Kansas Wants to Stop Anchoring - Will Your State Do the Same? With Tom Dickerson

Voice Over (00:00:03):

Every trial lawyer knows that moment when you've built what feels like an airtight case, but you're still lying awake wondering, what will the jury actually think? Jury research was once a luxury, reserved for cases that could support a big data study bill. Not anymore. Join trial lawyer and trial scientist, Alicia Campbell, an empirical legal scholar, Nick Schweitzer. As they break down the barriers between you and the minds of your jury, this is The Fred Files, produced and powered by LawPods.

Alicia Campell (00:00:36):

Well, hello, hello, and welcome to The Fred Files. We have a special guest today who needs no introduction, but we're going to pepper him with some questions anyway so he can tell us a little bit about himself and maybe some more interesting parts of his life besides just the practice of law, which is what we tend to talk about all the time here on this podcast. So it's nice to have a little break, little interest, and then talk about the big stuff because today is a big day. Today's we're going to talk about some big things that are occurring in law in the United States. Of course, I'm here with Nick Schweitzer.

Nick Schweitzer (00:01:07):

Hello.

Alicia Campell (00:01:07):

Yes. And it's going to be a very exciting podcast. I'm very excited about this one because we're going to talk to Tom Dickerson about all the things that he's been dealing with in the past couple of, what, weeks, months, and some surprise effects of it. You know what I mean? Well,

Thomas Dickerson (00:01:25):

It has been a surprise and we've been absolutely blitzed in my states where I practice. But the good news is we've been able to respond to that appropriately, but totally unexpected. And I think this is coming to a place near you. So I'm excited about A2 because I think we might be able to help a lot of people.

Alicia Campell (00:01:41):

Yeah, that's my hope as well, is that we can kind of put it out there because for what we're about to talk about, which I'll be even more cryptic, what we're about to talk about that we're not going to talk about right in this instance so you listen. I think it's been on the radar in terms of people been thinking about it, but not really on the radar as something has been happening or that there's a push nationwide. So Tom, you're in Arizona for spring break.

Thomas Dickerson (00:02:04):

I am. I am. And it's absolutely beautiful here. Well, at least for now. It's going to be like 105 this week.

Alicia Campell (00:02:11):

105.

Thomas Dickerson (00:02:11):

Yeah. They're talking about historic highs.

Nick Schweitzer (00:02:14):

I'm seeing that. Yeah. It's a little early, but it's-

Thomas Dickerson (00:02:16):

Yeah, so it's very hot. It's very hot. It's nice in the morning and it's nice in the evening, which is typical of the desert. It'll cool down quite a bit. But during the day when the sun is out, it is hot.

Alicia Campell (00:02:25):

I'm already stunned and we've just started because it's March. I didn't think it could be 105 in March.

Thomas Dickerson (00:02:32):

It can be. Well, when it's historic, yes. But yeah, it is very hot here. So we've been kind of trying to consolidate our activities into the morning and the evening. So this evening, we're going to go see a spring training game. After the sun is down, of course.

Alicia Campell (00:02:44):

Oh, that's awesome. Do you do spring break in Arizona every year?

Thomas Dickerson (00:02:48):

We do. We do. So my in- laws are from Nebraska and they're snowbirds. So they come down here about three, four months out of the year. After they knock out the holidays, Thanksgiving and Christmas, they always come down here for warmer weather. And it's just been a tradition with the kids and they absolutely love it. They get time at the pool. We get to hike and enjoy the beautiful weather. And down here at this time of year, and if you haven't been, I encourage it because everything is blooming right now. There's these wonderful flowers that just sprout out of the desert and you walk around, you'll be literally walking to the grocery store and you can smell flowers in there. It's just amazing.

Nick Schweitzer (00:03:23):

Yeah. March is by far the best time to be in Arizona for sure.

Thomas Dickerson (00:03:27):

Yeah, that's beautiful.

Alicia Campell (00:03:28):

So what are your kids' favorite things to do in Arizona while they're there?

Thomas Dickerson (00:03:32):

Well, primarily the pool in the backyard. That's the absolute favorite. But we have a few things that we do every year. We try to hit a spring training game. So the baseball down here is great. The other thing we always do is we have a high-

Alicia Campell (00:03:43):

I cannot believe you're saying that as someone from St. Louis.

Thomas Dickerson (00:03:46):

Well, I know. I know. And the thing is, it's tough for me because my whole family are Cardinals fans. And we moved to Kansas City when I was pretty young. So I'm actually a Royals fan, but that's my second team. My second team is St. Louis for that reason. But the spring training games are fantastic. We kind of have two traditions. There's a quartz mine trail over here in the Sonoran Desert and you hike all the way up the mountain and there's these giant quartz boulders. I mean, they are probably, I don't know, 15 feet around and you can get on top of them and we take pictures with the kids every year. And then there's one particular cactus, one of the suarro cactus, they grow huge. People don't know how big they get. Everybody thinks of the typical cactus for Arizona. That's what I'm talking about.

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And those things will get 45 feet tall. I mean, this one's huge. And so we take a picture with the kids every year in front of it, Chelsea and I and Heidi and my kids. And so we have pictures every year and they just keep getting bigger and bigger. Time's really flying.

Alicia Campell (00:04:46):

How old are your kids?

Thomas Dickerson (00:04:48):

So 13 and 12.

Alicia Campell (00:04:50):

13 and 12.

Thomas Dickerson (00:04:52):

Yeah. This is the transition period. Yeah.

Alicia Campell (00:04:55):

Yeah. Yeah. New

Thomas Dickerson (00:04:57):

Adventure every day.

Alicia Campell (00:04:58):

New emotion every day. That's

Thomas Dickerson (00:04:59):

Right. That's right. My oldest is got lots of views, political views about what's going on in the world today. So we come home every night and we kind of debate a little bit and we talk about what's going on in the world. And it's an interesting time in the world right now.

