’m just.

Telling you statistically, but I was scrolling through LinkedIn the other day [00:18:00] and Keith Mitnick is in my feed and fantastic. If you’re not following Keith Mitnick on LinkedIn, you’re missing out on so much great information, but he’s talked about one of our key jobs is to find the fatal flaw in our cases and doing a focus group.

Earlier will allow you to find it earlier and fix it along the way. And so that’s why sometimes like having Lucas on to walk through, it sounded like, wow, that’s a lot of focus groups, but really lives of our cases, especially down here. A year and a half, two years, if you’ve got a COVID case, we’re talking, we’re kicked down the road, just still on making up cases from before COVID.

You got a long, you got a long life here. You’ve got time to finagle things if you get in there early. And that’s what I always encourage people to do, especially if we’re going to spend a big old hunk of money. Pile of money. 

Hillary Carls: Oh man. Cause we invest in our case, right? We, if you want to invest in an expert, okay.

50, 000 or whatever the number is. A focus group is a [00:19:00] bargain in comparison to that. It’s when we were in, we just saw each other in Missoula. I was talking with another Montana attorney then. I’m really like really intrigued by what Elizabeth was saying. Are you serious? Like it really works. What is it?

Like how much time do you invest? I go, It is seriously the best bang for your buck. It’s like you’re researching. Yeah, we can get on Westlaw and research law and find all the cases but this is researching the like human experience and Sure, you can’t perfectly replicate a focus group with a jury, but it sure is pretty good No, absolutely.

Absolutely. It’s Invaluable. And I really do. I actually, even as I’m talking here right now, I’m like, reminder, get this on the calendar. Schedule some more focus. 

Elizabeth Larrick: And I think one, one thing that, and I did it too. And I, sometimes I still phone a friend, you pick up the phone, you, or you got the monthly meeting and you say, Hey, can I run a case by you?

And that’s all good. But we live in this world. We [00:20:00] live and breathe in this world. And. I am always amazed when I’m doing focus groups at people on the outside, looking at our, looking at what we do and seeing things change. And I think one of the CLEs that I came was just, Hey, y’all, the world is a little different after COVID people got a little bit different expectations about things.

And one of the things I’m seeing in a lot of spaces in LinkedIn and on different CLEs are jurors. Don’t really care as much as you think they do. And most of them are even more angry now about being called to jury service than before. And I’ve seen that. And so it’s just, Ooh, don’t you want to know? It’s a simple question.

Hey, if you got called down the courthouse and this is something you’d listen to. Would it be a waste of your time? Yes. How come? Like, so even just having that, how do I pique their interests? Like, how do I get them not emotionally invested? Cause you can, or sometimes you can just [00:21:00] depend on what it is, but just knowing that, okay, like that funky thing or that little bitty piece, or that’s what annoys them or get rid of that.

Even if you just learned one thing, like it’s, I guarantee you, it’s going to be something that you would have done at trial. And you would have pissed somebody off and you just and you never would have known and that’s sometimes the kickers. I don’t know what happened. I’m like, oh boy, you always want to know so you can fix it for later.

Always helpful. I think naturally I’m totally biased though, because that’s what I do is focus groups. 

Hillary Carls: No, but it is. It really is. Especially the cause of civil litigation right now. If you’re not If you’re investing anything in your case, you really need to prioritize a focus group and the investment as well, because it’s, it’s good money after bad, if you don’t do it really.

And it’s the whole piece of the puzzle, two things that you were just saying. And one, Keith Miknik, I’m going to say his last name wrong. I apologize. I never get last names right. But I was just listening to him being [00:22:00] interviewed on another podcast and he, you were talking about the fatal flaw and it was, he just, This is like a focus group.

Somebody says something and it just like keys you in, but he was talking about it’s always earlier than you think it is and it’s farther back in time. And it just triggered all these cases I have that grounded them in the moment that we really had. And it was like, yes. And it was like these light bulb moments.

And that’s what the hope you get from this kind of education and these things and the whole deal. Um, I’m curious, too, what you have found in all the focus groups that you do, because in a couple of these cases that we’ve done, I’ve used them, I’ve tried to get the mediator or the settlement master to watch it as well, or talk about it, because they were to get some feedback.

I was like, really? Because we’re just a bunch of lawyers trying to guess this. And I’ll just be frank, none of the mediators talk onto it and they always clue me and tell me they’re not interested. And do you, have you heard of anyone successfully doing that?

Elizabeth Larrick: I [00:23:00] will tell you that I have not had, I will just say from my personal experience, not had great experience, but what I have learned is a lot of it is in the setup. Meaning like I have to start planting that seed with them when we set mediation that this is something that. If we’re going to, you’re going to have to watch it.

And again, people are like, well, that sounds like a condition. I’m like, it is a condition, but the other thing that I always hear or that I’ve heard from mediators, and I think John Rubin is local mediator here. And you just throw it at us. You just throw it at them and they’re not prepared. They’re it’s all over the place.

So it’s a, I think a lot of it is in the setup and. I think also, I, let’s just say from my experience, I didn’t tell them that I did it. I created a PowerPoint and then that was my opening, right? And I know that you guys don’t do, Montana doesn’t do a lot of openings, right? [00:24:00] 

Hillary Carls: It depends on the judge or the circumstance, but sure.

Yeah. 

Elizabeth Larrick: Okay. And some people are getting away from here in Texas. And that recent mediator we had on here was like, stop doing away with that. Do the openings. Like, even if it’s just 10 minutes, because this is that shot to talk, you know, that they like it. Cause they want to talk to your client. You like it.

Cause you want to talk to the decision makers. And so I did that. I had an opening and I made this soul crushing PowerPoint. This was very early on. Didn’t tell anyone I was going to do that. I just. There was no way we were settling it 

Hillary Carls: after you’re talking about openings and mediation. We don’t do that.

Sorry. I thought you were talking about trial and 

Elizabeth Larrick: mediation and with this really bold, I would say, and of course crushed any possibility of settlement, which we needed to settle the case. But has it worked before you? Is 

Hillary Carls: it? Do you think that’s an effective? I I guess step in your guys mediation process, or can it 

Elizabeth Larrick: be?

It can be. I think it 100 percent can be. I think you got to get the mediator on [00:25:00] board and you got to do the warmups and the, some of the things that I think are difficult. And I’ll just say, Texas, we got a lot of lawyers. We got a lot of mediators. Montana, a little smaller crowd, a little smaller pond, sometimes maybe harder to convince your mediators.

But I was like, from what I’ve heard and what I understand is you got to warm it up early and you got to really say this is five minutes and if you don’t like, here’s all the information I can give you. Here’s the non disclosures, here’s the names, here’s where they live. It’s not my voice. And I think if you sometimes.

And someone’s going to hear this podcast and be like, that’s not how you do it. There are lots of ways to do it, but I’m just telling you from my experience, I didn’t warm anybody up and not warming people up and getting them set up for that. And just telling you can even tell the other side, Hey, we were running focus groups and this is what we found.

And I will just tell you, I’ve done it by ambush. And that never works. [00:26:00] I did. I’m thinking of another case I did by ambush, Oh, whoopsies don’t do it by ambush because they’re not expecting it. So I think it’s all in the warmup and I think it’s also the way I’ve seen it uses it’s you show me yours. I’ll show you mine.

Hillary Carls: So that’s interesting. So when now I’m curious on this whole mediation opening and ambush idea, because you’re right, because it’s getting back to your audience. You want your audience to respond positively to what you’re suggesting and stuff. And it ambush puts up our defenses and all that. When you do, like, an opening and mediation, is the defense also watching it?

Is it mediator and defense is watching your I think, see, I think that’s actually a really interesting good idea, because you want cases get settled when both parties are a little bit nervous about what’s going to happen, and I think it’s a I could see how under ambush you get super defensive and guard up.

However, if you prepped it exactly what you’re saying and all of it, it could be really effective to be like, want to have an honest conversation [00:27:00] about resolving this case, see my best day. Here it is. 

Elizabeth Larrick: That’s right. In the most effective, and again, I, Cause I don’t have to mediate anymore, but most people that I am talking to, and we’re doing focus groups, we’re doing that, unfortunately, like it’s, we got multiple mediation situations on these larger cases.

So you’re just buckle up buttercup. Like we, but that being said, like having that, always having an expectation and knowing what you’re working for and where you’re going and what the issues are. And then just knowing I, you think this is an issue for me. I am not afraid. Why, why I’m not afraid of that.

And it’s almost having that level of preparation. Sometimes I think that scares them more because you are doing the work. You’ve got the visual aids you’ve got. And so I always. When I hear people say, we’re not, once we get past mediation, then we’ll do ABCD. And I’m like, you’re just too late. Like you should [00:28:00] be doing all of those things and we don’t want to spend it.

And then mediation, you may get more value. There’s value in doing all of these things. It’s not like it’s going to go by the wayside or be lost. 

Hillary Carls: It’s a season of mediations. It seems. So I feel like I’m a mediation all the time. And you just described so many experiences. It’s, it can be such a hit or miss experience in terms of, and I can’t, yeah.

I’m constantly thinking because of course our clients want to settle their cases. I do, I agree exactly with what you’re talking about is our best card forward and trying to leverage the best moment for them to settle their cases. We’re going to trial. You’re afraid of me. I’m prepped. I’m ready to go.

Here we go. And all this stuff. And in the last couple of weeks, I’ve probably mediated, I don’t know, four or five cases and I’ve had the spectrum of experiences. One case, they knew I was prepped and ready to go, but it was really, the parties just came to the table and we had the right kind of facts to make them nervous early on.

And I had this other one, we’re on the [00:29:00] verge of trial and they’re, everyone’s just calling each other’s bluff. And I know the defense didn’t come to the table with this at all because. They think something that I’m not afraid of at all is undermining the case. And I, so anyhow, getting back to the original question about like focus groups and like mediations.

And now my very, I’m very interested in openings for mediations because I tried to actually do it in this case where they basically told me to go fly a kite. And I was like, wow, they just couldn’t hear 

Elizabeth Larrick: it, but I probably didn’t prep it right. When you’re asking people to do something that they haven’t done.

And you’re asking people, that’s not how it’s done. That’s not true. In many other states, we have, there are openings. In mediation, it’s just one of those things sometimes where you’re just like, I can’t come in good faith unless I know you’re actually going to have a space for me and a space and space open for you too.

So it’s sometimes I feel like, because here, especially most counties in Texas, especially where we are, where [00:30:00] I am, like it’s mandatory, you don’t have a choice. So it doesn’t matter whether you come with a dollar or four. 5 million, like you got to do it. And a lot of you just, you’re jumping through a hoop and it’s, we just wasted.

And so I know a lot of colleagues who just basically say, Hey, I filed a motion that says we don’t need to go to mediation. It’s a waste of time, waste of money. And then if the defense, no, we got to do it. You got to go in front of the judge to argue about it. But it’s such a, kind of like a hoop you jump through, which is frustrating.

Hillary Carls: And so. I agree it on all I go up and down on mediation so much I there’s bright moments and bright lights where it’s really effective tool that I’m grateful for my clients were able to use, but there’s a lot of way mediation can be a soul crushing experience, which is maybe that’s why it’s probably that’s what I don’t like about it for plaintiffs is when it feels like The process is to tell them all the defenses in a way they hear defenses in [00:31:00] a different way than we do and that it beats Them up over a day to try to get them to like minimize the value that they see or whatever But it’s a human experience.

Of course, that’s we do it on both sides arguing defenses and strengths and all the other things But I would like to I know mediations do work and all the same with my take most state courts Most of Montana State court orders it. Federal court, you’ll probably get order to it. I dunno, but it’s not as mandatory.

But it is. It’s a hard, 

Elizabeth Larrick: it’s, it’s become, it didn’t always be, it wasn’t always this way. It wasn’t always where it’s just the word, but it, it is a struggle. And I think a lot of people, there are a lot of great books. There’s a couple really good books out there about it. There’s a couple good classes about it, but.

Yeah, sometimes it’s just a slog and it’s just like, but I love, here’s what I love to do about with mediation is I love to spend, even though Texas is a big state, we got a lot of mediators, we do a lot of the same mediators. So I will prepare my client for the exact speech they’re going to get with [00:32:00] the particular mediator and exactly what they’re going to say.

And the media leaves the room, the client’s like, Oh, that’s exactly what you said was going to happen. I was like, I know, isn’t it weird? And like, so they’re not like, They’re mind blown. Like that’s actually going to happen. Cause they don’t believe me initially. I’m like, yeah, they’re going to come in here and tell you that your case stinks, that you weren’t hurt.

Your bills. No, we were not going to pay the whole bill. It’s just, which they’re like, what do you mean most? And that’s what I love about focus groups. We talk about reducing bills or what do you mean reduce the bill? Like it’s the bill, like, like all of a sudden the hospital is taking a discount, but that’s my, one of my favorite things to do with mediation is just listen, this is what we’re going to do.

It’s what we’re not going to do. We have a very kind of, it’s not as in depth as depo prep, but I spend quite a bit of time doing the mediation prep, just to make sure, like you said, we don’t have the air come out of the balloon and fall out. 

Hillary Carls: Cause the longer you do this, you learn that lawyers think about things.[00:33:00] 

Not the same way that other people in day to day life think about things. And so I become more like calloused or things don’t shock me as much of the, whatever it might be. And again, getting back to preparing your audience, when you’re preparing your client for mediation, like the expectations or what they’ll hear and like the processes and stuff and it, I do give up because I obviously I’ve in the last couple of weeks I’ve been doing quite a few mediations and it is the same intro because that is what the, that the client needs to hear on the whole thing.

I do wish defendants or insurance companies would understand that they also could Approach it in a way that maybe left the plaintiff feeling a little bit more respected, they’d probably be more effective, right? Which is like vinegar. 

Elizabeth Larrick: Hands down. That’s why I’m just like, I’m not sure how you guys are missing the mark here.

All my focus groups, if they would just take responsibility and say that, yeah, they caused the wreck. What are we doing here? I’m just like, those are the scariest cases, right? Where the defendant’s really nice and [00:34:00] says, yep, I totally crashed in the back of them. But that’s, it’s, here we are talking about mediation tangent.

Sorry, I think we do mediation focus groups and stuff like that, but I just. I think again, it just really goes back to helping you set expectations. Focus groups do, especially before I go to mediation and getting that outside perspective. Cause you know what the defense perspective is. You know what the insurance carrier’s perspective is.

And it’s like, how do I get them to look at this other perspective? Like you’re ignoring this. I know you don’t run folks groups. I know you think that this is a joke that I planted all these people, but I’ll show you the bad stuff too. Like you want to see the bad stuff. I’ll show you the bad stuff, but.

It’s a conundrum. And again, I think you nailed it. If the process was just a little bit more respectful, then I think we’d get a little bit farther with mediation and don’t get me wrong. There’s some great mediators who are, who do the process beautifully. And when the other lawyer recommends that person, you’re like, Oh, okay.

Like [00:35:00] now we’re serious because this is a good mediator. And other times you mediate, you’re just like, 

Hillary Carls: there’s nothing better than an effective mediator. And there’s just some that are really master that and do a good job, really do a good job. No, they’re great. And it’s actually interesting. One of the most effective mediators, I think in Montana right now, I’ve.

I have this one defense counsel who refuses to mediate with him. And I couldn’t believe it, quite frankly, because he’s an unbelievably respected attorney. And I was like, huh, that’s because he gets cases done. You pay more than you, you are, whatever it might be. But it It’s telling on that for sure. So we’re in the dispute resolution process, right?

And ultimately the jury trials where it all, or a judge trial, whatever it is, the final way we do that. But mediations, depositions, they’re pre filing. These are all moments that we have the opportunity to resolve whatever our client’s dispute is. 

Elizabeth Larrick: Yeah. [00:36:00] 

Hillary Carls: It’s a slog. 

Elizabeth Larrick: It’s a slog. It’s a total slog. I just, I’m so like, I would still be like, thank you for being a trial lawyer because it’s a slog.

Like litigation, sometimes it’s a battleground. Thank you so much for coming on. And I’m so glad we got to have a tangent talking about mediation because I know a lot of people want to use focus groups and mediation and I wish I had a better, I wish I had a better answer. And you know what? I’m going to find a better answer because I know I’m thinking, I got a lawyer right here in my mind.

Who uses mediation, uh, who uses focus groups at mediation, and I’m going to get him on here and he’s going to tell us how to do it. Oh, I love 

Hillary Carls: that. That’s great. Cause there is, there’s really effective ways to use trial tools to continue to advance our client’s goals. So thanks for going on the tangent with me.

Elizabeth Larrick: You’re welcome. It’s always enjoyable, Hillary, to talk with you. And I’m always. Again, just like you’re doing good work. Please keep up, keep up the work in this log. 

Hillary Carls: Absolutely. Thank many. Thanks for having me on. It’s been really fun. Thanks so much. Awesome. Thanks so 

Elizabeth Larrick: much. All right. If you all [00:37:00] enjoyed this podcast, which I hope that you did, please review it on your favorite podcast platform and until next time, thank you.

When you’ve got 20 years of litigation under your belt, stepping into a new role can feel like a leap. But that’s exactly what Kiele Linroth Pace did when she founded her law firm and took on the fresh challenge of the special counsel role. She has effectively blended her considerable experience in criminal law with the less familiar world of law firm administration. Now, she’s got the freedom to carefully select the projects that inspire her most, and she’s even contemplating the idea of training others to do the same.

Hiring and delegation are two major focal points of our discussion. Kiele shares her expertise in simplifying the hiring process, primarily for law firm owners and solo practitioners. We also talk about the positive impact of having clear job descriptions, accountability, and adequate systems in place for a successful hire. We also tackle some of the common mistakes that can stunt a law firm’s growth – neglecting personal development, overlooking the importance of outside perspective, and underestimating the power of delegation. 

One of the most fascinating parts of our conversation revolves around the art of setting boundaries to reclaim time. Kiele shares her journey of learning to set boundaries, and how it has allowed her to conserve energy, enhance productivity, and lead a more balanced life. We also dive into the idea of finding work that truly sparks your passion. Kiele’s perspective is inspiring. Even within the same job, changes can be made to better align your work with your passion. 

In this episode, you will hear:

• Special counsel in law firms
• Mistakes impacting law firm growth
• Freelance services and time management for lawyers
• Setting boundaries to reclaim time
• Coaching for ideal clients

Follow and Review:

We’d love for you to follow us if you haven’t yet. Click that purple ‘+’ in the top right corner of your Apple Podcasts app. We’d love it even more if you could drop a review or 5-star rating over on Apple Podcasts. Simply select “Ratings and Reviews” and “Write a Review” then a quick line with your favorite part of the episode. It only takes a second and it helps spread the word about the podcast.

Supporting Resources:

Would you like to learn more about Kiele and her services?

