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The Jury Will Read Your Emails: Legal Advice You Don’t Want to Ignore · Coopers' Code

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  We e-mail each and every day, hundreds of times a day.
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  Sometimes lawyers just love to e-mail, and it's going to be
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  those emails that are going to bite you in a legal malpractice
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  case. Howdy and welcome to the show.
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  Cooper's Code focuses on legal issues and noodle practitioners,
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  distilling wisdom so we all achieve the best results for our
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  clients. I'm Miles Cooper and I'm very
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  excited to share the Part 2 of this conversation with Marshall
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  Cole. Pivoting a little bit into being
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  a good client. And again, I, I think a little
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  bit about there's the, the phrase the Cobblers kids have no
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  shoes. I imagine that lawyers can
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  sometimes be challenging clients because they may have their own
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  opinions. They may just be who they are.
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  What makes a good client and and and how can one best help you
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  help them? A good client is someone who
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  trusts that they're in good hands with us and, you know,
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  this is what we do. And so you should feel
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  comfortable knowing that we've got your case under control and
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  we're going to advocate on your behalf.
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  And like I said a few minutes ago, you know, you have
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  insurance for a reason. Use it and then go about your
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  practice. Like I I mean it when I say it
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  will only bother you if we need you.
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  And some clients like to be very involved.
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  And I tend to see that the higher caliber of lawyers say,
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  Marshall, don't ever call me unless you absolutely need me.
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  The, the lesser are redlining my discovery responses and I'm fine
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  with both. It doesn't bother me.
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  I'm happy to reject red line changes or accept them.
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  It's just sort of I, I view it as unnecessary, unnecessary use
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  of their energy. Some people just take it really
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  personally and I get that and I'm sympathetic to that.
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  And so it doesn't phase me one way or the other.
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  But I think to be the best client is really just to be the
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  the happiest client, you know, just to focus on your work and
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  not let it bog you down and beat you up 'cause when it does that,
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  it, it, it impacts you, you know, just in your, your mental
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  state. And I hate to see that.
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  And it also, you know, wears on you and want makes you want to
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  get the case out of your mind and move on versus if you're
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  just not thinking about it from the get go, that's OK.
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  Now, sometimes it's inevitable, You know, sometimes you've got a
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  big case, you know, with excess exposure that's going to be
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  stressful for the insured and and we deal with that all the
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  time. Are there any other areas like
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  Nuggets, bullet points of things that people haven't been through
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  this process, wouldn't think to think about that you you you'd
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  like to highlight? E-mail.
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  We e-mail each and every day, hundreds of times a day.
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  Sometimes lawyers just love to e-mail and it's gonna be those
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  emails that are gonna bite you in a legal malpractice case.
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  And I've seen it going in so many different directions.
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  Lawyers talking rudely to their clients is a big one.
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  Lawyers talking poorly about Co counsel is a very big 1.
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  And in when I'm in trial, the majority of my exhibits are
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  emails, maybe some documents, maybe some photos, depending on
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  the underlying case. But it's going to be emails, and
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  humor does not translate in e-mail.
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  And if you're going to e-mail? Which?
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  We do. If you don't e-mail about
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  something, that can create problems, right?
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  If people think, Oh well, it wasn't memorialized in writing,
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  then it didn't happen. I deal with that pretty well in
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  jury selection if I have a case where there's no writings
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  reflecting certain things, but you just have to be aware that
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  they're there forever and you know, those are going to be
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  exhibits in your case. And so it's important to be
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  clear with what you're saying. Same with text.
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  You know, I, I, I don't really text my clients unless they're
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  very close to me because we shorthand text all the time.
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  And you know, there's nothing worse than seeing a settlement
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  with a client get really memorialized via text because
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  it's just not coming through. You know, you talk in, in slang,
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  shorthand, whatever. He is using an emoji.
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  It, it's, it's just not a way to communicate.
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  And so I've had some really, really bad cases dealing with
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  emails that had really results that that negatively impacted
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  certain certain firms. Fist emoji, Flag emoji.