Alicia Campell (00:05:13):

It is an interesting time, a very different time than I ever believed I would parent in, frankly. I did not think I would parent in a time that reminds me of the Jetsons so often. You know what I mean? Where I remember watching that commercial on Saturdays. You had cartoons on Saturday mornings, just TVs or I mean a phone. I mean, my kids are like, "What do you mean a phone plugged in the wall?" I'm like, "God, it seems so normal." And for them it's all like not. So it's kind of crazy, kind of crazy. So you're here for spring break, so we're going to have a wonderful time talking about what's gone on in Kansas recently, which you wouldn't think of Kansas, or at least I didn't, Tom, when I got your text messages, I didn't think of Kansas as being the first state to kind of go through this.

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I mean, I know about Uber, Nevada, and California, but this is a little bit different for you guys. Why don't you tell people what happened and how you found out what was going on in Kansas?

Thomas Dickerson (00:06:13):

Well, so a lot of people don't know this, but the truth is that Kansas has kind of been a historic bellwether for a number of really significant legal, not only decisions, but for different legislation that has had a potential impact nationally. So when Kansas was going to become a state, it was going to be a big controversy as to whether Kansas was going to be a free state or a slave state. And it was a huge controversy at the time. And then we had Brown versus Board of Education, that decision came out of the state of Kansas. And even more recently, we had the abortion referendum in which you had Kansas, a very red and conservative state, totally shoot down in a astonishing fashion, the kind of pro- life movement to get rid of abortion in the state. So for whatever reason, history has placed Kansas at the center in terms of our country as a threshold for some major issues.

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And with our practice being trial attorneys and standing up for injury victims, Kansas has become a bellwether for some other stuff. The chamber and business interests and insurance companies kind of view Kansas as a place where they can go first and test out extreme legislation, legislation that might not pass the common sense muster test in a lot of other states. And so what we've been dealing with recently, and the big mystery reveal is that we've had a slew of tort reform bills lately that we've been assaulted with, and they came out of absolutely nowhere this year. I have to say that all of us lawyers and our clients that deal with these issues and are familiar with them, we weren't expecting it this year, not like this. Kansas in the last 10 years has been very focused on the issues of the social conservatives. So it's been very much abortion centric.

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It's been very much pro- life movement and all the issues that come with that. So trans healthcare and you turn on Fox News and you saw what any of the social conservatives are getting all up in arms about, I mean, that's what has been the focus of the legislation in our state. I mean, recently even they passed a bill that basically takes transgendered people's driver's licenses away. This is national news. That has been the focus. But here lately, the chamber and the insurance companies and business interests have been proponents of countering the tactic of anchoring, and they've made this a big deal. And there's been several other tort reform bills that have been proposed, but anchoring has been the main center of what they were trying to push, and it was supposed to be their main priority in the session. So the bill that they're pushing, focusing on combating anchoring is a bill that basically prohibits any lawyer in an injury case from getting up and asking for any amount of money, any amount of money at all for non-economic damages.

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And so this bill, there's been bills like this that have been proposed in the past in different places, but specifically what's bad about this bill is it prohibits an amount, it prohibits a range of amounts. It prohibits any analogy in the case to argue what the fair trade value of what non-economics may actually be in the case. So in effect, I mean, it's the most draconian of all anchoring bills I think that we've seen. In other states, they don't prohibit what the chamber is trying to do here in Kansas and what business interests are trying to do in Kansas. So that's what we were confronted with and it was a really big problem.

Nick Schweitzer (00:09:49):

Did it also prohibit the defense from suggesting, apart from just saying, no, none, no money, does it also prohibit, does it specify anything about a defense attorney?

Thomas Dickerson (00:10:01):

It doesn't. It doesn't. And very interesting thing about this is we went to the defense bar when this came up and we said, "Well, look, guys, there's all this hoopla about anchoring right now." And as a threshold matter, I don't think we can say that jurors are stupid. Jurors are very sophisticated. They're very smart, they're intelligent. They can sort out right and wrong and good evidence from bad evidence and make a just decision in the case. That is the truth. So we went to the defense bar and we said, "Look, you love the idea of coming in and either asking for a zero or setting a low anchor in a case and asking for a low amount of money." And FYI, if this passes, you're in the same boat as us, guys, you're not going to be able to go ahead and present your low anchor number if you believe in the phenomenon.

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So this is problematic for you. And the truth is they all came to us hush, hush. And they said, "Well, look, we don't really like it either, but we don't want to upset the apple cart. We can't push back against these interests. These interests are our clients and they pay our bills and everything else." So the truth is it would've prohibited any lawyer, whether plaintiff or defense from saying anything. And the truth is the defense bar didn't really like it either, but their hands were kind of tied behind their back because they didn't want to upset the people that were their primary clients.

Alicia Campell (00:11:16):

And so how did you find out this was happening?

Thomas Dickerson (00:11:18):

Well, sadly, we found out it was happening because the bill just got introduced. Sometimes the way that the sausage is made in the legislature, you hope that between lobbyists, connections, things like that, you can get a good preview of what's coming as well the organizations that push these bills, they'll put out policy positions every year and what their priorities in the legislature are. So you hope that you get wind of these things that way so that you can be prepared and you can do something about it. This year we just got the bill. And at that point we just saw it and we're kind of in shock for a second because we had seen anchoring stuff other places, but it wasn't like this. This was a wholly more extreme measure in its entirety.

Alicia Campell (00:12:03):

And so what was the chamber's rationale for beating this? What was their rationale for wanting this? What did they claim is the benefit of such a draconian action?

Thomas Dickerson (00:12:14):

Right. This is what everybody's going to see. It's always, we need an evil scapegoat to push this position that's unreasonable. It is an unreasonable position. The idea, I think our founders would be rolling over in their graves if they knew that you're supposed to have the right to a jury trial, but you can't come into a case and you can't ask for the relief you're requesting. If this was, for instance, if I was representing a business and it was a breach of contract action, the idea that you couldn't go in a breach of contract action and say, "Hey, the other side breached the contract. This is the amount of damages I'm entitled to. " That would blow their mind. That would blow their mind. They'd be paying all their lobbyists for the opposite position. So to get back to your question, the rationale that we heard from in the legislature was that it's the greedy trial lawyers who, in their effort to make more money, they want to fool jurors.