Check out her website: https://pacefirm.com/

Or connect with her on LinkedIn: https://www.linkedin.com/in/kiele/ 

Books we talked about:

You are a Badass, Jen Sincero: https://www.amazon.com/You-Are-Badass%C2%AE-Doubting-Greatness/dp/0762447699 

You are a Badass at Making Money, Jen Sincero: https://www.amazon.com/You-Are-Badass-Making-Money/dp/0735222975 

The One Minute Manager, Ken Blanchard PhD and Spencer Johnson, MD: https://www.amazon.com/Minute-Manager-Kenneth-Blanchard-Ph-D/dp/074350917X 

The Big Leap, Gay Hendricks: https://www.amazon.com/Big-Leap-Conquer-Hidden-Level/dp/0061735361 

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 I sent you.[vc_raw_html css=”.vc_custom_1706917757750{border-radius: 10px !important;}”]%3Cscript%20src%3D%22https%3A%2F%2Ff.convertkit.com%2Fckjs%2Fck.5.js%22%3E%3C%2Fscript%3E%0A%20%20%20%20%20%20%3Cform%20action%3D%22https%3A%2F%2Fapp.convertkit.com%2Fforms%2F6080665%2Fsubscriptions%22%20class%3D%22seva-form%20formkit-form%22%20method%3D%22post%22%20data-sv-form%3D%226080665%22%20data-uid%3D%224e7d7814f1%22%20data-format%3D%22inline%22%20data-version%3D%225%22%20data-options%3D%22%7B%26quot%3Bsettings%26quot%3B%3A%7B%26quot%3Bafter_subscribe%26quot%3B%3A%7B%26quot%3Baction%26quot%3B%3A%26quot%3Bmessage%26quot%3B%2C%26quot%3Bsuccess_message%26quot%3B%3A%26quot%3BSuccess%21%20Now%20check%20your%20email%20to%20confirm%20your%20subscription.%26quot%3B%2C%26quot%3Bredirect_url%26quot%3B%3A%26quot%3B%26quot%3B%7D%2C%26quot%3Banalytics%26quot%3B%3A%7B%26quot%3Bgoogle%26quot%3B%3Anull%2C%26quot%3Bfathom%26quot%3B%3Anull%2C%26quot%3Bfacebook%26quot%3B%3Anull%2C%26quot%3Bsegment%26quot%3B%3Anull%2C%26quot%3Bpinterest%26quot%3B%3Anull%2C%26quot%3Bsparkloop%26quot%3B%3Anull%2C%26quot%3Bgoogletagmanager%26quot%3B%3Anull%7D%2C%26quot%3Bmodal%26quot%3B%3A%7B%26quot%3Btrigger%26quot%3B%3A%26quot%3Btimer%26quot%3B%2C%26quot%3Bscroll_percentage%26quot%3B%3Anull%2C%26quot%3Btimer%26quot%3B%3A5%2C%26quot%3Bdevices%26quot%3B%3A%26quot%3Ball%26quot%3B%2C%26quot%3Bshow_once_every%26quot%3B%3A15%7D%2C%26quot%3Bpowered_by%26quot%3B%3A%7B%26quot%3Bshow%26quot%3B%3Atrue%2C%26quot%3Burl%26quot%3B%3A%26quot%3Bhttps%3A%2F%2Fconvertkit.com%2Ffeatures%2Fforms%3Futm_campaign%3Dpoweredby%26amp%3Butm_content%3Dform%26amp%3Butm_medium%3Dreferral%26amp%3Butm_source%3Ddynamic%26quot%3B%7D%2C%26quot%3Brecaptcha%26quot%3B%3A%7B%26quot%3Benabled%26quot%3B%3Atrue%7D%2C%26quot%3Breturn_visitor%26quot%3B%3A%7B%26quot%3Baction%26quot%3B%3A%26quot%3Bshow%26quot%3B%2C%26quot%3Bcustom_content%26quot%3B%3A%26quot%3B%26quot%3B%7D%2C%26quot%3Bslide_in%26quot%3B%3A%7B%26quot%3Bdisplay_in%26quot%3B%3A%26quot%3Bbottom_right%26quot%3B%2C%26quot%3Btrigger%26quot%3B%3A%26quot%3Btimer%26quot%3B%2C%26quot%3Bscroll_percentage%26quot%3B%3Anull%2C%26quot%3Btimer%26quot%3B%3A5%2C%26quot%3Bdevices%26quot%3B%3A%26quot%3Ball%26quot%3B%2C%26quot%3Bshow_once_every%26quot%3B%3A15%7D%2C%26quot%3Bsticky_bar%26quot%3B%3A%7B%26quot%3Bdisplay_in%26quot%3B%3A%26quot%3Btop%26quot%3B%2C%26quot%3Btrigger%26quot%3B%3A%26quot%3Btimer%26quot%3B%2C%26quot%3Bscroll_percentage%26quot%3B%3Anull%2C%26quot%3Btimer%26quot%3B%3A5%2C%26quot%3Bdevices%26quot%3B%3A%26quot%3Ball%26quot%3B%2C%26quot%3Bshow_once_every%26quot%3B%3A15%7D%7D%2C%26quot%3Bversion%26quot%3B%3A%26quot%3B5%26quot%3B%7D%22%20min-width%3D%22400%20500%20600%20700%20800%22%20style%3D%22background-color%3A%20rgb%28255%2C%20255%2C%20255%29%3B%20border-radius%3A%206px%3B%22%3E%3Cdiv%20data-style%3D%22full%22%3E%3Cdiv%20data-element%3D%22column%22%20class%3D%22formkit-column%22%20style%3D%22background-color%3A%20rgb%2877%2C%2032%2C%20100%29%3B%22%3E%3Cdiv%20class%3D%22formkit-background%22%20style%3D%22opacity%3A%200.3%3B%22%3E%3C%2Fdiv%3E%3Cdiv%20class%3D%22formkit-header%22%20data-element%3D%22header%22%20style%3D%22color%3A%20rgb%28245%2C%20250%2C%20250%29%3B%20font-size%3A%2020px%3B%20font-weight%3A%20700%3B%22%3E%3Ch2%3ELet%27s%20keep%20the%20conversation%20going...%3C%2Fh2%3E%3C%2Fdiv%3E%3Cdiv%20class%3D%22formkit-subheader%22%20data-element%3D%22subheader%22%20style%3D%22color%3A%20rgb%28245%2C%20250%2C%20250%29%3B%20font-size%3A%2015px%3B%22%3E%3Cp%3ESubscribe%20to%20get%20valuable%20insights%20on%20case%20preparation%2C%20trial%20strategy%2C%20focus%20groups%2C%20witness%20preparation%2C%20and%20more%20off%20the%20social%20media%20grid%21%3C%2Fp%3E%3C%2Fdiv%3E%3Cdiv%20class%3D%22formkit-image%20formkit-image%20relative%20focus%3Aoutline-none%22%20role%3D%22button%22%20tabindex%3D%220%22%3E%3Cimg%20class%3D%22cursor-pointer%20focus%3Aoutline-blue%20%22%20src%3D%22https%3A%2F%2Fembed.filekitcdn.com%2Fe%2FuvpuWzKdsB35P59x2jukCL%2FfZLhSybQPt3etLder2tjyT%22%20style%3D%22max-width%3A%20100%25%3B%22%3E%3C%2Fdiv%3E%3C%2Fdiv%3E%3Cdiv%20data-element%3D%22column%22%20class%3D%22formkit-column%22%3E%3Cul%20class%3D%22formkit-alert%20formkit-alert-error%22%20data-element%3D%22errors%22%20data-group%3D%22alert%22%3E%3C%2Ful%3E%3Cdiv%20data-element%3D%22fields%22%20class%3D%22seva-fields%20formkit-fields%22%3E%3Cdiv%20class%3D%22formkit-field%22%3E%3Cinput%20class%3D%22formkit-input%22%20name%3D%22email_address%22%20aria-label%3D%22Email%22%20placeholder%3D%22Email%22%20required%3D%22%22%20type%3D%22email%22%20style%3D%22color%3A%20rgb%280%2C%200%2C%200%29%3B%20border-color%3A%20rgb%28227%2C%20227%2C%20227%29%3B%20border-radius%3A%204px%3B%20font-weight%3A%20400%3B%22%3E%3C%2Fdiv%3E%3Cdiv%20class%3D%22formkit-field%22%3E%3Cinput%20class%3D%22formkit-input%22%20aria-label%3D%22First%20Name%22%20name%3D%22fields%5Bfirst_name%5D%22%20required%3D%22%22%20placeholder%3D%22First%20Name%22%20type%3D%22text%22%20style%3D%22color%3A%20rgb%280%2C%200%2C%200%29%3B%20border-color%3A%20rgb%28227%2C%20227%2C%20227%29%3B%20border-radius%3A%204px%3B%20font-weight%3A%20400%3B%22%3E%3C%2Fdiv%3E%3Cdiv%20class%3D%22formkit-field%22%3E%3Cinput%20class%3D%22formkit-input%22%20aria-label%3D%22Last%20name%22%20name%3D%22fields%5Blast_name%5D%22%20required%3D%22%22%20placeholder%3D%22Last%20name%22%20type%3D%22text%22%20style%3D%22color%3A%20rgb%280%2C%200%2C%200%29%3B%20border-color%3A%20rgb%28227%2C%20227%2C%20227%29%3B%20border-radius%3A%204px%3B%20font-weight%3A%20400%3B%22%3E%3C%2Fdiv%3E%3Cdiv%20class%3D%22formkit-field%22%3E%3Cdiv%20role%3D%22button%22%20tabindex%3D%220%22%3E%3Cfieldset%20data-group%3D%22checkboxes%22%20class%3D%22formkit-9196%22%20type%3D%22Custom%22%20order%3D%223%22%20save_as%3D%22Tag%22%20group%3D%22field%22%3E%3Clegend%20style%3D%22color%3A%20rgb%280%2C%200%2C%200%29%3B%20font-weight%3A%20400%3B%22%3EHow%20did%20you%20hear%20about%20me%3F%3C%2Flegend%3E%3Cdiv%20class%3D%22formkit-checkboxes%22%20data-element%3D%22tags-checkboxes%22%20data-group%3D%22checkbox%22%20style%3D%22color%3A%20rgb%280%2C%200%2C%200%29%3B%20border-color%3A%20rgb%28227%2C%20227%2C%20227%29%3B%20border-radius%3A%204px%3B%20font-weight%3A%20400%3B%22%3E%3Cinput%20class%3D%22formkit-checkbox%22%20id%3D%22tag-883648303-2739281%22%20type%3D%22checkbox%22%20name%3D%22tags%5B%5D%22%20value%3D%222739281%22%3E%3Clabel%20for%3D%22tag-883648303-2739281%22%3EYour%20Podcast%3C%2Flabel%3E%3C%2Fdiv%3E%3Cdiv%20class%3D%22formkit-checkboxes%22%20data-element%3D%22tags-checkboxes%22%20data-group%3D%22checkbox%22%20style%3D%22color%3A%20rgb%280%2C%200%2C%200%29%3B%20border-color%3A%20rgb%28227%2C%20227%2C%20227%29%3B%20border-radius%3A%204px%3B%20font-weight%3A%20400%3B%22%3E%3Cinput%20class%3D%22formkit-checkbox%22%20id%3D%22tag-883648303-4434362%22%20type%3D%22checkbox%22%20name%3D%22tags%5B%5D%22%20value%3D%224434362%22%3E%3Clabel%20for%3D%22tag-883648303-4434362%22%3ELinkedIn%3C%2Flabel%3E%3C%2Fdiv%3E%3Cdiv%20class%3D%22formkit-checkboxes%22%20data-element%3D%22tags-checkboxes%22%20data-group%3D%22checkbox%22%20style%3D%22color%3A%20rgb%280%2C%200%2C%200%29%3B%20border-color%3A%20rgb%28227%2C%20227%2C%20227%29%3B%20border-radius%3A%204px%3B%20font-weight%3A%20400%3B%22%3E%3Cinput%20class%3D%22formkit-checkbox%22%20id%3D%22tag-883648303-4434363%22%20type%3D%22checkbox%22%20name%3D%22tags%5B%5D%22%20value%3D%224434363%22%3E%3Clabel%20for%3D%22tag-883648303-4434363%22%3EA%20Friend%3C%2Flabel%3E%3C%2Fdiv%3E%3Cdiv%20class%3D%22formkit-checkboxes%22%20data-element%3D%22tags-checkboxes%22%20data-group%3D%22checkbox%22%20style%3D%22color%3A%20rgb%280%2C%200%2C%200%29%3B%20border-color%3A%20rgb%28227%2C%20227%2C%20227%29%3B%20border-radius%3A%204px%3B%20font-weight%3A%20400%3B%22%3E%3Cinput%20class%3D%22formkit-checkbox%22%20id%3D%22tag-883648303-4434365%22%20type%3D%22checkbox%22%20name%3D%22tags%5B%5D%22%20value%3D%224434365%22%3E%3Clabel%20for%3D%22tag-883648303-4434365%22%3EGoogle%2F%20Internet%20search%3C%2Flabel%3E%3C%2Fdiv%3E%3Cdiv%20class%3D%22formkit-checkboxes%22%20data-element%3D%22tags-checkboxes%22%20data-group%3D%22checkbox%22%20style%3D%22color%3A%20rgb%280%2C%200%2C%200%29%3B%20border-color%3A%20rgb%28227%2C%20227%2C%20227%29%3B%20border-radius%3A%204px%3B%20font-weight%3A%20400%3B%22%3E%3Cinput%20class%3D%22formkit-checkbox%22%20id%3D%22tag-883648303-4434367%22%20type%3D%22checkbox%22%20name%3D%22tags%5B%5D%22%20value%3D%224434367%22%3E%3Clabel%20for%3D%22tag-883648303-4434367%22%3ECLE%20Event%3C%2Flabel%3E%3C%2Fdiv%3E%3C%2Ffieldset%3E%3C%2Fdiv%3E%3C%2Fdiv%3E%3Cdiv%20class%3D%22formkit-field%22%3E%3Cdiv%20role%3D%22button%22%20tabindex%3D%220%22%3E%3Cfieldset%20data-group%3D%22checkboxes%22%20class%3D%22formkit-9593%22%20type%3D%22Custom%22%20order%3D%224%22%20save_as%3D%22Tag%22%20group%3D%22field%22%3E%3Clegend%20style%3D%22color%3A%20rgb%280%2C%200%2C%200%29%3B%20font-weight%3A%20400%3B%22%3EI%20am%20a%28n%29%3A%3C%2Flegend%3E%3Cdiv%20class%3D%22formkit-checkboxes%22%20data-element%3D%22tags-checkboxes%22%20data-group%3D%22checkbox%22%20style%3D%22color%3A%20rgb%280%2C%200%2C%200%29%3B%20border-color%3A%20rgb%28227%2C%20227%2C%20227%29%3B%20border-radius%3A%204px%3B%20font-weight%3A%20400%3B%22%3E%3Cinput%20class%3D%22formkit-checkbox%22%20id%3D%22tag-883648593-1579500%22%20type%3D%22checkbox%22%20name%3D%22tags%5B%5D%22%20value%3D%221579500%22%3E%3Clabel%20for%3D%22tag-883648593-1579500%22%3ELawyer%20%2F%20Attorney%20%3C%2Flabel%3E%3C%2Fdiv%3E%3Cdiv%20class%3D%22formkit-checkboxes%22%20data-element%3D%22tags-checkboxes%22%20data-group%3D%22checkbox%22%20style%3D%22color%3A%20rgb%280%2C%200%2C%200%29%3B%20border-color%3A%20rgb%28227%2C%20227%2C%20227%29%3B%20border-radius%3A%204px%3B%20font-weight%3A%20400%3B%22%3E%3Cinput%20class%3D%22formkit-checkbox%22%20id%3D%22tag-883648593-4434375%22%20type%3D%22checkbox%22%20name%3D%22tags%5B%5D%22%20value%3D%224434375%22%3E%3Clabel%20for%3D%22tag-883648593-4434375%22%3ELegal%20support%20%2F%20Paralegal%20%3C%2Flabel%3E%3C%2Fdiv%3E%3Cdiv%20class%3D%22formkit-checkboxes%22%20data-element%3D%22tags-checkboxes%22%20data-group%3D%22checkbox%22%20style%3D%22color%3A%20rgb%280%2C%200%2C%200%29%3B%20border-color%3A%20rgb%28227%2C%20227%2C%20227%29%3B%20border-radius%3A%204px%3B%20font-weight%3A%20400%3B%22%3E%3Cinput%20class%3D%22formkit-checkbox%22%20id%3D%22tag-883648593-4434376%22%20type%3D%22checkbox%22%20name%3D%22tags%5B%5D%22%20value%3D%224434376%22%3E%3Clabel%20for%3D%22tag-883648593-4434376%22%3ELegal%20Consultant%20%2F%20Vendor%3C%2Flabel%3E%3C%2Fdiv%3E%3C%2Ffieldset%3E%3C%2Fdiv%3E%3C%2Fdiv%3E%3Cdiv%20class%3D%22formkit-field%22%3E%3Cinput%20class%3D%22formkit-input%22%20aria-label%3D%22Job%20Title%20%28if%20different%20from%20one%20of%20the%20above%20options%29%22%20name%3D%22fields%5Bsubscriber_type%5D%22%20placeholder%3D%22Job%20Title%20%28if%20different%20from%20one%20of%20the%20above%20options%29%22%20type%3D%22text%22%20style%3D%22color%3A%20rgb%280%2C%200%2C%200%29%3B%20border-color%3A%20rgb%28227%2C%20227%2C%20227%29%3B%20border-radius%3A%204px%3B%20font-weight%3A%20400%3B%22%3E%3C%2Fdiv%3E%3Cbutton%20data-element%3D%22submit%22%20class%3D%22formkit-submit%20formkit-submit%22%20style%3D%22color%3A%20rgb%28255%2C%20255%2C%20255%29%3B%20background-color%3A%20rgb%28248%2C%2099%2C%2074%29%3B%20border-radius%3A%2024px%3B%20font-weight%3A%20700%3B%22%3E%3Cdiv%20class%3D%22formkit-spinner%22%3E%3Cdiv%3E%3C%2Fdiv%3E%3Cdiv%3E%3C%2Fdiv%3E%3Cdiv%3E%3C%2Fdiv%3E%3C%2Fdiv%3E%3Cspan%20class%3D%22%22%3ESubscribe%3C%2Fspan%3E%3C%2Fbutton%3E%3C%2Fdiv%3E%3Cdiv%20class%3D%22formkit-guarantee%22%20data-element%3D%22guarantee%22%20style%3D%22color%3A%20rgb%2877%2C%2077%2C%2077%29%3B%20font-size%3A%2013px%3B%20font-weight%3A%20400%3B%22%3EWe%20respect%20your%20privacy.%20Unsubscribe%20at%20any%20time.