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  Fire emoji. I've seen them all
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  unfortunately. Not to repeat myself, but
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  talking rudely to your client looks horrible to a jury.
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  And I get it, clients can be frustrating, but they're lay
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  people, they don't know the law. It's your job to inform them and
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  you need to do it nicely. They have a right to bother you.
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  That's that's your, you know, you're, you're hired to be
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  bothered. A mentor of mine long ago and
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  and this was more, you know, writing more letters than emails
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  back in the day, but the through line to emails and texts as well
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  as if you didn't, if you don't want to see it on the front page
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  somewhere, don't put in right if you would be embarrassed by by
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  what was in there. That's great advice.
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  Another thing to add to that is if you want to send some nasty
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  letter or e-mail to opposing counsel, write it.
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  Go to sleep and wake up the next day and decide whether that's A,
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  A, A good use of your time, B, whether it's actually going to
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  move the ball or advance anything on your client's
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  behalf. And nine times out of 10, or
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  even more than that, you're going to delete it.
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  You mentioned something interesting and that is you have
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  a a method or a questioning tool for cases where something has
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  not been memorialized. When you're picking a jury, is
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  that something that you're willing to share?
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  Yeah, And just to take one step back before I go there, every
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  mediator and every mediation I've ever had tells me jurors
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  hate lawyers. You know, you got to sell this
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  case. Jurors hate lawyers.
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  I have not found that to be the case in all of the jury trials
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  I've done. When I do jury in jury
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  selection, most people have never dealt with a lawyer one
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  way or the other. So they don't actually have an
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  opinion of that. Some and and some who the few
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  who have, generally it's neutral.
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  So, yeah, I'm sure I over the course of some of those
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  vladiers, I've had someone raise their hand and say I hate
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  lawyers. Probably most likely just to get
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  off the jury. I believe you go into it on
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  5050, you're just as even as the plaintiff.
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  If I'm dealing with a case where something's not in writing and
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  it's a big part of the case, I just hit it head on in, in in
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  jury selection. I start talking about, you know,
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  the fact that there's you're not going to see these things.
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  And you know, I talk about CSI, right, when that first came out
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  and it was really impacting how juries looked at criminal
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  evidence, right? If it wasn't, if there wasn't
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  this exact scientific method or data or, you know, fingerprint,
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  then obviously it doesn't exist. And I sort of use that as a
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  humorous way to walk into the subject of, OK, well, you know,
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  how many of you have had conversations with people that
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  don't get memorialized in writing?
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  You know, every one of those jurors.
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  And we as people talk to people on a regular basis and don't
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  memorialize it in writing. And so I get them to recognize
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  and back to reality and just common sense of we as human
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  beings communicate with each other in many different ways and
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  talking is one of them. And with the advent of e-mail
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  that we didn't dispense with oral communications.
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  And so I get an ongoing and, and like a nice flowing discussion
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  about that. And you'll start to see the
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  people who are skeptical or who think I'm trying to kind of
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  condition them on that. And then I know I can see it.
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  The, the non verbal cues become very obvious because they kind
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  of will shake their head and be like, oh, obviously there's
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  something there and he's trying to cover it up.
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  And that's just, I'm more looking for that than getting
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  the good answers from people who don't care.
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  So that's how I start dealing with it there.
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  And then hopefully you pick a panel who of, of jurors who
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  recognize that they're going to hear evidence about a
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  conversation that took place and obviously hear conflicting
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  evidence conversation that didn't take place.
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  Then it all depends on how much backup evidence there is going
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  through there. But I've definitely had that.
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  And it comes down to cases where there's settlement agreements
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  and often times settlements on the eve of trial or during trial
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  where things are moving very, very quickly.
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  And so it's easier to give context to the jurors about how
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  and why there wasn't an e-mail memorializing that particular
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  thing or we're not going to call this witness.
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  You know, still a lot of these decisions get made in real time,
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  and there's just generally not an e-mail confirming those types
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  of things. Well, we're talking about trial.