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And they found this brilliant psychological way to manipulate these everyday people and our poor jurors are just victims of this. Just it couldn't be farther from the truth, couldn't be farther from the truth. And what I really appreciate about knowing folks like you guys is that you are studying this and we know that from a neuroscience perspective and a psychology perspective, that's just not true. Jurors are not stupid. In summary, the way that they were selling this thing was they were telling their other representatives that jurors were being subjected to manipulation by trial lawyers and that essentially we were so clever because we would just come in and ask for these amounts of money and then the jurors just couldn't help themselves. They had to give us high dollars. And that's the narrative that was spun and they brought in everybody to try to support this.

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The trucking industry, the medical lobby, the chamber, the insurance folks, the insurance brokers, there was an industry that represents landlords and stuff like that. They came in and supported it. So it kind of looks like trying to push a boulder up a mountain. And when you get confronted with these things and you see all the special interests that are on the other side of it, and then you look behind you and you say, "Well, it's just us and people. " In the state, it can be a pretty daunting prospect. And that's what we were dealing with this session.

Alicia Campell (00:14:41):

And were legislators receptive to this idea that jurors can't know any better, don't know any better? I mean, because by that logic, if you take it to its end, it's like, well, then how does a defendant ever win a case? A plaintiff lawyer's there and asking for money. I mean, how did they respond to this argument? Did it seem like they thought it had any heft to it?

Thomas Dickerson (00:15:03):

Yeah. Yeah, they did. And you're absolutely right. The proof is in the pudding. Where's all these massive verdicts in the state? If in fact, it's so easy for us to go into a court and get in front of a jury and ask for these high numbers and we just get them, where are all these massive, massive, massive verdicts in our state? And there are some big verdicts, but if you look at those cases, the truth is that they're meritorious cases with usually really bad catastrophic damages and the jurors sorted it out the right way. So their reaction from everybody, the other representatives that heard this, one of them actually got up and said, "Well, anchoring is a phenomenon that's known in psychology. We just need to trust the science. This is not correct." I mean, that's essentially what he said. And so I was kind of taken aback by that because if you know anything about trying cases and you've tried cases before and you've been in a courtroom, you know with a hundred percent certainty that it is not as simple as going in and saying, "Give me a hundred million dollars," and then they give you a hundred million dollars.

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It doesn't work that way. Trial is so much more complex than that, and these people really do care about jury service and getting it right. And I've been on the receiving end of defense verdicts where I disagreed with it, but I look back at a lot of those cases and I say, "Well, yeah, the jurors probably got it right in terms of what evidence they had and everything else."

Alicia Campell (00:16:26):

Yeah, it's just an incredible position to me for them to have. And so it makes me just a little nervous to know that it has such an audience that can hear that and go, "Well, yeah, I wrote about that in a book somewhere." I mean, the one that people bring up a lot is, well, I saw it or I read it and thinking fast and slow with Kahneman, which is a lot of people's Bible in terms of this type of research. But I mean, even that is a bad substitute for what we deal with in trial because that whole chapter isn't about context, it's about the lack of context so that people are anchored when they know nothing else. That's not what a trial is at all. They have nothing but all the facts. We have to give them that. There's no lack of context.

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So it's just a crazy argument to me to make straight faced. I mean, of course everybody can ... It's like, yeah, well, Alicia, hello. Of course she would say that because it's true. It's really just true. So it startles me that this many people would be receptive to it because, I mean, then how does a defense attorney ever win? If the odds are so stacked and jurors can only hear numbers and money and can be manipulated, then I guess a defense attorney just has no ... I mean, what are they paying all these people for to represent them? They should just walk in, be unwrapped and be like, "When the plaintiff attorney asks, the jury will give it to them." Except that's not how it works at all. So it's fascinating to me that people would respond well to these kind of arguments. Did they ask any good questions?

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Well, because I mean, there were like, well, we should probably start. We should back up because I know more than I should probably be saying. But there was testimony and things like that given during this process. Is that right?

Thomas Dickerson (00:18:02):

There was. There were questions that were asked and I viewed the debate and the process of you had kind of three different categories of folks that were taking a position. For a lot of the Democratic folks who are typically, you look at trial lawyers interest in terms of what issues we're concerned about, usually the Democrats are the ones who are listening to our issues the most. Those were a lot of the folks that were asking questions. A lot of the questions were focused particularly on not the psychology, but the reality and a pragmatic approach asking questions about, well, what happens to the elderly and what happens to sex abuse victims and what happens to people whose damages are primarily non-economic and what happens to those folks? So these were a lot of the questions being asked. And the truth is it would detrimentally affect all those people in a really horrible way.

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Then you had the folks that were just on board with what the chamber wanted, which was this bill to be passed. And they're the same people where unfortunately people like me and trial lawyers, we can't really have a discussion with those people even though we would love to engage and we would love to have a rational discussion with those folks and we would love to talk about policy and we would love to talk about making courts fair for everybody with the other side. We would love to do that. That's exactly what this country is about. And now again, legislation is done is you have a dialogue, you have a debate, and then you try to get something that really is fair for everybody. There were those folks, and there's not really anything that we can say because they don't really want to listen to us.

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Then there was a third category of people in the legislature, and I would kind of put those folks into the constitutional conservative box. And these are the same people that they know that this country was founded with the idea that we have certain freedoms and rights, and that's what it is. So those folks are a little bit more receptive to hearing what we have to say because they do in fact believe in the right to a jury trial in its purest form, no different than they believe in freedom of speech. In this country, people can say things that might hurt somebody. They might say things that you vehemently disagree with, but they have the right to say it, and that's an important thing in our country. And what we try to do with those folks is talk to them about how, well, look, we love the First Amendment, we love the Second Amendment, we love the Fourth Amendment.