%3C%2Fdiv%3E%3Cdiv%20class%3D%22formkit-powered-by-convertkit-container%22%3E%3Ca%20href%3D%22https%3A%2F%2Fconvertkit.com%2Ffeatures%2Fforms%3Futm_campaign%3Dpoweredby%26amp%3Butm_content%3Dform%26amp%3Butm_medium%3Dreferral%26amp%3Butm_source%3Ddynamic%22%20data-element%3D%22powered-by%22%20class%3D%22formkit-powered-by-convertkit%22%20data-variant%3D%22dark%22%20target%3D%22_blank%22%20rel%3D%22nofollow%22%3EBuilt%20with%20ConvertKit%3C%2Fa%3E%3C%2Fdiv%3E%3C%2Fdiv%3E%3C%2Fdiv%3E%3Cstyle%3E.formkit-form%5Bdata-uid%3D%224e7d7814f1%22%5D%20%2A%7Bbox-sizing%3Aborder-box%3B%7D.formkit-form%5Bdata-uid%3D%224e7d7814f1%22%5D%7B-webkit-font-smoothing%3Aantialiased%3B-moz-osx-font-smoothing%3Agrayscale%3B%7D.formkit-form%5Bdata-uid%3D%224e7d7814f1%22%5D%20legend%7Bborder%3Anone%3Bfont-size%3Ainherit%3Bmargin-bottom%3A10px%3Bpadding%3A0%3Bposition%3Arelative%3Bdisplay%3Atable%3B%7D.formkit-form%5Bdata-uid%3D%224e7d7814f1%22%5D%20fieldset%7Bborder%3A0%3Bpadding%3A0.01em%200%200%200%3Bmargin%3A0%3Bmin-width%3A0%3B%7D.formkit-form%5Bdata-uid%3D%224e7d7814f1%22%5D%20body%3Anot%28%3A-moz-handler-blocked%29%20fieldset%7Bdisplay%3Atable-cell%3B%7D.formkit-form%5Bdata-uid%3D%224e7d7814f1%22%5D%20h1%2C.formkit-form%5Bdata-uid%3D%224e7d7814f1%22%5D%20h2%2C.formkit-form%5Bdata-uid%3D%224e7d7814f1%22%5D%20h3%2C.formkit-form%5Bdata-uid%3D%224e7d7814f1%22%5D%20h4%2C.formkit-form%5Bdata-uid%3D%224e7d7814f1%22%5D%20h5%2C.formkit-form%5Bdata-uid%3D%224e7d7814f1%22%5D%20h6%7Bcolor%3Ainherit%3Bfont-size%3Ainherit%3Bfont-weight%3Ainherit%3B%7D.formkit-form%5Bdata-uid%3D%224e7d7814f1%22%5D%20h2%7Bfont-size%3A1.5em%3Bmargin%3A1em%200%3B%7D.formkit-form%5Bdata-uid%3D%224e7d7814f1%22%5D%20h3%7Bfont-size%3A1.17em%3Bmargin%3A1em%200%3B%7D.formkit-form%5Bdata-uid%3D%224e7d7814f1%22%5D%20p%7Bcolor%3Ainherit%3Bfont-size%3Ainherit%3Bfont-weight%3Ainherit%3B%7D.formkit-form%5Bdata-uid%3D%224e7d7814f1%22%5D%20ol%3Anot%28%5Btemplate-default%5D%29%2C.formkit-form%5Bdata-uid%3D%224e7d7814f1%22%5D%20ul%3Anot%28%5Btemplate-default%5D%29%2C.formkit-form%5Bdata-uid%3D%224e7d7814f1%22%5D%20blockquote%3Anot%28%5Btemplate-default%5D%29%7Btext-align%3Aleft%3B%7D.formkit-form%5Bdata-uid%3D%224e7d7814f1%22%5D%20p%3Anot%28%5Btemplate-default%5D%29%2C.formkit-form%5Bdata-uid%3D%224e7d7814f1%22%5D%20hr%3Anot%28%5Btemplate-default%5D%29%2C.formkit-form%5Bdata-uid%3D%224e7d7814f1%22%5D%20blockquote%3Anot%28%5Btemplate-default%5D%29%2C.formkit-form%5Bdata-uid%3D%224e7d7814f1%22%5D%20ol%3Anot%28%5Btemplate-default%5D%29%2C.formkit-form%5Bdata-uid%3D%224e7d7814f1%22%5D%20ul%3Anot%28%5Btemplate-default%5D%29%7Bcolor%3Ainherit%3Bfont-style%3Ainitial%3B%7D.formkit-form%5Bdata-uid%3D%224e7d7814f1%22%5D%20.ordered-list%2C.formkit-form%5Bdata-uid%3D%224e7d7814f1%22%5D%20.unordered-list%7Blist-style-position%3Aoutside%20%21important%3Bpadding-left%3A1em%3B%7D.formkit-form%5Bdata-uid%3D%224e7d7814f1%22%5D%20.list-item%7Bpadding-left%3A0%3B%7D.formkit-form%5Bdata-uid%3D%224e7d7814f1%22%5D%5Bdata-format%3D%22modal%22%5D%7Bdisplay%3Anone%3B%7D.formkit-form%5Bdata-uid%3D%224e7d7814f1%22%5D%5Bdata-format%3D%22slide%20in%22%5D%7Bdisplay%3Anone%3B%7D.formkit-form%5Bdata-uid%3D%224e7d7814f1%22%5D%5Bdata-format%3D%22sticky%20bar%22%5D%7Bdisplay%3Anone%3B%7D.formkit-sticky-bar%20.formkit-form%5Bdata-uid%3D%224e7d7814f1%22%5D%5Bdata-format%3D%22sticky%20bar%22%5D%7Bdisplay%3Ablock%3B%7D.formkit-form%5Bdata-uid%3D%224e7d7814f1%22%5D%20.formkit-input%2C.formkit-form%5Bdata-uid%3D%224e7d7814f1%22%5D%20.formkit-select%2C.formkit-form%5Bdata-uid%3D%224e7d7814f1%22%5D%20.formkit-checkboxes%7Bwidth%3A100%25%3B%7D.formkit-form%5Bdata-uid%3D%224e7d7814f1%22%5D%20.formkit-button%2C.formkit-form%5Bdata-uid%3D%224e7d7814f1%22%5D%20.formkit-submit%7Bborder%3A0%3Bborder-radius%3A5px%3Bcolor%3A%23ffffff%3Bcursor%3Apointer%3Bdisplay%3Ainline-block%3Btext-align%3Acenter%3Bfont-size%3A15px%3Bfont-weight%3A500%3Bcursor%3Apointer%3Bmargin-bottom%3A15px%3Boverflow%3Ahidden%3Bpadding%3A0%3Bposition%3Arelative%3Bvertical-align%3Amiddle%3B%7D.formkit-form%5Bdata-uid%3D%224e7d7814f1%22%5D%20.formkit-button%3Ahover%2C.formkit-form%5Bdata-uid%3D%224e7d7814f1%22%5D%20.formkit-submit%3Ahover%2C.formkit-form%5Bdata-uid%3D%224e7d7814f1%22%5D%20.formkit-button%3Afocus%2C.formkit-form%5Bdata-uid%3D%224e7d7814f1%22%5D%20.formkit-submit%3Afocus%7Boutline%3Anone%3B%7D.formkit-form%5Bdata-uid%3D%224e7d7814f1%22%5D%20.formkit-button%3Ahover%20%3E%20span%2C.formkit-form%5Bdata-uid%3D%224e7d7814f1%22%5D%20.formkit-submit%3Ahover%20%3E%20span%2C.formkit-form%5Bdata-uid%3D%224e7d7814f1%22%5D%20.formkit-button%3Afocus%20%3E%20span%2C.formkit-form%5Bdata-uid%3D%224e7d7814f1%22%5D%20.formkit-submit%3Afocus%20%3E%20span%7Bbackground-color%3Argba%280%2C0%2C0%2C0.1%29%3B%7D.formkit-form%5Bdata-uid%3D%224e7d7814f1%22%5D%20.formkit-button%20%3E%20span%2C.formkit-form%5Bdata-uid%3D%224e7d7814f1%22%5D%20.formkit-submit%20%3E%20span%7Bdisplay%3Ablock%3B-webkit-transition%3Aall%20300ms%20ease-in-out%3Btransition%3Aall%20300ms%20ease-in-out%3Bpadding%3A12px%2024px%3B%7D.formkit-form%5Bdata-uid%3D%224e7d7814f1%22%5D%20.formkit-input%7Bbackground%3A%23ffffff%3Bfont-size%3A15px%3Bpadding%3A12px%3Bborder%3A1px%20solid%20%23e3e3e3%3B-webkit-flex%3A1%200%20auto%3B-ms-flex%3A1%200%20auto%3Bflex%3A1%200%20auto%3Bline-height%3A1.4%3Bmargin%3A0%3B-webkit-transition%3Aborder-color%20ease-out%20300ms%3Btransition%3Aborder-color%20ease-out%20300ms%3B%7D.formkit-form%5Bdata-uid%3D%224e7d7814f1%22%5D%20.formkit-input%3Afocus%7Boutline%3Anone%3Bborder-color%3A%231677be%3B-webkit-transition%3Aborder-color%20ease%20300ms%3Btransition%3Aborder-color%20ease%20300ms%3B%7D.formkit-form%5Bdata-uid%3D%224e7d7814f1%22%5D%20.formkit-input%3A%3A-webkit-input-placeholder%7Bcolor%3Ainherit%3Bopacity%3A0.8%3B%7D.formkit-form%5Bdata-uid%3D%224e7d7814f1%22%5D%20.formkit-input%3A%3A-moz-placeholder%7Bcolor%3Ainherit%3Bopacity%3A0.8%3B%7D.formkit-form%5Bdata-uid%3D%224e7d7814f1%22%5D%20.formkit-input%3A-ms-input-placeholder%7Bcolor%3Ainherit%3Bopacity%3A0.8%3B%7D.formkit-form%5Bdata-uid%3D%224e7d7814f1%22%5D%20.formkit-input%3A%3Aplaceholder%7Bcolor%3Ainherit%3Bopacity%3A0.8%3B%7D.formkit-form%5Bdata-uid%3D%224e7d7814f1%22%5D%20%5Bdata-group%3D%22dropdown%22%5D%7Bposition%3Arelative%3Bdisplay%3Ainline-block%3Bwidth%3A100%25%3B%7D.formkit-form%5Bdata-uid%3D%224e7d7814f1%22%5D%20%5Bdata-group%3D%22dropdown%22%5D%3A%3Abefore%7Bcontent%3A%22%22%3Btop%3Acalc%2850%25%20-%202.5px%29%3Bright%3A10px%3Bposition%3Aabsolute%3Bpointer-events%3Anone%3Bborder-color%3A%234f4f4f%20transparent%20transparent%20transparent%3Bborder-style%3Asolid%3Bborder-width%3A6px%206px%200%206px%3Bheight%3A0%3Bwidth%3A0%3Bz-index%3A999%3B%7D.formkit-form%5Bdata-uid%3D%224e7d7814f1%22%5D%20%5Bdata-group%3D%22dropdown%22%5D%20select%7Bheight%3Aauto%3Bwidth%3A100%25%3Bcursor%3Apointer%3Bcolor%3A%23333333%3Bline-height%3A1.4%3Bmargin-bottom%3A0%3Bpadding%3A0%206px%3B-webkit-appearance%3Anone%3B-moz-appearance%3Anone%3Bappearance%3Anone%3Bfont-size%3A15px%3Bpadding%3A12px%3Bpadding-right%3A25px%3Bborder%3A1px%20solid%20%23e3e3e3%3Bbackground%3A%23ffffff%3B%7D.formkit-form%5Bdata-uid%3D%224e7d7814f1%22%5D%20%5Bdata-group%3D%22dropdown%22%5D%20select%3Afocus%7Boutline%3Anone%3B%7D.formkit-form%5Bdata-uid%3D%224e7d7814f1%22%5D%20%5Bdata-group%3D%22checkboxes%22%5D%7Btext-align%3Aleft%3Bmargin%3A0%3B%7D.formkit-form%5Bdata-uid%3D%224e7d7814f1%22%5D%20%5Bdata-group%3D%22checkboxes%22%5D%20%5Bdata-group%3D%22checkbox%22%5D%7Bmargin-bottom%3A10px%3B%7D.formkit-form%5Bdata-uid%3D%224e7d7814f1%22%5D%20%5Bdata-group%3D%22checkboxes%22%5D%20%5Bdata-group%3D%22checkbox%22%5D%20%2A%7Bcursor%3Apointer%3B%7D.formkit-form%5Bdata-uid%3D%224e7d7814f1%22%5D%20%5Bdata-group%3D%22checkboxes%22%5D%20%5Bdata-group%3D%22checkbox%22%5D%3Alast-of-type%7Bmargin-bottom%3A0%3B%7D.formkit-form%5Bdata-uid%3D%224e7d7814f1%22%5D%20%5Bdata-group%3D%22checkboxes%22%5D%20%5Bdata-group%3D%22checkbox%22%5D%20input%5Btype%3D%22checkbox%22%5D%7Bdisplay%3Anone%3B%7D.formkit-form%5Bdata-uid%3D%224e7d7814f1%22%5D%20%5Bdata-group%3D%22checkboxes%22%5D%20%5Bdata-group%3D%22checkbox%22%5D%20input%5Btype%3D%22checkbox%22%5D%20%2B%20label%3A%3Aafter%7Bcontent%3Anone%3B%7D.formkit-form%5Bdata-uid%3D%224e7d7814f1%22%5D%20%5Bdata-group%3D%22checkboxes%22%5D%20%5Bdata-group%3D%22checkbox%22%5D%20input%5Btype%3D%22checkbox%22%5D%3Achecked%20%2B%20label%3A%3Aafter%7Bborder-color%3A%23ffffff%3Bcontent%3A%22%22%3B%7D.formkit-form%5Bdata-uid%3D%224e7d7814f1%22%5D%20%5Bdata-group%3D%22checkboxes%22%5D%20%5Bdata-group%3D%22checkbox%22%5D%20input%5Btype%3D%22checkbox%22%5D%3Achecked%20%2B%20label%3A%3Abefore%7Bbackground%3A%2310bf7a%3Bborder-color%3A%2310bf7a%3B%7D.formkit-form%5Bdata-uid%3D%224e7d7814f1%22%5D%20%5Bdata-group%3D%22checkboxes%22%5D%20%5Bdata-group%3D%22checkbox%22%5D%20label%7Bposition%3Arelative%3Bdisplay%3Ainline-block%3Bpadding-left%3A28px%3B%7D.formkit-form%5Bdata-uid%3D%224e7d7814f1%22%5D%20%5Bdata-group%3D%22checkboxes%22%5D%20%5Bdata-group%3D%22checkbox%22%5D%20label%3A%3Abefore%2C.formkit-form%5Bdata-uid%3D%224e7d7814f1%22%5D%20%5Bdata-group%3D%22checkboxes%22%5D%20%5Bdata-group%3D%22checkbox%22%5D%20label%3A%3Aafter%7Bposition%3Aabsolute%3Bcontent%3A%22%22%3Bdisplay%3Ainline-block%3B%7D.formkit-form%5Bdata-uid%3D%224e7d7814f1%22%5D%20%5Bdata-group%3D%22checkboxes%22%5D%20%5Bdata-group%3D%22checkbox%22%5D%20label%3A%3Abefore%7Bheight%3A16px%3Bwidth%3A16px%3Bborder%3A1px%20solid%20%23e3e3e3%3Bbackground%3A%23ffffff%3Bleft%3A0px%3Btop%3A3px%3B%7D.formkit-form%5Bdata-uid%3D%224e7d7814f1%22%5D%20%5Bdata-group%3D%22checkboxes%22%5D%20%5Bdata-group%3D%22checkbox%22%5D%20label%3A%3Aafter%7Bheight%3A4px%3Bwidth%3A8px%3Bborder-left%3A2px%20solid%20%234d4d4d%3Bborder-bottom%3A2px%20solid%20%234d4d4d%3B-webkit-transform%3Arotate%28-45deg%29%3B-ms-transform%3Arotate%28-45deg%29%3Btransform%3Arotate%28-45deg%29%3Bleft%3A4px%3Btop%3A8px%3B%7D.formkit-form%5Bdata-uid%3D%224e7d7814f1%22%5D%20.formkit-alert%7Bbackground%3A%23f9fafb%3Bborder%3A1px%20solid%20%23e3e3e3%3Bborder-radius%3A5px%3B-webkit-flex%3A1%200%20auto%3B-ms-flex%3A1%200%20auto%3Bflex%3A1%200%20auto%3Blist-style%3Anone%3Bmargin%3A25px%20auto%3Bpadding%3A12px%3Btext-align%3Acenter%3Bwidth%3A100%25%3B%7D.formkit-form%5Bdata-uid%3D%224e7d7814f1%22%5D%20.formkit-alert%3Aempty%7Bdisplay%3Anone%3B%7D.formkit-form%5Bdata-uid%3D%224e7d7814f1%22%5D%20.formkit-alert-success%7Bbackground%3A%23d3fbeb%3Bborder-color%3A%2310bf7a%3Bcolor%3A%230c905c%3B%7D.formkit-form%5Bdata-uid%3D%224e7d7814f1%22%5D%20.formkit-alert-error%7Bbackground%3A%23fde8e2%3Bborder-color%3A%23f2643b%3Bcolor%3A%23ea4110%3B%7D.formkit-form%5Bdata-uid%3D%224e7d7814f1%22%5D%20.formkit-spinner%7Bdisplay%3A-webkit-box%3Bdisplay%3A-webkit-flex%3Bdisplay%3A-ms-flexbox%3Bdisplay%3Aflex%3Bheight%3A0px%3Bwidth%3A0px%3Bmargin%3A0%20auto%3Bposition%3Aabsolute%3Btop%3A0%3Bleft%3A0%3Bright%3A0%3Bwidth%3A0px%3Boverflow%3Ahidden%3Btext-align%3Acenter%3B-webkit-transition%3Aall%20300ms%20ease-in-out%3Btransition%3Aall%20300ms%20ease-in-out%3B%7D.formkit-form%5Bdata-uid%3D%224e7d7814f1%22%5D%20.formkit-spinner%20%3E%20div%7Bmargin%3Aauto%3Bwidth%3A12px%3Bheight%3A12px%3Bbackground-color%3A%23fff%3Bopacity%3A0.3%3Bborder-radius%3A100%25%3Bdisplay%3Ainline-block%3B-webkit-animation%3Aformkit-bouncedelay-formkit-form-data-uid-4e7d7814f1-%201.4s%20infinite%20ease-in-out%20both%3Banimation%3Aformkit-bouncedelay-formkit-form-data-uid-4e7d7814f1-%201.4s%20infinite%20ease-in-out%20both%3B%7D.formkit-form%5Bdata-uid%3D%224e7d7814f1%22%5D%20.formkit-spinner%20%3E%20div%3Anth-child%281%29%7B-webkit-animation-delay%3A-0.32s%3Banimation-delay%3A-0.32s%3B%7D.formkit-form%5Bdata-uid%3D%224e7d7814f1%22%5D%20.formkit-spinner%20%3E%20div%3Anth-child%282%29%7B-webkit-animation-delay%3A-0.16s%3Banimation-delay%3A-0.16s%3B%7D.formkit-form%5Bdata-uid%3D%224e7d7814f1%22%5D%20.formkit-submit%5Bdata-active%5D%20.formkit-spinner%7Bopacity%3A1%3Bheight%3A100%25%3Bwidth%3A50px%3B%7D.formkit-form%5Bdata-uid%3D%224e7d7814f1%22%5D%20.formkit-submit%5Bdata-active%5D%20.formkit-spinner%20~%20span%7Bopacity%3A0%3B%7D.formkit-form%5Bdata-uid%3D%224e7d7814f1%22%5D%20.formkit-powered-by%5Bdata-active%3D%22false%22%5D%7Bopacity%3A0.35%3B%7D.formkit-form%5Bdata-uid%3D%224e7d7814f1%22%5D%20.formkit-powered-by-convertkit-container%7Bdisplay%3A-webkit-box%3Bdisplay%3A-webkit-flex%3Bdisplay%3A-ms-flexbox%3Bdisplay%3Aflex%3Bwidth%3A100%25%3Bz-index%3A5%3Bmargin%3A10px%200%3Bposition%3Arelative%3B%7D.formkit-form%5Bdata-uid%3D%224e7d7814f1%22%5D%20.formkit-powered-by-convertkit-container%5Bdata-active%3D%22false%22%5D%7Bopacity%3A0.35%3B%7D.formkit-form%5Bdata-uid%3D%224e7d7814f1%22%5D%20.formkit-powered-by-convertkit%7B-webkit-align-items%3Acenter%3B-webkit-box-align%3Acenter%3B-ms-flex-align%3Acenter%3Balign-items%3Acenter%3Bbackground-color%3A%23ffffff%3Bborder%3A1px%20solid%20%23dde2e7%3Bborder-radius%3A4px%3Bcolor%3A%23373f45%3Bcursor%3Apointer%3Bdisplay%3Ablock%3Bheight%3A36px%3Bmargin%3A0%20auto%3Bopacity%3A0.95%3Bpadding%3A0%3B-webkit-text-decoration%3Anone%3Btext-decoration%3Anone%3Btext-indent%3A100%25%3B-webkit-transition%3Aease-in-out%20all%20200ms%3Btransition%3Aease-in-out%20all%20200ms%3Bwhite-space%3Anowrap%3Boverflow%3Ahidden%3B-webkit-user-select