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  I imagine with the cases you've had there, there may have been a
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  trial moment or trial moments that stand out to you in terms
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  of cases you've handled anything that you feel was was a
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  particular learning lesson or piece of wisdom, either of, of
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  great success or like, oh, this is a learning and, and next time
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  I might do it differently. Oh, I'll bring in arbitrations
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  as well, because I do a lot of those.
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  But I had a huge case that that hinged on emails and, and it
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  hinged on one firm talking poorly about another firm.
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  And I really, that was where I really learned, you know, and,
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  and I in my firm was the, the firm I was representing was the
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  one being poorly talked about and.
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  There was very powerful. And it's very powerful that we
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  were able to use and the other firm just really couldn't do
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  anything with it. They they were stuck in a
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  position in a really bad position.
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  And so that it was where I really got to see the impact of
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  sort of these bad emails and also where I really started
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  talking when I do CL ES to lawyers about, you know, just
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  cause it's not your opposing counsel doesn't mean you can
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  talk shit about your Co counsel or someone in your own firm.
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  You, you, you know, it was just eye opening for me.
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  And so I talk a lot about that. You don't think twice about, Oh,
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  it's not my opposing counselor, it's not my client.
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  Who cares how I talk to them about these other people?
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  But emails just look bad in all my trials, each one of them.
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  I it's reaffirms my belief that that jurors don't hate lawyers.
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  And I also, you know, deal with the case within the case when I
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  get to trial, which is, you know, in order to prevail
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  against a lawyer, you've got to prove that.
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  But for the lawyer's conduct, you would have done better in
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  the underlying case. And so I've really learned trial
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  after trial, how difficult that is for a plaintiff to prove.
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  And This is why you really want to be with a firm with
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  experience because there's motions and lemonade we file,
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  there's jury instructions that we request that are specific to
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  these very nuanced issues. And so the case within the case
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  can be difficult and judges have a lot of discretion as to how
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  they're going to run the case within the case.
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  We always try to require that they literally retry it.
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  But some judges will allow you to read deposition testimony
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  from the underlying case and that brings in certain issues.
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  And so not knowing what you're doing and not knowing what might
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  come up and dealing with the underlying case is is huge
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  because if they don't prove that, then you're going to non
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  suit them on on an element and perhaps be done before you even
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  get to verdict. I don't believe this is the
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  place for us to to all of a sudden start doing an hour long
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  side lecture on on artificial intelligence and its use in the
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  law. But I do want to provide a
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  platform for ways in which you have seen it influence the
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  personal liability sphere to the extent that it has in terms of
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  of defending cases or analyzing cases.
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  As you know and the people who we've spoken to know, I'm a big
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  proponent of AI as as are you, and I haven't yet seen it come
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  in the door as far as a a claim, you know, someone using AI and
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  getting in trouble. We've all as lawyers presumably
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  heard about the firms that have gotten into trouble for citing
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  cases that don't exist in briefs.
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  You know, just happened recently a month or two ago to another
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  firm. They're, they got sanctioned.
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  Everyone's getting sanctioned for doing it.
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  I use AI creatively as a tool. I don't mind ChatGPT, but I'm
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  not using it to get cases. I'm using it to discover trial
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  themes or if I'm deposing an expert witness in a field that
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  I'm unfamiliar with, you know, give me 50 questions on this
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  particular field. If I get 2 huge success because
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  it took 10 seconds to get it. So I look at it and, and I urge
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  everyone I speak to about it. It's if, if you wanted to do
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  your job for you, I think you're taking a big risk a lot, a lot
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  of times it probably can. And there are a lot of people I
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  know that are trying to have their firms run by AI and, you
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  know, BA sitting on a beach somewhere.
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  That's fine. You're taking a risk.
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  But the, the technology's there almost there, wherever it is.
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  My firm's not taking that approach.
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  I look at it as just another resource to add value to my, on
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  my client's behalf. And that's how I'd use it.