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We have all these fundamental rights in this country, but if you value those things, you also have to value the Seventh Amendment. Those people are more receptive to our message because they realize that constitutional rights are really important and they worry like we worry. What happens if you take away the right to a jury trial and no longer can you go in and ask for relief in a case? What's next? Does someone who disagrees with the idea that a business could come in and sue on a breach of contract case and then take away their right in that case to ask for relief in their case? Or for a lot of folks, especially over in Missouri, this is a huge, huge issue where we've got a very, very strong Second Amendment proponent base in the state of Missouri where I practice also. What happens if we take away the Seventh Amendment, what happens to the Second Amendment?

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Are they going to start limiting your right to bear arms and things like that? So that third group we talked to quite a bit, and that's where we were able to get some support.

Alicia Campell (00:21:39):

Oh, that's nice to hear. I mean, because I think the constitutional parts of it are the most important, but I'm not always certain that people fully comprehend the constitutional implications because you're exactly right. How do you stop it once you start this? How do you pick? How do you choose? Yeah. Yeah. So the group that was a little more Democratic, they were super receptive. So how did you create any kind of cohesion for the plaintiff's bar, especially since you guys didn't really know it was coming? What were some of the things you guys were doing to do that?

Thomas Dickerson (00:22:09):

Well, I mean, the first thing we did was we look, our trial lawyers organization in Kansas has a legislative committee and we talk every legislative session when bills come up, we talk about what's coming up and we talk about what to do about it. When this particular bill came up, there's some things that we have a conversation on and we say, "Look, we could work with this. Let's talk to the other side. Let's see what we can do to compromise." This was really more of a no compromise situation because when you start trying to take away people's constitutional rights, you have to stand up and do something about it. You just have to. We have an obligation in this profession doing what we do to stand up against the powers that be and try to protect people's constitutional rights. It's the most important thing that we do as trial lawyers that represent everyday people.

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First and foremost, I mean, getting big settlements and verdicts is great, but that is a product of having a strong foundation of a jury trial and constitutional rights. And if we don't stand up for those things, then we're really lost. And so this was one of those things that we said, look, we can't allow this to pass and we have to be all in on organizing to do something about it. And fortunately in our trial organization, we have some folks who are like- minded and adhere to that philosophy. And so we started to mobilize around that idea that we really needed to stop because it was the right thing to do. I mean, forget anything else and how it may impact anybody else financially, this is the right thing to do to oppose this.

Alicia Campell (00:23:41):

And so for people listening, just you talking about it made me think, if you're a lawyer who believes just as we do that this is something we have to stand up for, we need to be on the forefront, we need to be doing it, what's the ways that they could be tapped into this? Because really, frankly, I didn't know until getting text from you and emails from you and listening to how it's working, I'm not tapped into that part of the Missouri Bar, for example. So that might be helpful too for people who are listening, because I know once I mentioned this was happening on a couple calls, people were like, "Oh, how do I get involved? How do I find out about it? How do I help and help mobilize?"

Thomas Dickerson (00:24:17):

So this is the ultimate question, right? How do you organize the plaintiff's bar? It's a struggle that I feel like we've been dealing with forever, and it's probably the biggest problem we have. We're fragmented. And I think some of it is based also on the tort system itself, because if you think about the tort system itself, the tort system itself is fragmented. We don't have a federal tort. I mean, besides the 1983 cases and the Federal Tort Claims Act, each state's laws are the tort laws for the state. And so by its very nature, I think we're segregated a little bit. Kansas is segregated from Missouri and Missouri is segregated from California and California is segregated from Texas. And because that's the case, we all have our own battles that we're fighting all the time. That makes it really hard. It makes it hard to organize because our interests aren't always ... And here's the thing, I say our interests aren't always aligned.

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Our interests are aligned on some key things. And I think that's one thing first that we need to recognize is as trial lawyers, we are stewards of the Seventh Amendment and the right to jury trial in this country. That's what we are. And we have the obligation to look at that first and look at it from the big picture. That's hard though to put at the pinnacle of priority when, for instance, you have fights going on like right now in California where Uber is trying to cap attorney's fees and not only cap attorney's fees, but a cap attorney's fees in a fashion that it will not even be economically feasible for everyday people to bring lawsuits anymore, lawyer not. So the question that you pose is a question that is extremely difficult to address because I don't think we have the right answer at this point.

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I think we're developing some answers and I think that there's some very strong leaders that are in the plaintiff's bar right now who probably need to use their platform to reach out to folks and to get organized. I'll speak from personal experience here and tell you some things that I think are ways that people can get organized. The first thing, first and foremost, everybody needs to get involved in their trial lawyers organization because they're trial lawyers organization for their state. So everybody's got either ... For Kansas, it's the Kansas Association of Trial Lawyers from Missouri. It's Missouri Association of Trial Attorneys. And in California, it's the Consumer Association, forget the actual name of it, CAOAC, whatever that stands for is the organization out there. So that's the very first thing that you can do is you can get involved in that organization because that's the organization that's going to be involved in the lobbying of the state legislature, paying attention to what bills are up, things like that day-to-day.

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Beyond that though, I would really encourage people to get involved in other organizations that are taking the fight nationally and also doing things to support other states that are dealing with problems. So there's very good leaders that are out there right now. Nick Rowley, who's a law partner of mine and fantastic trial lawyer. He got together with some people and started an organization called Justice Watch. Justice Watch is an organization that keeps their eye out for judges that support the right to a jury trial and judges that are not supporting the right to a jury trial, and that can go out and influence states where there are judicial elections. That's another organization. Right now in Kansas, we are in the process of starting and probably over this summer it will be launched. We've already got the gears turning on it. I haven't told you about this yet, but I'm very excited.

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We're starting an organization with everyday people, and it's a grassroots organization. It's going to be called something along the lines of injured Kansans for justice, and it's going to be comprised of people that have been through and have experienced the tort system themselves. So these are people that have had to file a lawsuit, who've obtained a settlement from an insurance company. They know with certainty that there's this narrative out there that the deck is stacked against corporations and this and that. Well, the truth is the deck is stacked against everyday people and all the time these corporations and these monied interests are trying to chip away at people's rights, constitutional rights. What we've found is extremely powerful is the same thing that's powerful in the courtroom, and that is people telling their stories, people telling their stories. The way that we've been able to get traction against the anchoring bill that was up this year was bringing our clients, bringing the victims of sexual abuse, bringing the victims of medical malpractice, explaining to the folks that, look, these are your constituents and they're telling you exactly their story and how this would affect them.