%3Anone%3B-moz-user-select%3Anone%3B-ms-user-select%3Anone%3Buser-select%3Anone%3Bwidth%3A190px%3Bbackground-repeat%3Ano-repeat%3Bbackground-position%3Acenter%3Bbackground-image%3Aurl%28%22data%3Aimage%2Fsvg%2Bxml%3Bcharset%3Dutf8%2C%253Csvg%20width%3D%27162%27%20height%3D%2720%27%20viewBox%3D%270%200%20162%2020%27%20fill%3D%27none%27%20xmlns%3D%27http%3A%2F%2Fwww.w3.org%2F2000%2Fsvg%27%253E%253Cpath%20d%3D%27M83.0561%2015.2457C86.675%2015.2457%2089.4722%2012.5154%2089.4722%209.14749C89.4722%205.99211%2086.8443%204.06563%2085.1038%204.06563C82.6801%204.06563%2080.7373%205.76407%2080.4605%208.28551C80.4092%208.75244%2080.0387%209.14403%2079.5686%209.14069C78.7871%209.13509%2077.6507%209.12841%2076.9314%209.13092C76.6217%209.13199%2076.3658%208.88106%2076.381%208.57196C76.4895%206.38513%2077.2218%204.3404%2078.618%202.76974C80.1695%201.02445%2082.4289%200%2085.1038%200C89.5979%200%2093.8406%204.07791%2093.8406%209.14749C93.8406%2014.7608%2089.1832%2019.3113%2083.1517%2019.3113C78.8502%2019.3113%2074.5179%2016.5041%2073.0053%2012.5795C72.9999%2012.565%2072.9986%2012.5492%2073.0015%2012.534C73.0218%2012.4179%2073.0617%2012.3118%2073.1011%2012.2074C73.1583%2012.0555%2073.2143%2011.907%2073.2062%2011.7359L73.18%2011.1892C73.174%2011.0569%2073.2075%2010.9258%2073.2764%2010.8127C73.3452%2010.6995%2073.4463%2010.6094%2073.5666%2010.554L73.7852%2010.4523C73.9077%2010.3957%2074.0148%2010.3105%2074.0976%2010.204C74.1803%2010.0974%2074.2363%209.97252%2074.2608%209.83983C74.3341%209.43894%2074.6865%209.14749%2075.0979%209.14749C75.7404%209.14749%2076.299%209.57412%2076.5088%2010.1806C77.5188%2013.1%2079.1245%2015.2457%2083.0561%2015.2457Z%27%20fill%3D%27%2523373F45%27%2F%253E%253Cpath%20d%3D%27M155.758%206.91365C155.028%206.91365%20154.804%206.47916%20154.804%205.98857C154.804%205.46997%20154.986%205.06348%20155.758%205.06348C156.53%205.06348%20156.712%205.46997%20156.712%205.98857C156.712%206.47905%20156.516%206.91365%20155.758%206.91365ZM142.441%2012.9304V9.32833L141.415%209.32323V8.90392C141.415%208.44719%20141.786%208.07758%20142.244%208.07986L142.441%208.08095V6.55306L144.082%206.09057V8.08073H145.569V8.50416C145.569%208.61242%20145.548%208.71961%20145.506%208.81961C145.465%208.91961%20145.404%209.01047%20145.328%209.08699C145.251%209.16351%20145.16%209.2242%20145.06%209.26559C144.96%209.30698%20144.853%209.32826%20144.745%209.32822H144.082V12.7201C144.082%2013.2423%20144.378%2013.4256%20144.76%2013.4887C145.209%2013.5629%20145.583%2013.888%20145.583%2014.343V14.9626C144.029%2014.9626%20142.441%2014.8942%20142.441%2012.9304Z%27%20fill%3D%27%2523373F45%27%2F%253E%253Cpath%20d%3D%27M110.058%207.92554C108.417%207.88344%20106.396%208.92062%20106.396%2011.5137C106.396%2014.0646%20108.417%2015.0738%20110.058%2015.0318C111.742%2015.0738%20113.748%2014.0646%20113.748%2011.5137C113.748%208.92062%20111.742%207.88344%20110.058%207.92554ZM110.07%2013.7586C108.878%2013.7586%20108.032%2012.8905%20108.032%2011.461C108.032%2010.1013%20108.878%209.20569%20110.071%209.20569C111.263%209.20569%20112.101%2010.0995%20112.101%2011.459C112.101%2012.8887%20111.263%2013.7586%20110.07%2013.7586Z%27%20fill%3D%27%2523373F45%27%2F%253E%253Cpath%20d%3D%27M118.06%207.94098C119.491%207.94098%20120.978%208.33337%20120.978%2011.1366V14.893H120.063C119.608%2014.893%20119.238%2014.524%20119.238%2014.0689V10.9965C119.238%209.66506%20118.747%209.16047%20117.891%209.16047C117.414%209.16047%20116.797%209.52486%20116.502%209.81915V14.069C116.502%2014.1773%20116.481%2014.2845%20116.44%2014.3845C116.398%2014.4845%20116.337%2014.5753%20116.261%2014.6519C116.184%2014.7284%20116.093%2014.7891%20115.993%2014.8305C115.893%2014.8719%20115.786%2014.8931%20115.678%2014.8931H114.847V8.10918H115.773C115.932%208.10914%20116.087%208.16315%20116.212%208.26242C116.337%208.36168%20116.424%208.50033%20116.46%208.65577C116.881%208.19328%20117.428%207.94098%20118.06%207.94098ZM122.854%208.09713C123.024%208.09708%20123.19%208.1496%20123.329%208.2475C123.468%208.34541%20123.574%208.48391%20123.631%208.64405L125.133%2012.8486L126.635%208.64415C126.692%208.48402%20126.798%208.34551%20126.937%208.2476C127.076%208.1497%20127.242%208.09718%20127.412%208.09724H128.598L126.152%2014.3567C126.091%2014.5112%20125.986%2014.6439%20125.849%2014.7374C125.711%2014.831%20125.549%2014.881%20125.383%2014.8809H124.333L121.668%208.09713H122.854Z%27%20fill%3D%27%2523373F45%27%2F%253E%253Cpath%20d%3D%27M135.085%2014.5514C134.566%2014.7616%20133.513%2015.0416%20132.418%2015.0416C130.496%2015.0416%20129.024%2013.9345%20129.024%2011.4396C129.024%209.19701%20130.451%207.99792%20132.191%207.99792C134.338%207.99792%20135.254%209.4378%20135.158%2011.3979C135.139%2011.8029%20134.786%2012.0983%20134.38%2012.0983H130.679C130.763%2013.1916%20131.562%2013.7662%20132.615%2013.7662C133.028%2013.7662%20133.462%2013.7452%20133.983%2013.6481C134.535%2013.545%20135.085%2013.9375%20135.085%2014.4985V14.5514ZM133.673%2010.949C133.785%209.87621%20133.061%209.28752%20132.191%209.28752C131.321%209.28752%20130.734%209.93979%20130.679%2010.9489L133.673%2010.949Z%27%20fill%3D%27%2523373F45%27%2F%253E%253Cpath%20d%3D%27M137.345%208.11122C137.497%208.11118%20137.645%208.16229%20137.765%208.25635C137.884%208.35041%20137.969%208.48197%20138.005%208.62993C138.566%208.20932%20139.268%207.94303%20139.759%207.94303C139.801%207.94303%20140.068%207.94303%20140.489%207.99913V8.7265C140.489%209.11748%20140.15%209.4147%20139.759%209.4147C139.31%209.4147%20138.651%209.5829%20138.131%209.8773V14.8951H136.462V8.11112L137.345%208.11122ZM156.6%2014.0508V8.09104H155.769C155.314%208.09104%20154.944%208.45999%20154.944%208.9151V14.8748H155.775C156.23%2014.8748%20156.6%2014.5058%20156.6%2014.0508ZM158.857%2012.9447V9.34254H157.749V8.91912C157.749%208.46401%20158.118%208.09506%20158.574%208.09506H158.857V6.56739L160.499%206.10479V8.09506H161.986V8.51848C161.986%208.97359%20161.617%209.34254%20161.161%209.34254H160.499V12.7345C160.499%2013.2566%20160.795%2013.44%20161.177%2013.503C161.626%2013.5774%20162%2013.9024%20162%2014.3574V14.977C160.446%2014.977%20158.857%2014.9086%20158.857%2012.9447ZM98.1929%2010.1124C98.2033%206.94046%20100.598%205.16809%20102.895%205.16809C104.171%205.16809%20105.342%205.44285%20106.304%206.12953L105.914%206.6631C105.654%207.02011%20105.16%207.16194%20104.749%206.99949C104.169%206.7702%20103.622%206.7218%20103.215%206.7218C101.335%206.7218%2099.9169%207.92849%2099.9068%2010.1123C99.9169%2012.2959%20101.335%2013.5201%20103.215%2013.5201C103.622%2013.5201%20104.169%2013.4717%20104.749%2013.2424C105.16%2013.0799%20105.654%2013.2046%20105.914%2013.5615L106.304%2014.0952C105.342%2014.7819%20104.171%2015.0566%20102.895%2015.0566C100.598%2015.0566%2098.2033%2013.2842%2098.1929%2010.1124ZM147.619%205.21768C148.074%205.21768%20148.444%205.58663%20148.444%206.04174V9.81968L151.82%205.58131C151.897%205.47733%20151.997%205.39282%20152.112%205.3346C152.227%205.27638%20152.355%205.24607%20152.484%205.24611H153.984L150.166%2010.0615L153.984%2014.8749H152.484C152.355%2014.8749%20152.227%2014.8446%20152.112%2014.7864C151.997%2014.7281%20151.897%2014.6436%20151.82%2014.5397L148.444%2010.3025V14.0508C148.444%2014.5059%20148.074%2014.8749%20147.619%2014.8749H146.746V5.21768H147.619Z%27%20fill%3D%27%2523373F45%27%2F%253E%253Cpath%20d%3D%27M0.773438%206.5752H2.68066C3.56543%206.5752%204.2041%206.7041%204.59668%206.96191C4.99219%207.21973%205.18994%207.62695%205.18994%208.18359C5.18994%208.55859%205.09326%208.87061%204.8999%209.11963C4.70654%209.36865%204.42822%209.52539%204.06494%209.58984V9.63379C4.51611%209.71875%204.84717%209.88721%205.05811%2010.1392C5.27197%2010.3882%205.37891%2010.7266%205.37891%2011.1543C5.37891%2011.7314%205.17676%2012.1841%204.77246%2012.5122C4.37109%2012.8374%203.81152%2013%203.09375%2013H0.773438V6.5752ZM1.82373%209.22949H2.83447C3.27393%209.22949%203.59473%209.16064%203.79688%209.02295C3.99902%208.88232%204.1001%208.64502%204.1001%208.31104C4.1001%208.00928%203.99023%207.79102%203.77051%207.65625C3.55371%207.52148%203.20801%207.4541%202.7334%207.4541H1.82373V9.22949ZM1.82373%2010.082V12.1167H2.93994C3.37939%2012.1167%203.71045%2012.0332%203.93311%2011.8662C4.15869%2011.6963%204.27148%2011.4297%204.27148%2011.0664C4.27148%2010.7324%204.15723%2010.4849%203.92871%2010.3237C3.7002%2010.1626%203.35303%2010.082%202.88721%2010.082H1.82373Z%27%20fill%3D%27%2523373F45%27%2F%253E%253Cpath%20d%3D%27M13.011%206.5752V10.7324C13.011%2011.207%2012.9084%2011.623%2012.7034%2011.9805C12.5012%2012.335%2012.2068%2012.6089%2011.8201%2012.8022C11.4363%2012.9927%2010.9763%2013.0879%2010.4402%2013.0879C9.6433%2013.0879%209.02368%2012.877%208.5813%2012.4551C8.13892%2012.0332%207.91772%2011.4531%207.91772%2010.7148V6.5752H8.9724V10.6401C8.9724%2011.1704%209.09546%2011.5615%209.34155%2011.8135C9.58765%2012.0654%209.96557%2012.1914%2010.4753%2012.1914C11.4656%2012.1914%2011.9607%2011.6714%2011.9607%2010.6313V6.5752H13.011Z%27%20fill%3D%27%2523373F45%27%2F%253E%253Cpath%20d%3D%27M15.9146%2013V6.5752H16.9649V13H15.9146Z%27%20fill%3D%27%2523373F45%27%2F%253E%253Cpath%20d%3D%27M19.9255%2013V6.5752H20.9758V12.0991H23.696V13H19.9255Z%27%20fill%3D%27%2523373F45%27%2F%253E%253Cpath%20d%3D%27M28.2828%2013H27.2325V7.47607H25.3428V6.5752H30.1724V7.47607H28.2828V13Z%27%20fill%3D%27%2523373F45%27%2F%253E%253Cpath%20d%3D%27M41.9472%2013H40.8046L39.7148%209.16796C39.6679%209.00097%2039.6093%208.76074%2039.539%208.44727C39.4687%208.13086%2039.4262%207.91113%2039.4116%207.78809C39.3823%207.97559%2039.3339%208.21875%2039.2665%208.51758C39.2021%208.81641%2039.1479%209.03905%2039.1039%209.18554L38.0405%2013H36.8979L36.0673%209.7832L35.2236%206.5752H36.2958L37.2143%2010.3193C37.3578%2010.9199%2037.4604%2011.4502%2037.5219%2011.9102C37.5541%2011.6611%2037.6025%2011.3828%2037.6669%2011.0752C37.7314%2010.7676%2037.79%2010.5186%2037.8427%2010.3281L38.8886%206.5752H39.9301L41.0024%2010.3457C41.1049%2010.6943%2041.2133%2011.2158%2041.3276%2011.9102C41.3715%2011.4912%2041.477%2010.958%2041.644%2010.3105L42.558%206.5752H43.6215L41.9472%2013Z%27%20fill%3D%27%2523373F45%27%2F%253E%253Cpath%20d%3D%27M45.7957%2013V6.5752H46.846V13H45.7957Z%27%20fill%3D%27%2523373F45%27%2F%253E%253Cpath%20d%3D%27M52.0258%2013H50.9755V7.47607H49.0859V6.5752H53.9155V7.47607H52.0258V13Z%27%20fill%3D%27%2523373F45%27%2F%253E%253Cpath%20d%3D%27M61.2312%2013H60.1765V10.104H57.2146V13H56.1643V6.5752H57.2146V9.20312H60.1765V6.5752H61.2312V13Z%27%20fill%3D%27%2523373F45%27%2F%253E%253C%2Fsvg%253E%22%29%3B%7D.formkit-form%5Bdata-uid%3D%224e7d7814f1%22%5D%20.formkit-powered-by-convertkit%3Ahover%2C.formkit-form%5Bdata-uid%3D%224e7d7814f1%22%5D%20.formkit-powered-by-convertkit%3Afocus%7Bbackground-color%3A%23ffffff%3B-webkit-transform%3Ascale%281.025%29%20perspective%281px%29%3B-ms-transform%3Ascale%281.025%29%20perspective%281px%29%3Btransform%3Ascale%281.025%29%20perspective%281px%29%3Bopacity%3A1%3B%7D.formkit-form%5Bdata-uid%3D%224e7d7814f1%22%5D%20.formkit-powered-by-convertkit%5Bdata-variant%3D%22dark%22%5D%2C.formkit-form%5Bdata-uid%3D%224e7d7814f1%22%5D%20.formkit-powered-by-convertkit%5Bdata-variant%3D%22light%22%5D%7Bbackground-color%3Atransparent%3Bborder-color%3Atransparent%3Bwidth%3A166px%3B%7D.formkit-form%5Bdata-uid%3D%224e7d7814f1%22%5D%20.formkit-powered-by-convertkit%5Bdata-variant%3D%22light%22%5D%7Bcolor%3A%23ffffff%3Bbackground-image%3Aurl%28%22data%3Aimage%2Fsvg%2Bxml%3Bcharset%3Dutf8%2C%253Csvg%20width%3D%27162%27%20height%3D%2720%27%20viewBox%3D%270%200%20162%2020%27%20fill%3D%27none%27%20xmlns%3D%27http%3A%2F%2Fwww.w3.org%2F2000%2Fsvg%27%253E%253Cpath%20d%3D%27M83.0561%2015.2457C86.675%2015.2457%2089.4722%2012.5154%2089.4722%209.14749C89.4722%205.99211%2086.8443%204.06563%2085.1038%204.06563C82.6801%204.06563%2080.7373%205.76407%2080.4605%208.28551C80.4092%208.75244%2080.0387%209.14403%2079.5686%209.14069C78.7871%209.13509%2077.6507%209.12841%2076.9314%209.13092C76.6217%209.13199%2076.3658%208.88106%2076.381%208.57196C76.4895%206.38513%2077.2218%204.3404%2078.618%202.76974C80.1695%201.02445%2082.4289%200%2085.1038%200C89.5979%200%2093.8406%204.07791%2093.8406%209.14749C93.8406%2014.7608%2089.1832%2019.3113%2083.1517%2019.3113C78.8502%2019.3113%2074.5179%2016.5041%2073.0053%2012.5795C72.9999%2012.565%2072.9986%2012.5492%2073.0015%2012.534C73.0218%2012.4179%2073.0617%2012.3118%2073.1011%2012.2074C73.1583%2012.0555%2073.2143%2011.907%2073.2062%2011.7359L73.18%2011.1892C73.174%2011.0569%2073.2075%2010.9258%2073.2764%2010.8127C73.3452%2010.6995%2073.4463%2010.6094%2073.5666%2010.554L73.7852%2010.4523C73.9077%2010.3957%2074.0148%2010.3105%2074.0976%2010.204C74.1803%2010.0974%2074.2363%209.97252%2074.2608%209.83983C74.3341%209.43894%2074.6865%209.14749%2075.0979%209.14749C75.7404%209.14749%2076.299%209.57412%2076.5088%2010.1806C77.5188%2013.1%2079.1245%2015.2457%2083.0561%2015.2457Z%27%20fill%3D%27white%27%2F%253E%253Cpath%20d%3D%27M155.758%206.91365C155.028%206.91365