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• 15:02
  dot law. As we kind of coming into the
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  final stretch, is there anything else, any other area that we
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  haven't talked about? Wisdom pieces of cases, tools
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  that have been beneficial to you that you'd like to share with
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  our listeners. On the technical side, I would
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  say a lot of lawyers don't think about breach of fiduciary duty
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  and a lot of lawyers think, OK, I get sued.
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  It's a cause of action for maybe breach of contract, legal
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  malpractice. And that's that's negligence,
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  breach of fiduciary duty and a breach of fiduciary duty.
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  Cause of action creates complexities to your case for
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  the following reason A and a breach of fiduciary duty can
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  come from most common is going to be a conflict of interest and
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  undisclosed or unwaved conflict. It could be another many other
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  ways and the more I do CL ES and talk about what I'm about to
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  say, I feel like the more plaintiffs lawyers listen to it
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  and so they know to add a breach of fiduciary duty cause of
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  action. So I apologize for this, but
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  it's, it's, it's good to know on the defense side and as lawyers
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  as a whole just so you avoid it. But there's negligent breach of
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  fiduciary duty and intentional breach of fiduciary duty.
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  If you look at the jury instructions on intentional
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  breach of fiduciary duty, the word intentional does not show
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  up in the jury instruction. It's not like fraud where you
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  have to intend to act, intend to cause harm.
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  It's nothing like that. Rather, if you failed to get a
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  conflict waiver and represented 2 clients, one would argue,
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  well, that was negligence, I just didn't do it.
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  On the flip side, the plaintiff's floor is going to
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  argue, no, that's intentional, you didn't do it.
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  And unfortunately, you're likely going to fall into the category
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  of the intentional breach because the way the jury
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  instruction is worded and there are two big issues if you find
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  yourself facing an intentional breach versus a negligent breach
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  situation of fiduciary D. One is it's not going to be
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  covered. Intentional conduct is not
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  covered by your professional liability policy.
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  So your fraud, all those causes of action you'll never going to
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  get coverage for anyways. But intentional breach, it's a
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  Gray area. It's not fraud, right?
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  It's much different than that, but you're not going to get
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  coverage for it. So that's number one.
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  Number 2, the causation standard is different between negligent
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  breach of fiduciary duty and intentional breach of fiduciary
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  duty. With negligent breach of
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  fiduciary duty, it's the same as legal malpractice causation.
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  But for the lawyer's conduct, what would the result have been?
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  But for the breach of fiduciary duty, what would the result have
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  been? You still have to prove that
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  actual damage on the intentional breach side.
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  It's a substantial factor causation standard, which is you
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  would know Miles as the plaintiffs lawyer, much, much
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  easier to prove than. But for causation and the
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  damages that you can recover for an intentional breach of
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  fiduciary duty, you can get non economic damages and importantly
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  emotional distress damages. There's a case called Newton
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  versus Foster, a good case to read, which allowed for the
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  plaintiff to recoup emotional distress as a result of what the
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  lawyer did. Now think about it.
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  If you've got substantial factor causation, you don't need to
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  have economic monetary loss. You could have just the
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  emotional distress, right? This lawyer screwed up my case.
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  He sold me out. It was a total conflict.
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  It was the most stressful situation of my life, ruined my
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  life. Emotional distress give me
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  $1,000,000. And the one thing I've found in
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  trying these types of cases where I think lawyers and really
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  anyone in a position of ownership over someone's
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  well-being, which I think we have when we're lawyers for
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  cases, we take ownership of their, that issue in their life
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  is a lack of sympathy for the lawyer.
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  If something goes wrong, You know, it's easy for a
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  plaintiff's lawyer to sell to a jury that this was the most
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  important thing in this person's life and this lawyer didn't take
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  care of him. It's very powerful and a jury,
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  really, I've watched jurors just eat that up because I've
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  defended a couple of these cases.
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  We've had to take him to trial, tried to resolve and couldn't
• 19:46
  resolve them. And they're tough cases to
• 19:49
  defend because plaintiffs can be sympathetic.
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  It's easy to sell that. I came to this lawyer in this
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  situation. I trusted this lawyer.