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And that's so much more powerful than the lawyer getting up and saying it. And we don't have that in this country right now, and we need that in this country right now. We need these stories and our clients to get up and to speak themselves. Unfortunately, it's very difficult to organize that, and so that's why as lawyers, we got to get up and stand up and help do that. So those are all things that we're kind of doing right now. The most fundamental thing you can do is get involved in your trial lawyers organization, but I'm super excited and I want to hear a little bit about what you, Alicia, are doing and what you, Nick are doing with some of the juror research because for us in Kansas, and I don't want to spoil it, I want you guys to talk about it a little bit, but we used some of the research that you all had on anchoring to get evidence submitted to the legislature that was really impactful, to counter some of these narratives that are false.

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And that's really important. We have to make sure that the truth is out there and the There's way, way, way more to this anchoring idea. Whether it's true or not, I don't know. I think there's probably some phenomenon, but once you start taking something that's been studied in very simple ways and trying to put this phenomenon into the juror context, which is complex decision making, I think it's a square peg in a round hole. So I'm interested to hear what organizations that you guys have. I've heard like JEDI and some other ones that we may be able to support.

Nick Schweitzer (00:30:26):

Yeah. Well, this is really interesting because it sounds like there was some frantic texts sent between you guys and then I started getting a frantic text saying this thing is happening. What do we have? Do we have research that has been done, that can be done on it? And it turns out we have. So over the past couple years, working with John and Alicia and Jedi, the nonprofit that they have started, we have been able to kind of assemble quickly, oftentimes, research to address very specific questions that have popped up. These are typically questions that kind of speak to the assumptions being made by whether it's legislatures or specific court cases or something like that, and kind of tackle it from a psychological and a scientific perspective. So with this particular situation, we actually had a lot going on already. So there's a number of people involved.

(00:31:28):

So it happened that a couple years ago, Samantha Bean, who was a graduate student of ours at Arizona State University, worked on a dissertation. And the question was, what happens when you allow or don't allow an attorney to request a specific amount of money? And what the thought is, well, are there consequences perhaps if you don't let that happen? And I'll come back to that. But then also in parallel with that, we're thinking about this idea that, oh, the jurors are just kind of anchoring. And every time someone asks for a certain amount of money, they're just giving it to them. Well, we have along with John Alicia studied in the big data sense, many, many, many, many cases. And just first of all, intuitively, we know having seen the results of those, jurors are not just giving the amount of money. They rarely, in fact, the amount of money asked for.

(00:32:20):

So that got us thinking, so how often does that happen? And so what we were able to do is we were able to look across a lot of the cases that we had studied over the past couple years, and we thought, okay, well, if jurors are anchoring, what would it look like? Because in a lot of these cases, we actually test different requests for non-economic damages. And so basically we've created randomized experiments testing the impact of essentially anchoring. We would say it's not really anchoring, but what these folks are calling anchoring to see, well, how big of an impact is it actually making? And I mean, the takeaway from that study was that it's rarely happening. And in fact, when you ask for different increasing amounts of money, we wanted to know, well, how often are jurors then responding by giving you those increased amounts of money?

(00:33:13):

And when we use kind of traditional statistical methods, it's happening very rarely, less than 10% of the time. And in fact, 70% of the time, if I'm remembering these numbers right, you find no statistical impact of these different requests because the jurors are not necessarily just listening to these requests and giving money. They're listening to the case, they're listening to the evidence, they're listening to the facts and they are figuring, well, what's the right compensation in that sense? And they're giving it. And we were able to look at this in a couple different other ways. We looked at a huge dataset, and I mean, not to bore anyone with the statistics of it, but we can look and see, well, okay, of all the statistical variation in damage awards, how much of it was actually related to the amount of money the attorney asked for?

(00:34:02):

And the answer was less than 1%. Less than 1% of the variability in those damage awards had anything to do with what the attorney asked for, tiny, tiny amounts. So those two things together just tell us right away like, "Okay, this is just not happening. This is not an issue." And also mentioned the entire ... I think Tommy, you were kind of alluding to this, but anchoring is talked about like it's a bias of some sort, and the original research is like, write down your zip code and then guess the number of countries in the world or something like that. And oh, if you have a higher zip code, you guess a higher number than if you have a lower zip code starting whatever. And that just is supposed to show, oh, you have this little thing in your head that kind of goes off that kind of pulls you one way or the other when it really shouldn't.

(00:34:51):

Well, those are all trivial sort of little isolation kind of things. And they don't really hold up when you're talking about actual meaningful numbers like you would have in a court case, not to mention all of the context and everything else that goes along with the whole trial. I mean, we just found almost no evidence that there is really anchoring of any kind going on. And when we do, we look at some of these cases, and a lot of times there's kind of ambiguous levels of harm, or there's a lot of harm, it's catastrophic, and it's situations where jurors really kind of want guidance because they don't really know, well, how much is this terrible, terrible thing worth? And so they have no idea. And so they might take some cues, but again, these are just the most ambiguous of the cases and again, very, very rare.

(00:35:40):

And so we thought, okay, let's pair that going back to this dissertation that I talked about earlier. Well, so then what's the harm? What would happen if we actually forbid people from making these requests? And there are downsides in fact. And so the biggest downside, and this has been shown not just in Santan's research, but in other research as well, when jurors don't have ... So okay, we know jurors struggle to figure out how much these kind of intangible things are worth, and they need somebody to go through and lay it out for them, not just throw out a random number, but attorneys don't just throw out a random number. They say, "Well, here are the things that happens. Here's why." You justify it. You argue it just like you argue any other point of your case. When you don't get that, jurors start to just wildly guess and they wildly guess sometimes producing really, really high awards, sometimes producing really, really low awards, but they're all over the place and they're less calibrated to the actual kind of harms that are going on in the case.