%20154.804%206.47916%20154.804%205.98857C154.804%205.46997%20154.986%205.06348%20155.758%205.06348C156.53%205.06348%20156.712%205.46997%20156.712%205.98857C156.712%206.47905%20156.516%206.91365%20155.758%206.91365ZM142.441%2012.9304V9.32833L141.415%209.32323V8.90392C141.415%208.44719%20141.786%208.07758%20142.244%208.07986L142.441%208.08095V6.55306L144.082%206.09057V8.08073H145.569V8.50416C145.569%208.61242%20145.548%208.71961%20145.506%208.81961C145.465%208.91961%20145.404%209.01047%20145.328%209.08699C145.251%209.16351%20145.16%209.2242%20145.06%209.26559C144.96%209.30698%20144.853%209.32826%20144.745%209.32822H144.082V12.7201C144.082%2013.2423%20144.378%2013.4256%20144.76%2013.4887C145.209%2013.5629%20145.583%2013.888%20145.583%2014.343V14.9626C144.029%2014.9626%20142.441%2014.8942%20142.441%2012.9304Z%27%20fill%3D%27white%27%2F%253E%253Cpath%20d%3D%27M110.058%207.92554C108.417%207.88344%20106.396%208.92062%20106.396%2011.5137C106.396%2014.0646%20108.417%2015.0738%20110.058%2015.0318C111.742%2015.0738%20113.748%2014.0646%20113.748%2011.5137C113.748%208.92062%20111.742%207.88344%20110.058%207.92554ZM110.07%2013.7586C108.878%2013.7586%20108.032%2012.8905%20108.032%2011.461C108.032%2010.1013%20108.878%209.20569%20110.071%209.20569C111.263%209.20569%20112.101%2010.0995%20112.101%2011.459C112.101%2012.8887%20111.263%2013.7586%20110.07%2013.7586Z%27%20fill%3D%27white%27%2F%253E%253Cpath%20d%3D%27M118.06%207.94098C119.491%207.94098%20120.978%208.33337%20120.978%2011.1366V14.893H120.063C119.608%2014.893%20119.238%2014.524%20119.238%2014.0689V10.9965C119.238%209.66506%20118.747%209.16047%20117.891%209.16047C117.414%209.16047%20116.797%209.52486%20116.502%209.81915V14.069C116.502%2014.1773%20116.481%2014.2845%20116.44%2014.3845C116.398%2014.4845%20116.337%2014.5753%20116.261%2014.6519C116.184%2014.7284%20116.093%2014.7891%20115.993%2014.8305C115.893%2014.8719%20115.786%2014.8931%20115.678%2014.8931H114.847V8.10918H115.773C115.932%208.10914%20116.087%208.16315%20116.212%208.26242C116.337%208.36168%20116.424%208.50033%20116.46%208.65577C116.881%208.19328%20117.428%207.94098%20118.06%207.94098ZM122.854%208.09713C123.024%208.09708%20123.19%208.1496%20123.329%208.2475C123.468%208.34541%20123.574%208.48391%20123.631%208.64405L125.133%2012.8486L126.635%208.64415C126.692%208.48402%20126.798%208.34551%20126.937%208.2476C127.076%208.1497%20127.242%208.09718%20127.412%208.09724H128.598L126.152%2014.3567C126.091%2014.5112%20125.986%2014.6439%20125.849%2014.7374C125.711%2014.831%20125.549%2014.881%20125.383%2014.8809H124.333L121.668%208.09713H122.854Z%27%20fill%3D%27white%27%2F%253E%253Cpath%20d%3D%27M135.085%2014.5514C134.566%2014.7616%20133.513%2015.0416%20132.418%2015.0416C130.496%2015.0416%20129.024%2013.9345%20129.024%2011.4396C129.024%209.19701%20130.451%207.99792%20132.191%207.99792C134.338%207.99792%20135.254%209.4378%20135.158%2011.3979C135.139%2011.8029%20134.786%2012.0983%20134.38%2012.0983H130.679C130.763%2013.1916%20131.562%2013.7662%20132.615%2013.7662C133.028%2013.7662%20133.462%2013.7452%20133.983%2013.6481C134.535%2013.545%20135.085%2013.9375%20135.085%2014.4985V14.5514ZM133.673%2010.949C133.785%209.87621%20133.061%209.28752%20132.191%209.28752C131.321%209.28752%20130.734%209.93979%20130.679%2010.9489L133.673%2010.949Z%27%20fill%3D%27white%27%2F%253E%253Cpath%20d%3D%27M137.345%208.11122C137.497%208.11118%20137.645%208.16229%20137.765%208.25635C137.884%208.35041%20137.969%208.48197%20138.005%208.62993C138.566%208.20932%20139.268%207.94303%20139.759%207.94303C139.801%207.94303%20140.068%207.94303%20140.489%207.99913V8.7265C140.489%209.11748%20140.15%209.4147%20139.759%209.4147C139.31%209.4147%20138.651%209.5829%20138.131%209.8773V14.8951H136.462V8.11112L137.345%208.11122ZM156.6%2014.0508V8.09104H155.769C155.314%208.09104%20154.944%208.45999%20154.944%208.9151V14.8748H155.775C156.23%2014.8748%20156.6%2014.5058%20156.6%2014.0508ZM158.857%2012.9447V9.34254H157.749V8.91912C157.749%208.46401%20158.118%208.09506%20158.574%208.09506H158.857V6.56739L160.499%206.10479V8.09506H161.986V8.51848C161.986%208.97359%20161.617%209.34254%20161.161%209.34254H160.499V12.7345C160.499%2013.2566%20160.795%2013.44%20161.177%2013.503C161.626%2013.5774%20162%2013.9024%20162%2014.3574V14.977C160.446%2014.977%20158.857%2014.9086%20158.857%2012.9447ZM98.1929%2010.1124C98.2033%206.94046%20100.598%205.16809%20102.895%205.16809C104.171%205.16809%20105.342%205.44285%20106.304%206.12953L105.914%206.6631C105.654%207.02011%20105.16%207.16194%20104.749%206.99949C104.169%206.7702%20103.622%206.7218%20103.215%206.7218C101.335%206.7218%2099.9169%207.92849%2099.9068%2010.1123C99.9169%2012.2959%20101.335%2013.5201%20103.215%2013.5201C103.622%2013.5201%20104.169%2013.4717%20104.749%2013.2424C105.16%2013.0799%20105.654%2013.2046%20105.914%2013.5615L106.304%2014.0952C105.342%2014.7819%20104.171%2015.0566%20102.895%2015.0566C100.598%2015.0566%2098.2033%2013.2842%2098.1929%2010.1124ZM147.619%205.21768C148.074%205.21768%20148.444%205.58663%20148.444%206.04174V9.81968L151.82%205.58131C151.897%205.47733%20151.997%205.39282%20152.112%205.3346C152.227%205.27638%20152.355%205.24607%20152.484%205.24611H153.984L150.166%2010.0615L153.984%2014.8749H152.484C152.355%2014.8749%20152.227%2014.8446%20152.112%2014.7864C151.997%2014.7281%20151.897%2014.6436%20151.82%2014.5397L148.444%2010.3025V14.0508C148.444%2014.5059%20148.074%2014.8749%20147.619%2014.8749H146.746V5.21768H147.619Z%27%20fill%3D%27white%27%2F%253E%253Cpath%20d%3D%27M0.773438%206.5752H2.68066C3.56543%206.5752%204.2041%206.7041%204.59668%206.96191C4.99219%207.21973%205.18994%207.62695%205.18994%208.18359C5.18994%208.55859%205.09326%208.87061%204.8999%209.11963C4.70654%209.36865%204.42822%209.52539%204.06494%209.58984V9.63379C4.51611%209.71875%204.84717%209.88721%205.05811%2010.1392C5.27197%2010.3882%205.37891%2010.7266%205.37891%2011.1543C5.37891%2011.7314%205.17676%2012.1841%204.77246%2012.5122C4.37109%2012.8374%203.81152%2013%203.09375%2013H0.773438V6.5752ZM1.82373%209.22949H2.83447C3.27393%209.22949%203.59473%209.16064%203.79688%209.02295C3.99902%208.88232%204.1001%208.64502%204.1001%208.31104C4.1001%208.00928%203.99023%207.79102%203.77051%207.65625C3.55371%207.52148%203.20801%207.4541%202.7334%207.4541H1.82373V9.22949ZM1.82373%2010.082V12.1167H2.93994C3.37939%2012.1167%203.71045%2012.0332%203.93311%2011.8662C4.15869%2011.6963%204.27148%2011.4297%204.27148%2011.0664C4.27148%2010.7324%204.15723%2010.4849%203.92871%2010.3237C3.7002%2010.1626%203.35303%2010.082%202.88721%2010.082H1.82373Z%27%20fill%3D%27white%27%2F%253E%253Cpath%20d%3D%27M13.011%206.5752V10.7324C13.011%2011.207%2012.9084%2011.623%2012.7034%2011.9805C12.5012%2012.335%2012.2068%2012.6089%2011.8201%2012.8022C11.4363%2012.9927%2010.9763%2013.0879%2010.4402%2013.0879C9.6433%2013.0879%209.02368%2012.877%208.5813%2012.4551C8.13892%2012.0332%207.91772%2011.4531%207.91772%2010.7148V6.5752H8.9724V10.6401C8.9724%2011.1704%209.09546%2011.5615%209.34155%2011.8135C9.58765%2012.0654%209.96557%2012.1914%2010.4753%2012.1914C11.4656%2012.1914%2011.9607%2011.6714%2011.9607%2010.6313V6.5752H13.011Z%27%20fill%3D%27white%27%2F%253E%253Cpath%20d%3D%27M15.9146%2013V6.5752H16.9649V13H15.9146Z%27%20fill%3D%27white%27%2F%253E%253Cpath%20d%3D%27M19.9255%2013V6.5752H20.9758V12.0991H23.696V13H19.9255Z%27%20fill%3D%27white%27%2F%253E%253Cpath%20d%3D%27M28.2828%2013H27.2325V7.47607H25.3428V6.5752H30.1724V7.47607H28.2828V13Z%27%20fill%3D%27white%27%2F%253E%253Cpath%20d%3D%27M41.9472%2013H40.8046L39.7148%209.16796C39.6679%209.00097%2039.6093%208.76074%2039.539%208.44727C39.4687%208.13086%2039.4262%207.91113%2039.4116%207.78809C39.3823%207.97559%2039.3339%208.21875%2039.2665%208.51758C39.2021%208.81641%2039.1479%209.03905%2039.1039%209.18554L38.0405%2013H36.8979L36.0673%209.7832L35.2236%206.5752H36.2958L37.2143%2010.3193C37.3578%2010.9199%2037.4604%2011.4502%2037.5219%2011.9102C37.5541%2011.6611%2037.6025%2011.3828%2037.6669%2011.0752C37.7314%2010.7676%2037.79%2010.5186%2037.8427%2010.3281L38.8886%206.5752H39.9301L41.0024%2010.3457C41.1049%2010.6943%2041.2133%2011.2158%2041.3276%2011.9102C41.3715%2011.4912%2041.477%2010.958%2041.644%2010.3105L42.558%206.5752H43.6215L41.9472%2013Z%27%20fill%3D%27white%27%2F%253E%253Cpath%20d%3D%27M45.7957%2013V6.5752H46.846V13H45.7957Z%27%20fill%3D%27white%27%2F%253E%253Cpath%20d%3D%27M52.0258%2013H50.9755V7.47607H49.0859V6.5752H53.9155V7.47607H52.0258V13Z%27%20fill%3D%27white%27%2F%253E%253Cpath%20d%3D%27M61.2312%2013H60.1765V10.104H57.2146V13H56.1643V6.5752H57.2146V9.20312H60.1765V6.5752H61.2312V13Z%27%20fill%3D%27white%27%2F%253E%253C%2Fsvg%253E%22%29%3B%7D%40-webkit-keyframes%20formkit-bouncedelay-formkit-form-data-uid-4e7d7814f1-%7B0%25%2C80%25%2C100%25%7B-webkit-transform%3Ascale%280%29%3B-ms-transform%3Ascale%280%29%3Btransform%3Ascale%280%29%3B%7D40%25%7B-webkit-transform%3Ascale%281%29%3B-ms-transform%3Ascale%281%29%3Btransform%3Ascale%281%29%3B%7D%7D%40keyframes%20formkit-bouncedelay-formkit-form-data-uid-4e7d7814f1-%7B0%25%2C80%25%2C100%25%7B-webkit-transform%3Ascale%280%29%3B-ms-transform%3Ascale%280%29%3Btransform%3Ascale%280%29%3B%7D40%25%7B-webkit-transform%3Ascale%281%29%3B-ms-transform%3Ascale%281%29%3Btransform%3Ascale%281%29%3B%7D%7D.formkit-form%5Bdata-uid%3D%224e7d7814f1%22%5D%20blockquote%7Bpadding%3A10px%2020px%3Bmargin%3A0%200%2020px%3Bborder-left%3A5px%20solid%20%23e1e1e1%3B%7D.formkit-form%5Bdata-uid%3D%224e7d7814f1%22%5D%20.seva-custom-content%7Bpadding%3A15px%3Bfont-size%3A16px%3Bcolor%3A%23fff%3Bmix-blend-mode%3Adifference%3B%7D.formkit-form%5Bdata-uid%3D%224e7d7814f1%22%5D%20.formkit-modal.guard%7Bmax-width%3A420px%3Bwidth%3A100%25%3B%7D%20.formkit-form%5Bdata-uid%3D%224e7d7814f1%22%5D%7Bbox-shadow%3A0%202px%2015px%200%20rgba%28210%2C214%2C220%2C0.5%29%3Bmax-width%3A700px%3Boverflow%3Ahidden%3B%7D.formkit-form%5Bdata-uid%3D%224e7d7814f1%22%5D%20%5Bdata-style%3D%22full%22%5D%7Bwidth%3A100%25%3Bdisplay%3Ablock%3B%7D.formkit-form%5Bdata-uid%3D%224e7d7814f1%22%5D%20.formkit-header%7Bmargin-top%3A0%3Bmargin-bottom%3A20px%3B%7D.formkit-form%5Bdata-uid%3D%224e7d7814f1%22%5D%20.formkit-subheader%7Bmargin%3A15px%200%3B%7D.formkit-form%5Bdata-uid%3D%224e7d7814f1%22%5D%20.formkit-column%7Bpadding%3A20px%3Bposition%3Arelative%3B%7D.formkit-form%5Bdata-uid%3D%224e7d7814f1%22%5D%20.formkit-column%3Anth-child%282%29%7Bborder-top%3A1px%20solid%20%23e9ecef%3B%7D.formkit-form%5Bdata-uid%3D%224e7d7814f1%22%5D%20.formkit-background%7Bwidth%3A100%25%3Bheight%3A100%25%3Bposition%3Aabsolute%3Btop%3A0%3Bleft%3A0%3Bbackground-size%3Acover%3Bbackground-position%3Acenter%3Bopacity%3A0.5%3Bz-index%3A1%3B%7D.formkit-form%5Bdata-uid%3D%224e7d7814f1%22%5D%20.formkit-header%2C.formkit-form%5Bdata-uid%3D%224e7d7814f1%22%5D%20.formkit-subheader%2C.formkit-form%5Bdata-uid%3D%224e7d7814f1%22%5D%20.formkit-image%7Bz-index%3A2%3Bposition%3Arelative%3B%7D.formkit-form%5Bdata-uid%3D%224e7d7814f1%22%5D%20.formkit-field%7Bmargin%3A0%200%2015px%200%3B%7D.formkit-form%5Bdata-uid%3D%224e7d7814f1%22%5D%20.formkit-input%2C.formkit-form%5Bdata-uid%3D%224e7d7814f1%22%5D%20.formkit-submit%7Bwidth%3A100%25%3B%7D.formkit-form%5Bdata-uid%3D%224e7d7814f1%22%5D%20.formkit-guarantee%7Bfont-size%3A13px%3Bmargin%3A0%200%2015px%200%3B%7D.formkit-form%5Bdata-uid%3D%224e7d7814f1%22%5D%20.formkit-guarantee%20%3E%20p%7Bmargin%3A0%3B%7D.formkit-form%5Bdata-uid%3D%224e7d7814f1%22%5D%20.formkit-powered-by-convertkit-container%7Bmargin-bottom%3A0%3B%7D.formkit-form%5Bdata-uid%3D%224e7d7814f1%22%5D%5Bmin-width~%3D%22600%22%5D%20%5Bdata-style%3D%22full%22%5D%2C.formkit-form%5Bdata-uid%3D%224e7d7814f1%22%5D%5Bmin-width~%3D%22700%22%5D%20%5Bdata-style%3D%22full%22%5D%2C.formkit-form%5Bdata-uid%3D%224e7d7814f1%22%5D%5Bmin-width~%3D%22800%22%5D%20%5Bdata-style%3D%22full%22%5D%7Bdisplay%3Agrid%3Bgrid-template-columns%3Arepeat%28auto-fit%2Cminmax%28200px%2C1fr%29%29%3B%7D.formkit-form%5Bdata-uid%3D%224e7d7814f1%22%5D%5Bmin-width~%3D%22600%22%5D%20.formkit-submit%2C.formkit-form%5Bdata-uid%3D%224e7d7814f1%22%5D%5Bmin-width~%3D%22700%22%5D%20.formkit-submit%2C.formkit-form%5Bdata-uid%3D%224e7d7814f1%22%5D%5Bmin-width~%3D%22800%22%5D%20.formkit-submit%7Bwidth%3A100%25%3B%7D.formkit-form%5Bdata-uid%3D%224e7d7814f1%22%5D%5Bmin-width~%3D%22600%22%5D%20.formkit-column%2C.formkit-form%5Bdata-uid%3D%224e7d7814f1%22%5D%5Bmin-width~%3D%22700%22%5D%20.formkit-column%2C.formkit-form%5Bdata-uid%3D%224e7d7814f1%22%5D%5Bmin-width~%3D%22800%22%5D%20.formkit-column%7Bpadding%3A40px%3B%7D.formkit-form%5Bdata-uid%3D%224e7d7814f1%22%5D%5Bmin-width~%3D%22600%22%5D%20.formkit-column%3Anth-child%282%29%2C.formkit-form%5Bdata-uid%3D%224e7d7814f1%22%5D%5Bmin-width~%3D%22700%22%5D%20.formkit-column%3Anth-child%282%29%2C.formkit-form%5Bdata-uid%3D%224e7d7814f1%22%5D%5Bmin-width~%3D%22800%22%5D%20.formkit-column%3Anth-child%282%29%7Bborder-top%3Anone%3B%7D%20%3C%2Fstyle%3E%3C%2Fform%3E[/vc_raw_html]