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  I never trust anyone again. And you've got a problem.
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  So it's a bit of a long answer, but it requires that explanation
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  to understand the difference between a negligent breach and
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  an intentional breach. And if you face yourself on the
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  ladder, it creates problems for your case and obviously.
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  We deal with it and it doesn't mean you're going to pay out of
• 20:20
  pocket to resolve the case, but it it could mean that if you go
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  all the way to Trump and and you just need to be aware of that
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  risk. At a top level, can a lot of
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  that exposure be resolved with conflict waivers?
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  Oh, of course, if you, if you do things right to begin with, then
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  you're not going to get face a breach of fiduciary duty cause
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  of action. Now, I've, I, I truly believe
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  that I've spoken so many times that my, my friends on the other
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  side know what to do. So they'll allege it just to
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  throw it in there and that we can demur it out.
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  If it's truly duplicative of a legal malpractice cause of
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  action, we'll get rid of it. I mean, it's got to have teeth
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  at the end of the day and I've 7 out of 10 don't have teeth.
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  They just allege it and it's not a big issues.
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  I'm not, no one needs to freak out about it.
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  But if you do find yourself facing the legitimate one, those
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  are those are issues and and it creates the causation standard
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  is one that that people really don't focus on as being a much
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  easier pathway for the plaintiff to get a verdict.
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  As we talk about conflict waivers, do you have thoughts on
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  whether a conflict waiver should be a completely separate
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  document or whether it is OK to have that as a clause within a
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  representation agreement that you just kind of default to have
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  in and edit out if there's no 2nd and, and I'll I'll explain
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  why I'm asking the question. Yeah, In almost any case where
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  the clients are married, there is an injured person and then
• 21:51
  there's a lot of potential loss of consortium claim for the
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  spouse. And well, the loss of consortium
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  claim often times doesn't have a lot of independent value.
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  Sometimes it does, but often times it's a derivative claim.
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  It's kind of brought along to help the insurance adjuster put
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  a little bit more money in a bucket.
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  Often times it's not one that you want to put before a jury,
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  but at the same time you need to make it available.
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  And there is the potential for conflict.
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  And I know a lot of firms will do that as a a conflict waiver
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  within the Rep agreement. I would do them as separate
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  because the client can void A retainer agreement at any time,
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  right? They it's, it's just they can
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  fire you and, and, or, or if you if something's wrong with that
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  retainer agreement, it's voidable at the client's option.
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  You don't want the conflict waiver to be a part of that.
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  It's similar to on the plaintiff side.
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  If you do referral fee agreements, some lawyers put
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  them in a retainer agreement. Not smart, because again, if
• 22:48
  that retainer agreement gets voided for some reason, there
• 22:52
  goes your referral fee agreement, same thing.
• 22:54
  There could potentially go your conflict where now I know
• 22:57
  there's provisions within the retainer agreement that you
• 22:59
  could put in that say just because one's one provision may
• 23:02
  be void, it doesn't void the whole thing.
• 23:04
  That doesn't necessarily apply to retainer agreements because
• 23:06
  it's a much different type of contract that is 100% of the
• 23:11
  time and generally gonna be viewed in favor of the client
• 23:15
  over the lawyer. You know, we see this a lot with
• 23:19
  arbitration provisions. We can talk for a whole other
• 23:21
  hour on arbitration and whether it's good or bad, but if you
• 23:26
  don't dot your IS and cross your T's in your retainer agreement,
• 23:29
  we've had retainer agreements be voided and there goes your
• 23:32
  arbitration provision. And by that I mean lawyer may
• 23:34
  forget to send a fully executed copy of the retainer agreement
• 23:38
  to the client, which is required under the Business and
• 23:41
  Professions Code. So if your client comes in and
• 23:43
  signs a retainer agreement in your office and they don't leave
• 23:46
  with a copy or you don't send them a copy, you didn't comply.
• 23:50
  And we have lost motions to compel arbitration, which were
• 23:54
  affirmed on appeal because of not the failure to strictly
• 23:57
  comply with the rules. And that may seem like a there
• 24:00
  was no dispute. It was signed.