(00:36:42):

And what's beyond that, what you start to see is a lot of the things that you would hope are not necessarily influencing decisions like personal biases and things like that. Those start to pop up because they don't have anything else to base their numbers on. So all of a sudden all these things, these extra judicial, extra legal things are starting to show up in their awards. We would hope that you don't want that. You want the awards to be based on the actual facts of the case and the actual harms, and instead it's not. So I mean, these two things together just kind of made it very, very clear, very obvious. Anchoring isn't really a big deal and it doesn't really happen and jurors aren't just blindly doing this, but when you take it away, you have worse outcomes. You have less fair, less just, less calibrated to the case award.

Thomas Dickerson (00:37:32):

I think that's so funny. The idea that, okay, we're going to propose this anchoring bill. Hey, you can't even ask for any specific amount of money anymore. The ironic thing about this, I've found this specifically in focus groups that I've done recently with John and Alicia, but what we're finding is it sows chaos. And the funny thing is insurance companies want predictability. They want to know what to expect. And the funny thing is this very bill that they're pushing, it's ironic that in doing this, they're going to have the opposite effect, but it's the product of them reading an article in a plaintiff's magazine where they talked about anchoring in probably a way too over simplistic way that isn't accurate on the science at all. And so the funny thing is they actually could be shooting themselves on the foot here by doing this. The reality is when they're like, "Well, if the trial lawyers are fighting against this, well, it's because it's going to be negative for them." No, the reason we're fighting it is because you're trying to violate our client's constitutional rights.

(00:38:29):

That's why we're fighting it because we have to take a stand on this, because if you take away this constitutional right, it's going to take away another constitutional right down the line and we can't allow that slippery slope. But it's really interesting that you say, "Hey, we're going to have some chaos here if we go ahead and these things happen. If lawyers don't get to ask for money, who knows what happened?"

Alicia Campell (00:38:50):

Yeah, it came from our overall frustration with places like Pennsylvania. So we've been running studies forever where, oh, I get on a call, I'm like, "Oh God, you're from Pennsylvania. Okay." And for us on the build end, what that means for our studies is that it comes with a bunch of warnings. I don't know if you know this, Tom. So we don't have to do this in Kansas, especially now. And we don't have to do this in Missouri, but in Pennsylvania and New Jersey, we have to give warnings to jurors and say, "Hey, nobody's going to give you a number in this case." They're not allowed to give you a number in this case because actually jurors are very irritated by that fact. They're very irritated and we get feedback from them that they're like, "You know what? I don't like this. Look, I may not agree with this attorney and I may not agree with this attorney on all things, but they live and work in this field.

(00:39:40):

And if anybody who can tell me what an arm off case is worth or not worth, it would be the attorneys who've spent all this time litigating the case." So for us, we knew, and that's kind of what started Sam's dissertation is we were like, we have to get at this idea that not giving a number is okay because none of our jurors like it. And they're very good at telling us, "Hey, we don't like it when we don't get a suggestion," which also means jurors are just taking it as a suggestion like, "Tell me what you think it's worth and I'll tell you whether or not I think your evidence supports it or I agree with you. " And so a lot of times what we see between the damages asks where people ask for too much and then they start to see their liability rate fall is because jurors are actively rejecting the number and now you're losing credibility with them.

(00:40:29):

So the fact that this was the play, I'm like, this could not be ... And I mean, think Pennsylvania bears it out because West Ball got a billion dollars in Philly and you would say no.

Thomas Dickerson (00:40:40):

Respired all verdicts up there were billions as well.

Alicia Campell (00:40:43):

Yeah. And so it just kind of lets ... You become more of a victim too of the due process that you get in courts. And I like saying that. I know that's usually used for plaintiffs, but that's how I view voir dire. It's another element of due process in the court system. So the less that you get, then you are going to seat a jury that is more biased because we're not doing the things that we need to to make sure we're getting at that. And then you're giving those people no number. Talk about tainting juries because it's something that we can't have happen because the one thing that Mike, what? I think we've been doing this 11 years now. I don't know. I don't like to think about it because it reminds me I'm old. John and I talk about this a lot. One of the bedrocks of the democracy that we have to protect, and Tom, I think you're absolutely right about this.

(00:41:32):

And maybe you talking about, maybe think, is there some way, because Justice Watch is great, it's going to be featured at jury ball. And Jedi is the right way to go with this too, because you have to be a fool to ignore actual data. So our idea is that we're going to write papers with the help of Cornell and Jess and Nick to basically lay out this is what the data says about this particular thing that Chamber's upset about or the plaintiff lawyers are upset about. But I think there has to be some kind of solidifying of the jury system because we've done over 1,400 cases now. And I'll tell you, there are reasons that I am stunned by a jury's verdict when I think to myself, "Oh, it's a pretty good case." And we run it and the results go back and I go, "Ah, this did not jive with what my instinct would be here." But then when I go through and I read and I look at the data coming in and the juror comments and the reasons why they're not finding liability, I have never once been like, "Well, that doesn't make sense to me.

(00:42:28):

" It's usually something in the case that I didn't recognize would be a big deal to jurors or I didn't see the significance or the way it could be seen by other people because I'm a lawyer and I'm in my bubble, but jurors work hard and they try to do a good job and they want to get things right. And it's just like such a fundamental important thing, especially now in this political kind of atmosphere that you know what? A group of 12, just for the sake of, I love that number, the group of 12 coming in and as a community group saying, "No, we are not tolerating this is I think something that's so ... It's the best system on earth. It just really is. " So you're right, we need to come up with some way that we're gathering as a group, making sure we're contributing.