Episode Transcript:

Elizabeth Larrick: Hello, and welcome back to the Trial Lawyer Podcast. I am your host, Elizabeth Larrick, and today we have a treat.

We have a guest joining us. Kiela Linroth Pace is joining us. She and I Missed each other at a happy hour, but I [00:01:00] got her information and I had to have her come speak at the capital area trial lawyers association, which she did. And I’m so grateful she did. And after that, I’ve been following her on LinkedIn and I just love all her posts.

And recently she had a little post that caught my eye and I thought, Ooh, she needs to come on the podcast and tell all us trial lawyers about what she does. So thank you so much for joining the podcast. Thank you for inviting me. I’m excited to 

Kiela Linroth Pace: be here. 

Elizabeth Larrick: Yeah. So this post about being special counsel. So first of all, they know a little bit about you because we did a little bit of a bio background, but what does that mean?

I’m totally intrigued. Tell us a little bit. 

Kiela Linroth Pace: Right. It’s a new offering for me and it’s joining my two worlds, if you will, because of course I had a 20 plus year career as a litigator specifically I did domestic violence defense, which is criminal law. And of course, over the course of my business development journey, I also.

grew my solo practice into a boutique law firm. So in addition to the criminal law [00:02:00] background, especially a deep dive on domestic violence defense, there was law firm administration, building, running, directing the team, et cetera, that I did in that world. And up until recently, I thought that, I was leaving that behind to transition a shift gears into coaching, which originally started within my firm.

And then I ultimately decided that I actually wanted it to shift to a different audience. My ideal clients these days are lawyers rather than people who’ve been arrested for domestic assault. And what’s happened is I made this leap of faith. To just shut down my law firm at one point, I had been trying to run it while launching my coaching practice.

And it wasn’t really working very well for me. I know some people are successful in doing that, but I got to a point where I was like, you know what, I’m going to have to just give this my all. And so I just made that decision and started winding down my law firm. And that has been a long process that’s taken close to two years now, definitely over 18 months, somewhere in there.

And as I’ve wound down the law firm, of course, that [00:03:00] also has meant that my income is reducing because I’m very much in startup mode with my coaching practice. And even though that’s going well, now I’m at a point where I have more time. Because my caseload has shrunk. I’ve got one case left. I’m so excited.

And so congrats. Thank you. Yeah, it’s really exciting. And in the meantime, I developed myself as a speaker. I’ve been doing, in fact, that’s how you and I met. Of course, that’s been great fun, but I do need to supplement my income while I keep going. And so in thinking about, look, how do we want to do that?

Something that’s aligned, something that’s. For me, given my talents and strengths and whatnot, easy, lucrative and fun. And it still allows me a plenty of time to work on my coaching practice to both the marketing of it, the fulfillment for my existing clients and new clients and whatnot. So what came to mind, it was really an epiphany is thinking back to where I was in 2015 when I started my business development journey.

It was so hard to make the time that I needed to make to do all the things, right? So I [00:04:00] knew I needed to do things like hire and learn to hire, much less the actual implementation of it. And then there were all the things I was already doing that were necessary to provide the quality of representation that I wanted to for my clients.

And so just finding the time to actually implement. All of this new stuff. I was learning to continue doing the things before I was able to Things that legal work right before I was able to package it and deliver it to A qualified individual who I had hired or brought on whether that’s a staff member or a new vendor or whatever And so that was where the light bulb went off because it was like how awesome would it have been?

At that time, if I had some had somebody like me who was available to come in and delegate things to somebody I could trust to operate independently, someone who’s got their eye on the ball, both with regard to the quality of representation, as well as like the healthy development of a law practice. And especially if it’s moving into a small law firm.

So that was [00:05:00] it. And I’m so excited because it was like, Oh, my gosh, This is something I can do. This isn’t that would actually be a great help to some of my existing clients, future clients. And I’m happy to do this kind of work. And it really allows me to pick and choose. And I’m, I only have a small number of seats because I’m not available for a lot of time.

And it’s just me doing this work at this point. But if this goes well, this may actually be something that I train other people to come in and do and provide this type of assistance. But for now, It is just me and I have folks I’ve been talking to who are excited, but I’m just now launching it. It’s basically another startup.

Elizabeth Larrick: Awesome. And what I heard you say, what I think a lot of it will probably peak a lot of people who listen here, which is hiring, which is always a dreaded task. And I will of course, speak for myself running a law firm than doing what I do now. There’s always just so many pitfalls you can make. And so tell us a little bit more about that part of it.

As far as. That role that you take on or relieve some pressure in that area. 

Kiela Linroth Pace: It’s really going to depend on the needs, the [00:06:00] specific needs of each individual that I’m working with as to how comfortable they are with different aspects. Some people are more advanced in having hired people, having an idea of what their process is, who they want to work with and so forth.

But some people are going to be like I was. And honestly, before I started down the business development journey and Started doing business coaching. I was afraid of hiring. I had such a fear of hiring that I went for many years without hiring anybody. And when I finally realized I needed to, I actually went out and hired my husband.

I brought him in to my practice, Ben’s husband, I should say. He was a software developer, but he had a lot of strengths when it came to. It’s a law because of his family background. And so that was a good move in some ways and not so great in other ways. Cause I really didn’t know what I was doing when it came to hiring.

And even that, when you bring somebody in who’s close to you, it’s just as important that learn how to do this properly, how to be clear about what the job description is, what their role is, that sort of thing. And so what I’m talking [00:07:00] about, if somebody wants me to help them with hiring, probably the first step, and it’s going to, again, depend on where they are, how.

Pressing it is for them how overloaded and overwhelmed they are because it might start with I whatever it is that you need help with I take it off your plate first And do it myself so that I can get a good feel for what’s involved I might help you write some policies and procedures that are going to be helpful for somebody else because Ultimately, you probably want, depending on what the nature of the work is, you probably want me to peel it off, get it packaged, and then delegate it to somebody else, help you bring somebody on board.

Now that might be a direct hire employee, or it might be a vendor. For example, there are a lot of companies these days that provide a virtual assistance, including in the legal sphere. There’s some companies that focus on lawyers and being able to actually delegate well. To any of those providers, whether it’s a staff member or a vendor, that’s something I’m going to probably be better poised to do than most folks who haven’t gone down this business development journey.

So I can [00:08:00] do that. And like really any part of that process that they need help with, I can help them. 

Elizabeth Larrick: Yeah. And I would say most people. Most lawyers and solos or small firms are ready to hire right now. And they’re just not. And you know, it’s one of the biggest things that last 

Kiela Linroth Pace: year, 

Elizabeth Larrick: yeah, is people are just, and again, I get it.

We’re we, we are the business and we work on it and in it, as they always say. And I always cringe when I hear sometimes listening on podcasts or other stuff where people say, wait to hire and tell. And I’m like, no, because I did that for so long too. And just waited and just. Hire ahead, look ahead at that kind of stuff and get ready for it.

So I love that the delegating, I feel like that is such a skill. We have a skill we have to learn, especially as lawyers. 

Kiela Linroth Pace: It is, it is, and it can really be painful when you don’t know and don’t have a clue how to do it yet. And, and you do start hiring because you’re absolutely right. Sometimes you have to just get in there and do it and figure it out and [00:09:00] be prepared to make mistakes and then correct and make adjustments and whatnot.

But it can be. Challenging and problematic. When you hire somebody, you make that commitment with the idea that I’m going to be able to afford to pay this person because they’re going to take things off my plate that I’ll be able to do more lucrative things. Bring in more money. That’s true, but it can be tough to get from the point of where it’s a payout to it’s actually paying for itself if you don’t know how to delegate properly, if you don’t know, and it can cause other problems.

And it certainly did for me in my business. When I talk about or when I think about what I call team building round one, Where there were some accountability issues. There were some things that I didn’t really know how to do well. And so even though it seemed like we were doing well for a couple of years, ultimately there were some internal problems that I discovered after I had a couple of people leave.

And that’s when I’m going through and picking up the pieces and going, Oh, wow. That person who just quit without notice it’s too bad. I didn’t know what I know now about what was going on when they were 

Elizabeth Larrick: here, 

Kiela Linroth Pace: because that would have fired them. [00:10:00] 

Elizabeth Larrick: Yeah. Or just known like they weren’t ever going to be a good fit.

From the jump, because I’ve definitely done that, 

Kiela Linroth Pace: too. 

Elizabeth Larrick: We could definitely, I feel like spend most of our time talking about that. And I only touch on that so much because I feel like. I’m always hearing on listservs and from people like, Hey, I need this associate, or I’m looking for this paralegal, or is it, and it’s what systems do you have in place?

Where are you looking for? And we, I think as business owners can get so bogged down with that, that. Cause we’re working and then we’re just like, Oh, we need to have a system or policies or, or clearly written job descriptions that it’s, Oh yeah. And that takes so much time. I’m glad to hear that as something that you are passionate about.

Kiela Linroth Pace: Yeah, I actually love systems and spreadsheets and all kinds of stuff that a lot of people hate. 

Elizabeth Larrick: Yeah, sometimes it just feels over this overwhelming burden of wait a second. I just need to solve this problem, but now you’re telling me to have these six other things in place [00:11:00] before I can solve that problem.

But there’s a method to the madness. Let me ask you, if you want to step into this place and kind of help law firm owners, what are you seeing are some of the mistakes? Again, as being a law firm owner, just watching other people or having people in your coaching program, what are the mistakes that you’re seeing people make that are really directly impacting their ability to grow their business?

Kiela Linroth Pace: It’s not one that’s intuitive. The one that I see across the board, whether we’re talking about a solo or a small law firm owner, or even on up to bigger enterprises, the biggest mistake that I see is the one that I made myself. And that is neglecting themselves and their personal development. And we talked about delegating.

They also tend to resist delegating. You know, it’s a related issue, right? You’re taking on too much. You are typically most of the people that we’re talking about long, long past when they should have been looking at a way to take some of this stuff off their plate. Now they’re at this max capacity. And the problem is that when you’re, I’m like entrepreneurialism [00:12:00] and let me back up, let’s be clear.

A lot of lawyers I think don’t know this, but running a law firm, building a law firm is an entrepreneurial activity. It’s business. It’s not really law anymore. It’s business. And the thing about entrepreneurialism is that. Like true success, at least the way that I see it and that I define it now requires resilience.

It requires creativity and these are qualities that it’s hard to develop. It’s hard to maintain. It’s hard to embody them. If you’re anxious, if you’re overworked, if you’re overwhelmed, if you’re burned out and I was no exception even after, and this is the sad part, even a couple of years into my business development journey when I was working with some really great coaches and I was being taught all these wonderful lessons.

Technical lessons, really more about, about business. I was still neglecting my personal development. And so ultimately what happened is I got stuck and I couldn’t see the problem. I couldn’t see why I couldn’t progress. I had gotten to a certain point. I had [00:13:00] built a team. I had taken out commercial leases, all these things.

My gross revenues were hugely increased over where I had started. And it wasn’t that I wasn’t taking it seriously. I was working hard to learn, to implement. And in hindsight, I can say I was working too hard. And again, that’s that point at which I was neglecting myself, you know, doing all these things and they were great things, but I was never going to get past that particular point if it didn’t stop and create some space for myself.

Take care of myself, right? Because the solutions, they actually require that your brain have the space, have the time, have the energy. Contrary to everything else I’d accomplished up to that point in my life, really, it was never going to be solved by just throwing myself at the problem by working harder and harder.

So that’s why I say it’s counterintuitive. And I think that’s the biggest mistake that most people make. 

Elizabeth Larrick: Yeah. And hands down. One of the favorite things that I always hear is what got you here, won’t get you there. And it’s exactly right. You get to a point where you can run a keep [00:14:00] ramp against the wall.

This definitely has happened to me. And then at some point, like you said, somebody comes from completely out of left field and is like, Oh, it’s that. And you’re like, Oh, 

Kiela Linroth Pace: blind spot. 

Elizabeth Larrick: Wow. And I, man, I couldn’t have spotted it. And that’s why I love having a coach, having an outside perspective of somebody being able to come in and be like, Hey, Elizabeth, it’s this thing right here.

Oh man. Okay. So stop, go address this thing. That’s this limiting belief, this story you keep telling yourself, this thing that’s sabotaging what’s going on in day life. And you can’t figure it out. You like you said, you’re working harder at the problem and you’re not getting anywhere. Absolutely. A hundred percent preaching the choir on that personal development.

And I also appreciate you sharing, like you were doing all the things business wise, right. Doing all the things. And it was successful. Like you said, there’s always going to be some place that you get stopped. 

Kiela Linroth Pace: Yeah. 

Elizabeth Larrick: And having somebody else look at it always is really helpful. [00:15:00] And it sounds like that’s like, you want to bring in that outside perspective to help other law firms be able to see, Oh, Hey, here, you think this is the problem?

No, here is the actual bottleneck. So let’s figure this out. 

Kiela Linroth Pace: Yeah, that’s what I do as a coach and a consultant. That’s part of what I do as a coach and consultant. And that’s different work really. The freelance services, the special counsel role is a little bit different because it’s more about the implementation, right?

So as a coach, when I’m working with somebody and I might help them come up with an idea, or I might just get them on the right path so that they can come up with the idea that they need, but it’s up to them to implement it. I’m not going to actually do the work. They do the work. This is, in fact, this is something I like to tell people, respective clients when we’re talking about the possibility of working together.

Um, one of the things I want to make clear to them is one of the big differences between law and coaching is that in law, The lawyer has a lot of control over the end result and we can’t make the facts, [00:16:00] we can’t make the law and certainly our clients can do a lot to either help or hinder us in getting to the best possible result.

But in coaching, it’s actually the client who has to do the heavy lifting. Right. The, the coach is a guide, merely a guide, but the client is really the one that has to be responsible. The coach cannot do it for them. And so one of the differences here when it comes to special counsel, and this is a very, like I said, I have a limited amount of time and hours that I’m willing to put into this, but I can actually help them implement and that’s the difference because that was the thing when I was I have been working with coaches that I, I really w wanted, wished that I had somebody who knew what’s what, who could actually help me do that stuff, do the work.

And that’s the difference here. 

Elizabeth Larrick: Gotcha. And that makes so much sense. And I, I appreciate you clarifying that because that’s. We want implementation, even sometimes when we have a coach, it’s like picking up that amazing book that everybody loves. Let’s take Atomic Habits. That’s an amazing book, but it does nothing for you if you’re not going to [00:17:00] actually implement what it says in there.

Kiela Linroth Pace: First, you have to actually study it, not just read it, right? You can read a book and then put it back on your shelf and go on with your merry life and think, that was great. But it’s not going to get you anywhere. You first, you have to study it. And then you also have to do the exercises, whatever it is that they’re recommending that you do.

If you don’t actually do that part, the difference between reading and studying, like I have a whole little lesson for clients. 

Elizabeth Larrick: It’s such a huge deal. And I will say one of my favorite apps that I’ve gotten into is called Readwise. And I love a paper book, but I love Readwise because it’s, In wherever, whatever you’re reading on Kindle or wherever you can highlight, it goes into read wise.

And then every day you do a little review and it’s your little quotes. And I’m like, Oh yeah, I forgot about that. So it’s so helpful because just those little gentle reminders, but I try to have for myself again to know, Hey, I studied this. Don’t forget about it, but. Well, let’s keep going here. Let me get us back on track there.

Okay. So I know [00:18:00] business owners, law firm, we all need just more time in our day. I always hear from all my folks that work with, I’m just so busy or I don’t have enough time. What are things that you suggest or that you teach that kind of give people back their time? 

Kiela Linroth Pace: Okay. Specifically for lawyers, I have three.

I guess my, my, my top three suggestions, lawyers generally, but I would say especially litigators in the example that I’m going to give the first one I would say is learn to set healthy boundaries. Now I actually did a workshop on this topic last summer because it was requested so much by my local attorney mom group.

And that’s actually where. Um, my interest in coaching layers came from this large group of women. We probably have about 1500 members at this point, a very active Facebook group. And I had already done a mindset mastery one on one workshop for them just to help them understand this framework, the stuff that I do, that I practice these days that I teach and that, that went well, it was very well received.

But I was asking them like, okay, look, I have a couple of ideas about what’s next [00:19:00] in terms of topics, but how about you help me help you by letting me know. What do you need to know about? What do you want to know? And this was the thing that, this was my idea, and it was very well received. And along with that, they also said, and we’re not going to get into this, but imposter syndrome, right?

So healthy boundaries was the very next workshop that I did because it was so important. Much a problem for me in the earlier days of my, and also so much a problem for these attorneys that I was talking to and working with. So the UT Law CLE, they have an online catalog and there’s, it’s called setting boundaries with clients and colleagues.

This is the workshop that I did. And just to be clear, my role as a faculty member with UT Law CLE is basically. Completely volunteer. So I don’t get any money by recommending their workshops, but they do have some great content and this is one of the ones I’d recommend. And one of the examples that I talk about in that workshop that is to me is so clear, it’s, I think it’s probably clear for any litigator about where boundaries can come [00:20:00] into play is in the early days for me, when I was in court all the time.

The early days of my practice as a criminal defense attorney, I had no idea that I could and should set any boundaries when it came to scheduling. Specifically when for criminal defense attorneys, they have court coordinators and judges throwing dates at them right and left in multiple courts all day long.

I shouldn’t say all day long, all morning, mostly court is in the morning from like 9am to noon, but they might appear in multiple different courts and they get reset, meaning they’re in court today. And when they. Wrap up their business for the day on this particular case, the court coordinator or the judge throws a date at them and quite often they just take that date and they write it down and it goes in their calendar and they’re back.

Whatever random date was just thrown at them and then same thing to some extent with a contested hearing or trial and they’ll look at their calendar to make sure they don’t have an absolute conflict, right? Oh, I’m going to be in another county that day with a hearing or whatever. I can’t, I’m not going to do that.

But what I didn’t realize and so many attorneys don’t [00:21:00] realize. Especially the younger they are, the less experienced they are, is I could actually set boundaries. You know what? I need time to do my out of court work during business hours. So I can’t appear in court every single day of the week. That’s just so disruptive.

I can’t get anything else done if that’s what I’m doing. And so I learned to start doing things like, and there’s some trial and error here. You might have to experiment, but like taking Mondays off and not off from work, but off from court where Mondays was. And what I learned for that to be is by business and personal development.

As well as things like business errands, personal errands. This was my default day of the week. If I needed to schedule a doctor’s appointment or something specific that I need to do for my kids. And so that’s, to this day, that’s the day that I favored for that. Then Fridays I learned I absolutely couldn’t.

This is where the trial and error comes in and your specific circumstances matter. I was in court for, which is the domestic violence court in Travis County, a specialized court. And since by that point. I probably had, by the point I was doing this, I probably had 85 [00:22:00] percent of my cases were in that court.

And so I couldn’t take Fridays off because that’s when they did protective orders. That’s when the biggest docket was for the criminal cases. That’s whatever. So Friday was definitely one of my court days, my court heavy days, if you will. And then the afternoons, Tuesday, and I still favor this scheduling probably because of this background, but grouping my, you know, calls, so setting boundaries with clients about when I’m available to get on the phone.

Right. Obviously they need to be able to talk to me. I need to be able to answer their questions. You need to be able to get back to them quickly. But that doesn’t mean that I have to accept a call right now in this instant when I’m working on something else. So setting boundaries with clients where you say, no, I’m available outside of an emergency.

I’m available for office hours, whether that’s a meeting or it’s a phone call, or maybe it’s a zoom, a virtual meeting Tuesday through Friday from 2 p. m. to 6 p. m. or whatever it is. I’m just throwing out. What my times tend to be, but everybody’s life is a little different. What days work best for you and whatnot.