• 24:02
  You know, they, the client is, it's just I didn't get a copy of
• 24:05
  it. Tough judge, tough ruling.
• 24:08
  Correct technically. And you know, would every judge
• 24:11
  rule that way? Probably not.
• 24:14
  So it what does it take to separate it out?
• 24:17
  You know, it's it's not a big deal and it's cleaner anyways.
• 24:21
  And then then if something happens to your retainer
• 24:23
  agreement, that's fine. If something happens to your
• 24:25
  conflict waiver, they're both fine, you know, So it's no need
• 24:29
  to jumble everything together. I don't want to spend an hour on
• 24:34
  arbitration pauses 2 minutes, but I am interested in your
• 24:37
  thoughts because I know that some lawyers will include
• 24:40
  arbitrary and I'm talking over my own thoughts because my mind
• 24:43
  is moving too fast. In the plaintiff space where
• 24:48
  plaintiffs lawyers, consumer lawyers fight arbitration
• 24:51
  clauses, determine arbitration clauses are terrible.
• 24:55
  You will still see arbitration clauses sometimes in those same
• 24:58
  plaintiffs lawyers representation agreements.
• 25:01
  Do you have opinions on on pros cons?
• 25:03
  Should lawyers be using them? Should they not be using them?
• 25:07
  My firm uses it. Oh, it's similar to choosing
• 25:09
  insurance. You really need it.
• 25:10
  You need to give it actual thought.
• 25:12
  If you just have it because you went to some seminar and some
• 25:15
  person speaking said arbitration's the best thing in
• 25:17
  the world without doing any research, you're not doing
• 25:20
  yourself a favor. It's very expensive.
• 25:23
  It's getting more expensive year by year.
• 25:25
  So I think the old case line, the, the common knowledge and
• 25:31
  thought process was it's cheaper and it's quicker way to resolve
• 25:36
  your dispute. I don't think that's true
• 25:38
  anymore. It's certainly not cheaper
• 25:41
  'cause people would think, well, it, it doesn't span two or three
• 25:44
  years. So you save the, the legal fees
• 25:46
  that you would spend in that time.
• 25:48
  A I've had arbitration spend two or three years.
• 25:52
  While some may be shorter, they, you know, things get continued
• 25:56
  and whatever, even if it is shorter, whatever money you save
• 25:59
  in legal fees paying me, you spend with the arbitrator for 10
• 26:04
  thousand $20,000 a day of their time.
• 26:07
  And I don't fault the, the companies that do arbitrations.
• 26:09
  It's a business and costs are high and they've got to make
• 26:12
  money. But the, the benefit obviously
• 26:14
  is it's private. So if you have a type of
• 26:16
  practice and we have a lot of clients who don't want a single
• 26:20
  thing in the public eye, they don't care if it's more
• 26:24
  expensive, they don't care if it takes longer.
• 26:25
  They just want it private. And I get that.
• 26:29
  There's another important consideration or considerations
• 26:32
  which are you don't get a right to appeal in an arbitration or,
• 26:36
  or only on very, very limited issues, right.
• 26:38
  So if, if the arbitrator makes an, a legal error on an issue,
• 26:43
  you can't appeal that you know it.
• 26:44
  It's so limited. And in defending lawyers, we've
• 26:49
  got a lot of weapons at our disposal to, to handle your
• 26:53
  case. We get rid of a lot of cases on
• 26:56
  summary judgement and you're because causation, it's so hard
• 27:01
  to create a tribal issue, a fact on causation in a legal
• 27:03
  malpractice case that we have a really high success rate.
• 27:07
  You're not going to get that in an arbitration.
• 27:10
  And so the arbitrators, you could bring in MSJ, I'm sure we
• 27:14
  have and I'm sure they've been denied every time because they
• 27:19
  are going to want to have it heard on the merits.