(00:43:12):

And I can tell you it's going to be a big push at Jury Ball Madrid. I told Sean months ago, "Hey, I need the Justice Watch stuff because we're going to flank the stage. One side's going to be Justice Watch. One side's going to be Jedi. It's going to have QR codes. You're going to hear me say it, you need to donate." And then all the sponsors that are coming to Jury Ball, Madrid are donating. So they're paying their sponsorship fee and half of it's going to Justice Watch and half of it's going to JEDAC because we do need to fund these in a way that, because I think the last round of tort reform really kind of put trial lawyers on their heels. We all started changing our names. We took trial lawyers out of our names and I think this time we just need to really go with this justice because we're right about it.

(00:43:56):

What I tell people in Spain when they come up to me and they're like, "What in the hell is going on in Minnesota? What am I watching?" What is going on? I'm always happy that what I get to say is, "Yeah, right? You're watching this, right?" You know what Americans are going to be grateful for after this moment? Trial lawyers because when you watch the government get in the way, not do what they need to, come out with an early message, I can tell you, I can assure you there are people on the ground who are interested in standing up for those people and getting to the bottom of what actually happened. And we need to get that message out because I don't think that Americans see that as clearly as when I say to a European who spent their time watching law and order and they're like, "Oh yeah, oh yeah, I've seen this whole system you guys have.

(00:44:41):

It's fascinating." I think Americans maybe are a little too used to it. Sometimes I worry that they think it's ... Because that's the other thing. I think it's Valerie, right? Maybe it's Valerie who did ... Yeah, it is Valerie who asked jurors immediately after rendering a verdict if they thought the process was an enjoyable one, if they felt like it was something they liked doing and that the rate of satisfaction after being a juror is pretty high actually because the process isn't as bad as we tell them it is all the time. "So sorry to waste your time. You have to come in on a form. I think we've kind of made it more than it needs to be.

Thomas Dickerson (00:45:17):

Well, one thing we need to do a good job of is messaging to jurors, especially in the actual trials themselves and say, look, this process is so important and we believe in it. And I think by the end of this case, you're going to believe in it and this is going to be a positive experience for you. No one wants to show up for jury duty, but we've had great experiences afterwards, jurors coming and talking to us and saying that it's wonderful. Speaking to what you were saying though, yes, I mean, the justice system is about accountability. And I think in this country right now, it's a special time for lawyers to kind of reclaim the credibility of our profession. I think if the Justice Department is reformed and does some things in the next five to 10 years, and we see some things happen in terms of investigations and other things, it's a chance for lawyers to reclaim that position of credibility in society.

(00:46:04):

But we have the same opportunity as injury lawyers that represent people. We can do these things now. It is about organizing. And Madrid last year was extremely special. We have to hand it to you both. It was an amazing conference, probably the best conference I've ever been to. Oh,

Alicia Campell (00:46:21):

Tom, thank you. I just got goosebumps.

Thomas Dickerson (00:46:24):

Thank you. I'm serious. And if anyone's watching this, they need to register immediately and get ready to go to Spain because it'll change your practice, it'll change your perspectives, it'll change your life as a lawyer that does what we do. And certainly it did for me. It was an amazing experience. First time, and this is what was so fascinating to me is I've done a lot of focus groups in the past a ton. This was the first time I saw all of these amazing accomplished people that are just on the cutting edge, that are interested in the psychology, that are interested in juror decision making, that want to do the right thing and want to reform this country in the way that we administer jury trials in the right way to ensure fairness for everybody. And so being in a room of those people and learning from those people, it's just fantastic.

(00:47:11):

And I'm stoked. I'm ready to go right now, in fact. I'm ready to get right back over there to Madrid and also eat some liberico ham.

Alicia Campell (00:47:19):

Yeah, of course, right? And have a little wine. Well, I mean, and you're going to be one of the cutting edge speakers. I mean, you can't leap that out. I mean, we got to talk about all your success that you're having in addition to what you're doing to help shape the landscape in Kansas, which is very admirable. You didn't sit back.

Thomas Dickerson (00:47:36):

The thing we got to do is go try cases. That's what we have to do. And we have to stop taking the last best offer and we got to stand up and do the right thing. And I think the biggest thing that all of your fantastic work has shown me, both of you, is that right now is the best time ever to try cases. It's the best time ever to represent people. The atmosphere in this country right now, jurors are frustrated. There's been corporate power for a long time. They've been taking rights. They have been making a lot of money at the cost of everyday people. Things aren't affordable in this country anymore. People are frustrated and in the jury box, their voice is actually heard. And so they have the opportunity to speak out against injustice in that jury box and they want to and they're anxious to.

(00:48:22):

And so right now is the best time ever to be out trying cases and asking for justice for your clients to get fair value. What Jury Ball does and what the research that you all are doing is opening people's eyes. I've always been a fairly decent trial lawyer, I would say. I've gotten some really good verdicts and some really good results, but what the focus grouping has done and the psychological research that you all are doing is allowing us to raise our standards. I had this case last year that we settled for $95 million and I looked at it and I have a confession to make. The confession is I thought it was probably worth maybe 20 or $30 million. It was a massive case, but I had no idea. I had no idea that it was worth what it was worth. And what the focus grouping that you all do and the research that you all does allows folks like me to open our eyes to what these are actually worth.

(00:49:16):

So we've been a product of that and we've implemented in our practice, and I'm definitely anxious to share some of our other results with folks to see how they can implement it in their practices and help out as well. Because again, not only the beauty of what you're doing is it's not only to help lawyers get better results, but at its most fundamental level, what we're doing is we are advancing the fight for constitutional rights and fairness in jury trials, fairness in jury trials. That's the thing. So like having robust voir dire, that's a fairness issue. Both sides should be all for that. Allowing a lawyer to get up and ask for what damages are appropriate in the case, whether you're a plaintiff or a defendant, whether it's zero or whether it's a million dollars, that's fundamental fairness. And so what you're doing is fantastic.