But the most [00:23:00] important thing here is that number one is learning to set healthy boundaries. And there’s a whole process for doing that. If you don’t know how to do it already, makes you the most effective. That’s what this workshop is about. So when I was asked, please. Help us learn how to do this. I sat down and said, all right, so when I learned how to do this effectively, what were the steps, what was involved?

Because this is actually a mindset challenge. It may not seem like it may seem very practical, but you know, how to actually go about setting boundaries effectively is a mindset challenge. So that’s number one. Should I just go on to number two or do you have questions? I know I just rattled. Oh, no, no questions.

Elizabeth Larrick: Yeah. I was just going to say one of the healthiest boundaries that I ever sat in my business and I still had to, is I take no cold calls. 

Kiela Linroth Pace: Yes. 

Elizabeth Larrick: No 

Kiela Linroth Pace: cold. I totally agree with that. Yes, absolutely. And this was actually like that first group that I belonged to that provided business coaching for lawyers.

They taught me that. And it was a hard sell for me at first. And it is a hard sell for a lot of lawyers like they, and a lot of my ideal hire, I call them hiring attorneys, right? So [00:24:00] an attorney who’s looking at hiring me to do freelance work, to come in as special counsel, that’s a hiring attorney as to distinguish them from a client who’s hiring me to do them like a non lawyer who’s hiring me to do legal work for them, which I’m not really available to do any more of that.

Or an attorney who maybe it’s hiring me as a coach. So an ideal hiring attorney for me is somebody who really cares about the clients and really cares about the quality of representation they’re providing. And there’s this mindset that goes along with that. Oftentimes that you have to be available like now, and you have to be willing to drop everything to talk to the client in order to provide what the client needs in order to provide the high quality of representation and care that’s necessary.

And I’m here to tell you, that’s not true. That’s a limiting belief. Right there. And it’s one that is really destructive actually because it ends up meaning that you don’t have the time and energy. You get constantly interrupted even when you need to be doing work for your clients, right? Like when you would be best served and your clients would be best served for you having two [00:25:00] uninterrupted hours each day when you’re at your optimal.

For me, that’s typically like 10 a. m. to 12 p. m. when I am like, On point mentally. And that’s why I typically won’t take calls during that time. I won’t schedule calls or meetings. And so that’s something that, and there are tools there, a have a good assistant or paralegal, right? Who can provide a lot of the information and the contact that the client needs and then get back to them quickly.

Yes, I agree. And another thing that I like to do is I’ll return calls during a certain block. Right. Somebody called. I might try to call them back during my times during the office hours, but I’m not ever outside of an emergency going to take a call. Not typically not. And it’s not that I don’t care. It’s actually because I do care because I’m trying to conserve my energy so that I can be on point and focused only on that client and that client’s work when I need to be.

Elizabeth Larrick: Exactly. Yeah. I have a virtual receptionist that I call my iron curtain because they don’t let anybody get through unless it’s a judge. Cause all I do is, all I did was civil law. So [00:26:00] it never, there’s no emergencies in civil law. So. 

Kiela Linroth Pace: Ah, you didn’t do family law. I take it. No, absolutely not. No way. Cause that’s, it’s funny.

Cause a lot of people, when they hear me say domestic violence defense, they. Later, well, they’ll think I said family law. Oh God, no, I will not touch family law with a 10 foot ball. That’s even though they’re very comparable, family law is the closest you’re going to get to DV and vice versa. But there are some dynamics in family law that I, even as a criminal defense attorney, it was like, Nope, I’m not doing that.

Elizabeth Larrick: Yeah. I, I bless those people who do family law. Cause there’s a big need for it, but it just was, there is totally, 

Kiela Linroth Pace: they are truly the, yeah, they’re the. Angels and the people who love it and the people who do such a great job. It’s completely necessary and it can help those people, but this is an important part of like special counsel.

The folks who are doing family law, one thing that’s important to understand, if you’re interested in working with me, be aware that one of my policies is I am not signing [00:27:00] on as attorney of record. And as a general rule, I’m not going to be the primary one interfacing with the clients. Yeah. 

Elizabeth Larrick: Yeah. Those are my boundaries.

You’re trying to help the business, not the 

Kiela Linroth Pace: work 

Elizabeth Larrick: of the business. The business, 

Kiela Linroth Pace: the business owner. Yeah. And I might be available for things like, I’m really good at talking people off a ledge and sometimes that’s necessary in family law. That was sometimes necessary in criminal law as well. So it’s one thing to come in as a pinch hitter.

To assist in certain ways. And sometimes a client can benefit from hearing it from a different voice. And I get that, but yeah, no, I’m not going to become the one for your 

Elizabeth Larrick: clients. Special counsel does not mean that. 

Kiela Linroth Pace: Exactly. Exactly. Let’s see. We have number two, shall we? 

Elizabeth Larrick: Yeah. Keep going. Yeah. Yeah. What other, and again, just to get suggestions to get your, get some time back.

Kiela Linroth Pace: Exactly. So setting those healthy boundaries should get you some time that now you can turn your attention to number two. And these were, I’m saying these in the order that I actually mastered them in my own life. [00:28:00] Setting boundaries is a great place to start to get you some of your time back. And then you can take some of the time that it’s going to take a little bit more time at first, but I promise you it will get you back more time.

And that’s learning to delegate effectively. We talked about that a little earlier. So finding and delegating to Qualified team members or vendors. And sometimes vendors can actually end up being team members for you, depending on how that’s structured, like a virtual assistant. Sometimes you have a dedicated person or they may not be dedicated.

They may work on other people’s accounts, but they work regularly for you on an ongoing basis. And actually I would be another good example as special counsel. If I do regular routine work for a client, even though I’m a vendor. I can actually become a team member. And in fact, in the case of somebody who wants to guarantee a certain number of hours, they can actually even put me on their website and that can be helpful and beneficial.

But here’s the thing. Not knowing how to do this well, right? So it’s a great way to leverage your knowledge, your experience, but [00:29:00] only if you learn to do it well. So I’m going to provide a tip here that one, there was a book that was recommended to me by, I think it was one of the coaches that I was working with at the time.

That was a fantastic resource for me. And that is, it’s called the one minute manager. By Ken Blanchard and Spencer Johnson. This was huge for me. It’s a pretty easy read. It’s a fairly small book, but it was game changing in terms of helping me delegate better to other people in a way that they actually took responsibility for the problem and where I refused to take responsibility for the problem, right?

The problem actually ended up being. They called it a monkey. I loved this. So I’m giving them a monkey. They don’t get to give back the monkey to me. I can talk to them about the monkey. I can make suggestions. And usually I’m going to ask questions like helping guide them. That’s my job. That becomes my job as the manager.

So it’s just a fantastic book. And it’s been a long time since I read it and implemented it. But I remember that it made such a big difference and absolutely gave me a whole bunch of time back because at that point, I was having trouble where [00:30:00] I had hired people who needed me so much that it’s almost like I had created more work for myself initially.

So before you even hire you, if you haven’t hired anybody yet, before you even make your first hire, read this book. That’s what I would say. 

Elizabeth Larrick: Absolutely. I definitely have read it. It’s super short and the way that it’s written is very easy. It’s a story plus little, it’s super great. Same people who did, who moved my cheese.

Another very, I love that too. Yeah. Short and sweet. And that’s, I, he has a whole series. I know that the one minute manager can Blanchard and Spencer Johnson have a whole series, but of one minute, all kinds of stuff, but yeah, great recommendations, super easy to read and short, and you can reread it again and study it easily as well.

So. 

Kiela Linroth Pace: Yes. I honestly, so I’m back in startup mode. And when I start hiring my own team members again, I’m probably going to go back and read it. And actually, here’s another tip. This is an aside. This is a bonus. Some of the best resources for business and [00:31:00] personal development, put them on your shelf and come back to them.

Like, You’ll get more out of it if you read it again later. So if you start feeling like I’m struggling in this area again, go back to one of those foundational resources that helped you so much the first time around, because most likely, because you’re in a different place, you’ll get new things out of it.

You’ll be reminded of some things that maybe you forgot or you’re kind of rusty on. So yeah, dust off those bugs, get them back out and pay attention to your foundational resources. And honestly, who moved my cheese? That’s another one I’ll probably go back to soon. Right. And things are in, yeah, in flux.

It’s a great time to go to that book. 

Elizabeth Larrick: At the beginning of the year. I always like to reread a couple of books. Just one of them is you are a badass by Jen Sincero. One of my favorites. Yeah. Yeah. She’s, she’s a good punch in some of those ones. I’m always like, okay. I got to go back and read that or it’s just that time to refresh and get jazzed up again.

Kiela Linroth Pace: Yeah. No, she’s definitely that. I consider that her main book, primary book, I would consider a foundational resource in my own studies and books that I [00:32:00] recommend to clients. For sure. She’s got several and her money book, I forget if it’s like you are a bad ass at making money. Oh my gosh. That one’s fantastic for money mindset.

Yeah. Oh, 

Elizabeth Larrick: it’s awesome. I reread that one as well. And then she has the other one, I think she has a little one and then I’m a huge fan. I get her calendars. So I have a calendar reminder every day, but yeah, her two ones, you were about us and you’re about us at making money. She does a fantastic job. 

Kiela Linroth Pace: Yeah.

And I would recommend for lawyers in particular, definitely read her first book, but I would highly recommend the money book. And part of the reason I think it’s a lot of lawyers. I don’t know. They don’t like to talk about money. They don’t necessarily understand that money, like you need to get comfortable with money and you get comfortable talking about money and get to a place of having an abundance mindset.

I think many of us don’t, and we just have no clue what it means to have a good mindset around money. 

Elizabeth Larrick: Yeah. And I think in plaintiff’s personal injury, it’s, it’s tough because we walk in the [00:33:00] courtroom and everybody in that juror, they already programmed in their mind, we’re just a bunch of greedy trial lawyers.

And so talking about money can be tough if you’re not comfortable. Like they know it. That’s that little gut feeling. Exactly. 

Kiela Linroth Pace: Yeah. Yeah. Yeah. You’re going to be somewhat out of integrity if you’re not comfortable talking about money and that’s going to definitely communicate itself to them in ways that you may not understand and are not going to serve you well.

Elizabeth Larrick: One of the thing about Jensen Sarah really quickly, if you all pick up the book, so what I also love about her, you are a badass is in the back. She has all of her resources, like all these extra books, like if you are curious. And so I think one of her book is one of the very first ones that I picked up and then I loved it so much.

I just went through and went through her resources and she’s got a bunch of really great stuff in there too. If you just don’t know. And I think a lot of people just don’t really know where to get started sometimes. And so. 

Kiela Linroth Pace: That’s a great idea. Last 

Elizabeth Larrick: plug for her. I hope maybe she’s listening. No, I doubt it.

Yeah, I love it. 

Kiela Linroth Pace: Last suggestion. [00:34:00] No, I’m going to make one more. I’m going to make one more plug for her. One of the things I love about her writing is that it’s so fresh and irreverent and even funny at times, even though she’s dealing with a very serious subject matter. So it’s easy to read. It really connected with me on a level in a way that some of the resources that have been recommended to me before that were hard, like some of the money mindset books in particular.

I cannot remember the name of it right now. It doesn’t matter, but it was just like I had to force myself through those books. Hers. No way. It was just so easy to read and it was so easy to go back to. I actually look forward to it when I’m planning to return. So yeah, I’ll stop plugging her too. So let’s say we were still on our list of suggestions.

Number three. Yeah. For getting time back. Now this one is probably counterintuitive for a lot of folks too, but choose work that lights you up. I know it’s easier said than done and [00:35:00] oftentimes you may feel overwhelmed by the mere suggestion. If you’re at a place with your law practice, with your work, with the business side of things, if it’s so hard and it’s like pushing a boulder uphill, that kind of thing, that may make it feel overwhelming.

But if that’s you, and that’s what’s going on. Then this tip is especially for you because it doesn’t have to be that way, even within the same exact job, the same work, the same business, you can make changes, you can adjust things, you can delegate some of the things that are dragging you down like that energetically, and you can actually transform your job.

In my case, it was over a period of nine months that I was able to transform my job where the work that I was doing, even though it. Very much resembled the work that I was doing before was more aligned with things that let me up. Now, for me, ultimately, it actually also meant shifting out of law, even though there were a lot of things that I loved about law, about litigation, and a lot of things that were very fulfilling and rewarding.

What I ultimately realized is that coaching was really what let me up. And that’s [00:36:00] why I made that decision to shift gears. And so here’s the thing. This may, it may be a lot and it can be a lot, but I promise it pays massive dividends because the thing that you may not realize if you haven’t made any of these shifts yet is that your work can actually energize you rather than draining you, rather than sucking the soul out of you, so to speak.

And I know a lot of lawyers who are in that place where it really, there’s some litigators who that is what lights them up and that’s fantastic, but there are many people doing litigation where that’s really not what lights them up and that’s terrible because it tends to suck them dry. Right? So here’s the thing.

If you’re doing work that actually lights you up, then it energizes you rather than draining you, which means you need less recovery time. This is where you get your time back and it leaves you in better shape for everything else in your life. So when you’re going off to do the things with your family, when you’re sitting with your clients, as opposed to in the courtroom, you have more time, more energy, more ability to be there for them.

You’re more effective in your life and you’re happier. You’re [00:37:00] more at peace. So this is probably my favorite of these three, even though it’s the third to get to is it really took numbers one and two to get to a place where I could even see much less start figuring out how to implement number three.

Elizabeth Larrick: Having that space. And a lot of times I feel like that kind of limiting belief that may be underneath there, which is, I can’t say no because I need money. I need to, and the funny thing is, and I’m sure this happened for you. As soon as you really made that shift and went after that thing that lit you up.

The money comes right. The, the, it’ll follow your energy. And like you said, sometimes it’s just the smallest things. And I always tell people like we all in a law firm, or if there’s just two of you, generally you all, it’s a ying and yang. You all have give that person their strengths and what makes them happy.

And if luckily, if you don’t like it, great, give it to them and vice versa. Because not we’re just because you are a lawyer doesn’t mean you do. Everything that comes with being a lawyer, every single task, because you’re not going to be great at everything when it comes to being a lawyer, [00:38:00] there’s going to be stuff that you’re.

That’s right. Are fantastic at, and it lights you up and you love it. And then that other stuff, it just burdens you and it takes a long time. And it’s draining, just like you said, getting all that stuff rearranged. But I think you made the best point, which is you got to have a little space to have that reflection to see, Oh, That is not my jam or my jelly.

How can I delegate that or maybe just not do it? 

Kiela Linroth Pace: And there’s one thing that you said that kind of perked up my ear. Just because you’re really good at something doesn’t necessarily mean it’s what you’re meant to be doing forever and, or what lights you up. So this was certainly true for me. I was really good at defending DV cases.

And I was really good at criminal litigation. There were lots of aspects of it that really did light me up, but they were this pick and choose thing. And I felt like I had to, can I say shit? I felt like I had to slog through so much of it. I 

Elizabeth Larrick: think [00:39:00] I don’t, I’m not sure where exactly. It’s okay with me, but I don’t, 

Kiela Linroth Pace: here’s what I’ll just say it.

Okay. I felt like I had to slog through so much shit to get to the, the, the pieces that were so uplifting and rewarding and, and validating, even those pieces were few and far between for me, even though I was really good at it. And so ultimately that’s what I realized when I had that space and that time to reflect.

And that was for me, one of the silver linings of the pandemic. It really did give me a lot more space, a lot more time to reflect, even than I had already earned through these types of efforts in my work. And that’s when I realized I am really good at this, but it’s not what lights me up. It’s not what I need to be doing long term.

I’m grateful for the experiences, right? And they certainly feed, they lead to, they lead into. What I’m doing now and contribute toward what I bring to the table. I would hate for somebody who thinks I would hate for somebody to think I’m really good at this. So it must be what I meant to do. Not if it’s not lighting you up, [00:40:00] not if it’s not lighting.

Elizabeth Larrick: Yeah. Which makes me think of a book. 

Kiela Linroth Pace: Oh yeah. Which 

Elizabeth Larrick: books out there. Yeah. I love it. Gay Hendricks, the great leap. Okay. I 

Kiela Linroth Pace: have not read that one. 

Elizabeth Larrick: Oh, yeah. It’s a, it’s, and he talks about being in the zone of genius, being in the zone of excellence. And you may need to get drop off this thing that you do well to go to this like excellence level.

Oh, 

Kiela Linroth Pace: absolutely. He’s got lots 

Elizabeth Larrick: of stuff out there. That’s the one that I’ve read. He has another one out that builds on that, but I haven’t read that one yet, but, but yeah, it’s a great, it’s not very long. It’s pretty short and it’s, it talks about limiting beliefs, but then like this whole these zones, but it fits right in with what you just said.

Yeah. Yeah. I just, Oh my gosh. We’ll have to put all these. Okay. So let me just tell everybody who’s listening. We’re going to make a list of all these books. We’ve been talking about. We’ll put them in the show notes for you. Yeah, for sure. We’re coming now a little bit on time, but what I want to ask you, and so you can talk to everybody about what’s your ideal client, your favorite clients to help and let’s [00:41:00] divide it up.

If you don’t mind, let’s talk about coaching and then let’s talk about special counsel. 

Kiela Linroth Pace: Okay. So they’re related. They’re similar. So for special counsel, my ideal hiring attorney cares. About his or her clients about the quality of representation that they’re providing. But the part that really makes us a good fit is they’re pressed for time and they really want to focus on activities that are more lucrative, more impactful.

And when I talk about this, it might or might not be business activities, right? If they want to work on their business, that’s great. I can make help. Help them make the time. I can even point them in the right direction if they don’t already have a direction. But it may be that they want to be able to go on vacation uninterrupted.

Maybe that they want to spend more time with their family, that sort of thing. Basically, they know that there’s a better way and they’re looking, you know, looking for it and wanting to get some time back for themselves to, you know, start doing things. things better or different or whatever it is. And they understand that leveraging my experience can help them help provide a path for improving whatever it is, their law [00:42:00] practice, their business, their life in general.

So that’s there. When it comes to my coaching practice, it’s similar. But there’s a little bit more to it because we’re talking about a bigger investment of time, energy, and money. And so this is somebody who’s really ready for a change. They don’t necessarily know what that change means, but they know that what you said earlier, what got them here isn’t necessarily going to get them to the next level and they are ready to do.

Whatever they need to do in order to make that change for me, I had to get to a certain pain point in my life and my business to really be ready to make that kind of investment of time, energy, and money. Like I said, I also had to, even within that journey, I had to get to a certain point with my business development of getting stuck that place.

I had already made a significant investment of all three of those things, time, energy, and money and business coaching, but. To get to the point where I was actually ready to try different things, new things that I didn’t necessarily understand. So this is where some of the woo thing can come in. I had to get stuck in business.[00:43:00] 

I had to get stuck two years in with this gargantuan problem of I’ve got this now thriving, successful law firm that is still feeling like it’s riding on my shoulders and I have no relief. Right? So the person who’s a great fit for me in terms of, uh, coaching, It’s probably most of what I said about the hiring attorneys, but also they’re actually ready to try something new and different and understand that it may take a leap of faith.

It may be something that doesn’t, they don’t understand yet, so they’re ready to venture into the unknown. 