• 27:21
  And so then you got to be prepared to try your case to an
• 27:26
  arbitrator and, and, and we get great results and sometimes you
• 27:30
  get mixed results. And no matter what it is, you're
• 27:33
  stuck with it and you can't appeal.
• 27:35
  So you've got, if you're not thinking about all those things
• 27:38
  and what makes the most sense for your practice and you just
• 27:41
  have one in there. 9 times out of 10, I will have the
• 27:45
  discussion when a case comes in and I'll say, do you want to
• 27:48
  invoke it? Because most, most plaintiffs
• 27:50
  will file in the Superior Court and we'll have the petition to
• 27:53
  compel binding arbitration. Some insurance carriers won't
• 27:57
  allow you to invoke your arbitration fridge without
• 28:00
  consulting with them or you risk losing coverage because some
• 28:04
  very much dislike being an arbitration.
• 28:07
  And that's an important consideration to think about
• 28:09
  when you're buying insurance. So there are a lot of factors
• 28:13
  that go into it. And if I see a case where I
• 28:16
  think we've got a great chance at an MSJ and I think I've got a
• 28:19
  judge who who I know isn't shy about granting dispositive
• 28:23
  motions, I'll say unless you really want to keep this
• 28:25
  private, let's go to the Superior Court.
• 28:28
  Interesting. And it's because of the
• 28:30
  experience with jury trials, You, you, you.
• 28:32
  I can say that because I know I'm comfortable taking that case
• 28:35
  to trial with a jury. There may be a different
• 28:38
  certainly cases where I say let's get this thing in
• 28:40
  arbitration because we don't want it in front of a jury.
• 28:43
  I can see why this could be an hour long conversation on its
• 28:45
  own. Yeah, arbitration can be, I
• 28:47
  think I've done, I have PowerPoints on hour long
• 28:51
  presentations for, for arbitration because yeah, and,
• 28:54
  and unfortunately most people don't think about it.
• 28:57
  And also people choose choosing who which company is going to
• 29:01
  preside over it is very, very important.
• 29:04
  Depending on who you choose, you might have someone with 0
• 29:08
  qualifications who's not a retired judge versus someone who
• 29:14
  works for a very reputable company who's a retired judge
• 29:18
  that we know has tons of experience handling arbitrations
• 29:22
  and with in with respect to legal malpractice claims.
• 29:24
  Makes a huge difference. We followed that tangent down a
• 29:30
  a good rabbit hole, but I'll bring it back to the the
• 29:34
  question that teed us off in terms of you bringing forward
• 29:39
  the fiduciary duty piece. And and that is, are there any
• 29:42
  other areas that you think it would be useful for our
• 29:46
  listeners to know about? I think without doing a, a full
• 29:52
  Cle presentation on some of these issues, you know, your
• 29:55
  listeners have a good understanding now of probably
• 30:00
  two or three or more things that they haven't thought about and
• 30:04
  can improve their practice in the back office.
• 30:06
  And, and then how they, how they operate with clients, which I
• 30:11
  think should be hugely beneficial.
• 30:13
  I think about these issues routinely.
• 30:16
  I've got a retainer agreement sitting right in front of me
• 30:18
  here and I got a separate conflict waiver.
• 30:22
  And so these issues are things that we deal with in, in our
• 30:25
  practice on a daily basis and are constantly changing and
• 30:29
  thinking about and modifying. And, and I urge all your
• 30:32
  listeners to do the same thing because things are always
• 30:36
  changing. Well, Marshall, I, I really want
• 30:41
  to thank you for for your time today.
• 30:42
  I really enjoyed our conversation.
• 30:44
  I really appreciate you having me on and I look forward to our
• 30:47
  our next AI presentation in a couple months and it's, it's
• 30:52
  been great how I really appreciate it.
• 30:54
  Well, I'm, I'm looking forward to that too.
• 30:57
  Thank you for listening today. Please e-mail us at podcast at
• 31:00
  Coopers dot law with questions, comments, feedback and
• 31:03
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• 31:07
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• 31:12
  to all of you doing justice out there.
• 31:14
  Happy update.