Elizabeth Larrick: Gotcha. It sounds like what we’re looking for though are definitely people who are ready for something new, different, open to different solutions, curious learners, right? Maybe. You know, 

Kiela Linroth Pace: yeah, that’s for sure.

On for coaching, I’d say for hiring attorneys, not necessarily because if they’re interested in and want to go down the path of really transforming their practice, their business, their life, then yes, because that oftentimes is what it takes, but I’m not going to be pushing that on them. If what they’re really [00:44:00] looking for is just somebody to take some of the pressure off, take some things off their plate.

I can do that too. It’s all about consent. I’m not going to come in and say, we’re going to Completely transform everything here because they may like where they are. That’s not something I’m going to make a decision about. 

Elizabeth Larrick: Yeah. We’ve been talking about in my mind and what you mentioned, like somebody wants better, like work life balance, but you’re definitely going to come in and implement a system that they’ve never heard or thought of.

Thought of that’s still going to take a little bit of, I know this is different, but just give it a second, try it out for a little bit, you know, like not taking cold calls. Like sometimes I’ll tell people like lawyers that, and they’re like, what I’m like, yeah. 

Kiela Linroth Pace: And it’s funny. Cause I’m thinking about one particular attorney who is excited about the prospect of working with me.

We just had a conversation a couple of days ago and we’re going to have our next conversation in a couple of days, an office visit. And he’s one of those who is, I think he cannot even imagine. Scheduling calls the way that I do. And that’s my point is I’m not going to push anything on him. [00:45:00] I might suggest that he consider it, but that’s it.

And it’s totally, he gets to be the creator in his life, right? He gets to decide what he wants to do and what he doesn’t want to do. Even if I know that would provide him with a lot of relief. 

Elizabeth Larrick: Right. Everybody else knows it’s going to. 

Kiela Linroth Pace: Exactly. If it’s something that he’s just not comfortable contemplating at this point or forever, he gets to decide and it’s a little different.

And that’s what I mean, like the difference between somebody who wants to work with me as special counsel versus somebody who’s actually ready to work with me as a coach. It takes a bit more. It takes a bit more faith. It takes a bit more. And I don’t mean that in terms of religious faith, faith that I’m going to help them.

And if they’re not at that place yet and they’re not at that comfort level yet, then maybe what they really need to do is follow me on social media a bit, do a couple of my workshops and get a feel for who I am and what I’m like as a speaker and a coach before they take that leap. 

Elizabeth Larrick: Yeah. 

Kiela Linroth Pace: Are you doing any mastermind groups right now?

I have a group. It’s more of a mentoring [00:46:00] group. I originally tagged it as a mastermind group, but I actually recently decided I’m going to reframe that. And here’s the deal for folks who don’t really want to make the level of investment, money, time, energy, that private coaching is Requires and I say requires, because it’s usually if you’re investing at that level, then you want to make sure you’re really ready to put a lot into it.

I think, and that’s my preference. I don’t really want someone to step into one of my private coaching seats unless they are ready for that. For folks who want a lower level of investment, but still want to have access to me. That’s what the group experience is about. And I basically set aside three times each month, basically a weekly zoom call that we get together and they can ask any questions.

I might provide a lesson. And it’s really what they need type of time. And there are also like a monthly call that’s optional that they can have a private call with me. And that’s the way I’m doing that right now. It’s really just designed for the folks who, yeah, you know what? I am ready to work with you, but I’m not ready to work with you at that level.

Or I’m just [00:47:00] not, maybe I’m not now or may never be ready to invest at that level. It’s just a way to offer something for folks who are earlier in their. Careers, A, may not have the resources or they’re just so swamped. They’re like, I don’t, I just don’t know if I can make use of. 

Elizabeth Larrick: I think it’s a great way for people to put their toe in the water.

If they’re going to, if they’re ready to do something different, but you’re just checking things out, definitely support masterminds or mentor groups, just so you can at least be in the same space as like minded people, like someone trying to solve some issues. 

Kiela Linroth Pace: Absolutely. Yeah, absolutely. And to be clear, I have my own coach.

I have my own mastermind group that I belong to. 

Elizabeth Larrick: Same here. Same here. It’s, I always suggest it for anyone, no matter what they’re doing. Listen, having that outside person be able to like, look in and be like, Whoa, like you, you grow in leaps and bounds compared to doing something, trying to do it on your own.

Kiela Linroth Pace: Absolutely. Yeah. And sometimes people ask me like, okay, so [00:48:00] when should I hire a coach? Why should I hire a coach and who should I hire? These kinds of questions. When is when you feel like you need more, you’re maybe wanting to either get where you’d want to go faster. Or you’re stuck. You’re at sea. I know something needs to change.

I’m not sure what or how or whatever. These are great times to start looking into coaching and hiring a coach. The who, that’s another great question. And it’s a, it should be somebody who’s accomplished the thing that you want to accomplish. And you might like, how do you know that you might know other people who know them?

You might have, and this is a great one. They might have some opportunities, some ways to work with them that are a lower investment that you can start with. For me, that’s my workshops, right? Available through UT Law, CLE, or follow me on social media and look for those times when I’m going to be speaking for the Austin Bar Association or the Capital Area Trial Lawyers Association or whatever, for my, one of my first coaches, that was, he’d have these little trainings that were like audio recordings, and then it was followed by an [00:49:00] event that was live in person.

And you fly across the country and have a two day event, do things like that to get a sense for them, because the key is this, does it resonate with the Do you connect? Do you get a good feeling? Do you feel like they’re going to help you? That’s pretty much it. They’ve accomplished it and they click with you.

Elizabeth Larrick: Yeah. And there’s most people you should be able to, like you said, follow them on social media, go check out their websites, check out their blogs. They put a book out there. I always read the book and that generally will tell me like, do I want to invest more? Because the book’s a pretty low investment doing something else.

And I’m not, I don’t like to say every coach has to have a book because most of the ones that I’ve used don’t. But. They have enough material that, like you said, does that voice resonate or does it not? 

Kiela Linroth Pace: Because it doesn’t, it’s not going to. Exactly. Yeah. And you might be able to get on the phone with them.

I do a discovery call. And one thing I will say is if you are just trying to fill them out, just be honest. Make that clear. Some people will do, I used to do these strategy sessions after my workshops. I’ve gotten to a place where I need to [00:50:00] protect my time a little bit more, but you know, for somebody who’s genuinely interested, um, I would say just reach out to the person and see what they have, what they can suggest, you know, what they offer.

Elizabeth Larrick: Yeah, exactly. Keely. I really appreciate all of your time today. I know that folks listening probably hopefully learned a lot. If not, there are lots of book suggestions. We’ll put that in the show notes and also put a way for folks to connect with you directly. And again, like I said, I love following you on LinkedIn.

Is that a good place to follow like social media? 

Kiela Linroth Pace: Yeah, LinkedIn is a pretty good place to follow me. I also have a public profile on Facebook. It’s Austin Key LA and people sometimes think that’s my first name. No, it’s because I’m from, I’m born and raised in Austin. I’m one of the unicorns. Yeah, exactly.

So Austin Kiela is my handle on Facebook for my public profile as well as Instagram. Instagram isn’t really developed yet, a to do [00:51:00] list item, but you can follow me there and I do sometimes little video clips and little suggestions and whatnot, but my website is probably the best place if you want to.

LinkedIn, the, just messaging me on LinkedIn is great. I love that and then also you can get on my website and go to the contact page and if you just drop me a note there, it shoots me an email. 

Elizabeth Larrick: Awesome. All right. Thank you so much again. I appreciate you coming and talking to what special counsel means and hopefully we can have you back on in the future and 

Kiela Linroth Pace: I would love that.

Keep 

Elizabeth Larrick: trading book suggestions. Yeah. Thank you so much. I appreciate it. Awesome. Take care. Thank you. All right, everybody. Thank you so much for tuning in today. Appreciate that. If you liked the episode, please don’t forget to follow us on your favorite podcast platform and until next time, thank [00:52:00] you.

Are all clients a good fit for witness preparation? Join me as I share a recent experience of a client resisting deposition preparation. I will also discuss ways to identify if a client is open to learning – or if they’re just acting like a know-it-all. Discover the signs to look out for, and I’m also giving out some questions to consider to evaluate your client’s readiness and willingness to engage in the process.

This episode takes a closer look at how to handle clients and determine their level of investment in a case. I can’t stress enough the importance of having an in-depth conversation with the client before the deposition to ensure everyone is on the same page. I also offer tips on dealing with clients who may not be a good fit for witness preparation. Be ready to navigate the complexities of client management in the courtroom.

In this episode, you will hear:

• Questions to assess client readiness
• Tips for productive conversations with clients to ensure they’re invested in the process
• How to determine if a client is a good fit for witness preparation
• Questions to ask yourself to consider if a client is open to learning

Follow and Review:

We’d love for you to follow us if you haven’t yet. Click that purple ‘+’ in the top right corner of your Apple Podcasts app. We’d love it even more if you could drop a review or 5-star rating over on Apple Podcasts. Simply select “Ratings and Reviews” and “Write a Review” then a quick line with your favorite part of the episode. It only takes a second and it helps spread the word about the podcast.

Supporting Resources:

Have a question or idea for an episode? Email Elizabeth (she reads all her emails) Elizabeth@larricklawfirm.com 

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 I sent you.

Episode Transcript:

Elizabeth Larrick: Hello, and welcome back to the trial lawyer podcast with your host me, Elizabeth Larrick. Thanks so much for tuning in today. I want to have a short episode, but talk about something that happened recently that I think happens quite a lot to us. And that is clients [00:01:00] who resist getting prepared for deposition or trial.

And what it brought me to was thinking about having an episode talking with y’all about how not every client is a good fit for a client. Um, and so I’m going to talk about, um, how to do a witness preparation. And generally it comes down to three different things that I have seen and encountered. And trust me, I have definitely encountered this over the years of working with people in depositions who are not open to learn.

They are not open to the help. Or they just don’t think they need the help. Right? They think they know everything already. And You could have a person who has all those things wrapped all in one. And generally you’re going to have pretty easy signs to know this person would not be a good fit. But sometimes you have people who it’s hard to determine whether they’re a good fit or not because sometimes they have [00:02:00] behavior that tells you that they’re not really open to learning.

And sometimes they are. So sometimes it can be difficult to ascertain that. And I want to talk about this because I recently had this exact situation and I thought, was this totally preventable?

So let’s talk about it with our folks on the podcast, because I know you guys are running up against this kind of situation all the time. And I see people basically just let it happen. I let it happen. Let’s try to prevent that. So let me talk a little about the example that I have. So recently I had an attorney that asked me to come help with deposition prep and they had the deposition set two or three months out.

And so we start planning and the client all of a sudden plans a [00:03:00] vacation. And the vacation is the two weeks before the deposition arriving home one day before the deposition and kind of questioning. Okay. That seems like we’re cutting it really close. Hey, that’s all right. Let’s just use virtual, right?

We can use virtual. I’ve done it many times. I encourage folks here to use zoom on Witness preparation all the time. We start looking at, let’s make some Zoom appointments. And that becomes very difficult. It’s very hard to pin down. Sometimes they just don’t show up. That’s okay. All right. Lots going on over there.

So I just always want to be differential. Could be something else. I don’t know what’s going on. And then we have our in person meeting, show up late and then left early. Okay. All right. So there was really no preparation for this person at the end of the day, just hoping that they [00:04:00] did well, which I assumed that they did all right, their deposition.

But what it came down to is I think this was somebody who was not really open to the help, despite saying so. So I think this is a situation where there was a little bit of vetting and always was told whenever we had Zooms and calls together, Oh, of course, yes, absolutely. Oh, yes. I’m very much looking forward to this.

But then Roadblock, which is people always want to look at what are people saying, but really what are they doing? And what they’re doing is probably the truth, not necessarily what they’re saying. So what I want to do is talk about how we can look at cases. We can look at clients and really try to prevent a situation like this, because what happened was a lot of people put a lot of time and investment, not just me, into preparing this person and setting aside time.

And it was truly very much an energy suck. And It ended up being a total gamble because [00:05:00] we had invested so much time, but yet the client had not. So this is where maybe they’re not a good fit, right? Level of investment. So put together some questions that you could sit and ask yourself first. I always think it’s really helpful to walk through what You may be thinking in your mind asking some questions before you talk to your client that way one, you know planned out You have examples thoughtful when you have this conversation with the client, but what I would be asking Me, but this is what I asked myself now having gone through a situation where I was like wow That feels like there’s a lot of writing on the wall that we all ignored So what I want to ask myself is this person open to learning?

You And that, are they asking questions? And I think when we have a case and we, especially when we get into litigation, right, that’s really foreign for people. Some people they’ve had a [00:06:00] claim or someone’s had a claim before they’ve had, they’ve seen situations, but when it comes to litigation, most people are pretty foreign.

So I always want to be looking at, have they been asking questions? Are they open to learning the process? Are they curious about how this all works? Or are they just there when they need to be and otherwise? Now, I know there’s a lot of people who just don’t know what questions to ask, but you’re going to see that they have a level of engagement in what’s happening with the file.

They call, they’re curious, at least to know updates on what’s going on. The other question I ask, is this person ever acted like a know it all, right? And we all know what a know it all is, even as kids we know what know it alls are. Guess what? Those kids grow up to be adult know it alls. You could have a client that’s a know it all and that’s okay.

Hey, we gotta, we just gotta know what we’re working with here. Because sometimes know it alls are a resistance. Sometimes there’s ways to work through that resistance. And [00:07:00] I’ve seen a lot of lawyers do really good jobs working in relationships with know it alls, but they have boundaries and rules and expectations from the very beginning.

Now, sometimes we don’t know this about a person and we learn that about them, and then you still need to set up those boundaries, rules, and expectations. The other thing I always ask myself is, okay, is this person late all the time? Are they chronically returning things to my office or getting things back to me late?

And again, what we’re trying to figure out is what is the investment level of this person? You may have clients who are 100 percent invested, maybe they’re 90 percent invested and you don’t even lose one hour of worry on this person because you know that they give you their time and their attention with the case and that they’re going to do that when it comes time to prepare for deposition.

So, we’re [00:08:00] talking about people who maybe they’re not going to be a fit, maybe they’re going to be a little bit of an issue and that’s what they’re This is really addressing is those people who you have a hunch that they might not be a good fit, or you just know, big red flag, like totally no, they’re not going to be a good fit because we don’t want to waste your time and your energy.

You have only so many cases. You have so many things. You have to make a decision and a choice about how to use your energy and your time wisely. And if you have a client who’s not investing in Or invested in their case, then you really need to be upfront about, again, the repercussions of their lack of investment.

And I think when clients are not invested in their case, we’re seeing them not return things on time. We’re seeing them not give you things to support the file. Those examples like photographs, videos, [00:09:00] tax returns. Emails, text messages, are they not getting that because that’s evidence, people. We got to have that stuff.

Maybe they’re not returning that stuff. So they’re not best. Maybe they’re not returning your calls. Maybe they’re putting off having calls with you. Maybe they won’t schedule things to get things done. That’s somebody who’s just not really invested. And you know what happens when the client is not invested.

When you can’t get those key pieces of evidence to support their damages, to support liability, there is a large loss of value. You know it’s going to take a longer time to get to settlement and you have to start making decisions. So I think it’s really important to know that you as the lawyer have to tell your client about the repercussions, right?

You have to tell them there’s going to be a loss in value here. It’s going to take longer time to get to [00:10:00] settlement. And I have to make decisions about files, and guess what, this is probably not a file that we’re going to try, okay? Because you are not providing the evidence and the investment that we need to be able to take the case to a trial.

So, if that’s something that you’re hard set on, client, we might need to find you somebody different to work with, okay? But let’s talk about how to have that conversation. Once we decide, okay, this is somebody who’s going to put up a fight for preparation or they’re going to let you go through the motions and they’re just not going to show up or they’re not going to be present or they’re going to leave early.

They’re going to come up with an excuse. We want to prevent all that for you for sure. So I always have just a quick conversation with the client to talk about it. And again, I think in other episodes I’ve mentioned this, if not, I’ve wouldn’t, I’ve been doing CLEs. We’re talking people in podcasts and really emphasizing having a 30 minute [00:11:00] conversation.

It can even be 20 minutes y’all before you are scheduling a deposition and not sending an email, not, Hey, can we get dates for deposition? No, you are calling as a lawyer to talk about what it is and the dedication that you need from them for preparation, setting that scene. And that’s really what this little conversation is about, which is basically, Hey, we’re about to schedule deposition.

This is something you have not done before, right? That’s a fact right there. Can’t argue with the fact. Depositions significantly impact a case because decisions are made based on what is said or not said. Okay, so now we’re saying, hey, this is an important thing. You haven’t done it before. And then the next part of it is my process.

Part of what I do to prepare you is by having one on one time together over several meetings. So you can feel prepared and then walk into that deposition and show them that you were prepared. [00:12:00] How does that sound? So what have we done here? We’ve done several different things with this really easy setup and then we turn it over and open it in question.

How does that sound? And they’ll just tell you what they’re going to tell you. But, you’re stating a fact, they haven’t done it before. You’re stating another fact, it’s significant. And, what you want, what your expectation is that they are going to prepare with you one on one over several meetings. Because we always have everything has a reason built in here, right?

And what happens is you’ll get deflection. What are they going to ask me? We’ll get to that. That’s why I want to spend one on one time with you preparing. But how does that sound? I would like to know. See, we’re going back to that question, right? You guys are great at depositions. Okay, just rephrase that question.

Get it back to them. Right? Make sure that they’re answering that because we want to make sure people are a good fit. We want to use your energy and your time wisely. And likewise for the [00:13:00] client, it goes the same way. Hey, if this is something that you don’t want to invest in, that you don’t want to spend time and energy, then I’m not going to do that either.

But that means that we’re making decisions about this case and the value. And are you okay with that? because you’ve told me before I need X, Y, Z, or whatever the value is before. Because again, if you have had the case for a while, you’re going to know what the client thinks or feels, whether they trust you about the value or they don’t, they have an expectation in their mind of what they have to have.

We always have people like that. So you guys can think of an example in your mind. But I wanted to put together this short episode to talk about this because Even as somebody, myself, who has been doing this particular type of preparation for almost 10 years now. Easily, yes, it’s over 10 years I’ve been doing this.

I still run into people like this. I still get caught in this trap. And I don’t want you to get caught in this trap because we know it’s [00:14:00] preventable. We know it’s something that we can have a quick conversation about to understand. And hey, if that’s their decision, that’s fine. That’s their case. But you want to know so that you can be prepared for the same thing and then not be caught off guard.

All right. I hope that this episode was helpful. Again, short and sweet to the point, how do we figure out if people are a good fit for witness preparation, right? Ask yourself those questions. Is this person open to learning? Are they asking questions? Has this person acted like a no at all? Has this person been late?

Are they chronically returning things to the office slate or just not returning things at all? What’s their level of investment in this case so far? Then turn around and have a conversation with the client before the deposition gets scheduled so that you can both be on the same page. And then also so they can set aside time.

You’re, it’s a [00:15:00] very considerate thing to do. So I hope that this helps you. If you have a suggestion or if you have a question or if you want to come on the podcast, please email me. My email is always going to be in the show notes as a way to get ahold of me, but till next time. Thank you so much.