Alicia Campell (00:50:02):

Aw, thanks, Tom. That's nice. And what we couldn't do without Nick and Jess, it's a nice little group we've got going that I love very much. It's also like, I don't know, to me it's like you're very good at this in your presentations. I tell many lawyers who are struggling with these kind of issues that, well, Tom Dickerson goes through what is a part of an apology. When he has an admitted liability case, what elements of an apology are necessary? What do we teach our kids? And really that's what all this tort form gets to, right? Like, "Hey guys, if you're a corporation and you are okay with breaking the law or not paying attention or being in the business of general negligence just because that's cheaper than actually paying attention what you should be doing, then I think the way this happens is we do voir dire and we ask people what they think of it and whether or not they think this is something we want to tolerate if your admission is actually valid and we treat it just like we raise our kids.

(00:50:59):

For the life of me, I can't figure out why that would be bad."

Thomas Dickerson (00:51:02):

It's wonderful. I mean, the whole system itself is about accountability. That's really what it's about. The process of justice, I think, is double-sided, right? It's compensation for the plaintiff, but at the same time, it's accountability for the defendant and so that they learn an important lesson so that the next time the situation comes up, it doesn't happen again. And that's so much of what we do. I mean, we had a case that we tried in December and got almost $5 million on a premises liability case. We did the study with you, Alicia. And in that case, it was funny because the defense lawyer got up in closing in rebuttal and he literally said, "The plaintiff here and Mr. Dickerson does not care about the safety of people at this hospital. They care about getting money for their client." That's what they said. And the funny thing was I have emails going back four years with this law firm on the other side saying, "Hey, can you guys go fix that condition over there so somebody else doesn't get hurt?" And after the verdict came in, I sent an email to them and I was, "Hey, for the record, you got up and said we didn't care about safety about anybody at this hospital, but look at my emails from the past four years.

(00:52:12):

We've been asking you to fix the condition." And so there's so much of what we do that's also about making sure that safety happens, that accountability happens, and that we improve things for everybody in society.That's what really this is about. And look, it doesn't help me personally if somebody else gets hurt at the hospital, I may have another case. So it's none of my interest financially to make sure society is safer, but the truth is that's the right thing to do. And most lawyers that try cases, that is why they do it. The lawyers that are really good at least, the lawyers that are getting these massive verdicts, and a lot of them are going to be in Madrid. A lot of them are going to be in Madrid. And if you sit down and you talk to them, there's a reason that they're getting these massive verdicts and they're talking about the right things at trial.

(00:52:56):

They're talking about the things that actually matter, and that is making things better for everybody, both the plaintiff and the defendant. You want to make sure that it doesn't happen again, and you want to make sure that the plaintiff gets justice and is compensated appropriately.

Alicia Campell (00:53:08):

Well, and you saying that makes it even more clear why we need the jury system to be as cemented as a bedrock in the United States as possible, because you're right, the founding fathers would be turning over in their graves because the jury system is to take to account the moneyed interests, the more powerful in the country. So it should be very ashamed. It should be like something the chamber ... And the chamber never does once talk about how they go to the mat to limit a juror's ability to assess their actions in a particular case.

Thomas Dickerson (00:53:39):

And to circle back what we were talking about earlier, we need to do a better job as trial lawyers communicating with the legislature, and we need to let them know, look, this is what we stand for, and this is what we're trying to do. And these are the things that we're working on. And this is what we're trying to do is make things better for everybody. That's what we're trying to do. A lot of the fundamental things that you all are researching are things the defense should be 100% behind, 100% behind. I sit down to defense lawyers for a drink sometimes and I say, you're critical sometimes of plaintiff doing voir dire. And I'm one of those people, I'd hear the philosophy, I strike biased plaintiff jurors, just like I strike biased defense jurors because I believe in a fair trial for everybody. And in order to get that, you need just fair and neutral juries.

(00:54:24):

So I say, look, would you rather have more time for voir dire where you get to weed out all the people that are going to be biased against your case or not? Everybody knows the answer to that. The research you all are doing, they should be behind it too, because it's going to be better for them and their case.

Alicia Campell (00:54:41):

You're absolutely right. They should just be on board because it would help everyone.

Thomas Dickerson (00:54:44):

Yeah. Yeah.

Alicia Campell (00:54:46):

When I was in law school, John and I lived in Collinsville and we would travel. We taught high school during the day and then every night, well, four nights a week, we went to law school at SLU. And it was really interesting because I used to love that drive because for a while the Illinois Association of Justice, I think is what they were called at that point. They just had billboards and it was a giant picture of Abraham Lincoln and all it said was he was a trial lawyer. I always thought that was so like, we should put that all around ... Because I mean, Abe Lincoln's not really, he's not a radical person. I mean, maybe in the South, I don't know. But for the most part, I think most people don't think of Abe Lincoln as a bad dude, but it is such an important part of his makeup was that he was a lawyer and they debated all the time.

(00:55:31):

And I just think if we could do something, maybe Tom, we need to have another call about, "Hey, how can we do this? Because you're right, I think the time is now." And then it's just like, how do we get everybody to the mat? That's really what's going to make a difference. And we have this time where if there's any time where Americans can feel it, like having an independent judiciary, having the ability to walk into court themselves and make a determination that's within their control, I mean, now's the time, right?

Thomas Dickerson (00:55:58):

Oh, absolutely. I don't think when our founders got together, they had the idea that there was going to be special interests, the corporations that were just going to be like Frankenstein. They live forever. They've got unlimited money. As a trial lawyer, my career will be finite. I'll try a certain amount of cases, I'll die someday. And hopefully my daughter takes up the banner or my son takes the banner, somebody does. But our ability to push back against the tide is really important. And I don't think anybody ever visualized that these corporations were going to be as long around as long as they are with as much power as they have. And so they can make these sustained pushes for policies and things like that. And so that's why it's so important that we get organized as the plaintiff's bar. And I think that's the thing that we really need to talk about in the future, is how we organize and how we get the message out to make everything better for everybody, because we have that opportunity.

(00:56:53):

It's just we need to sit down and we need to have that conversation. And it's not something that anybody's going to be able to do by themselves. It's something that it's going to take a huge group effort. And that's one disadvantage that we do have. A corporation with a ton of money and a ton of resources like Uber, one Uber can take on all of the people in the state of California. And so it's tougher for us to get organized, but that's why it's so important that we do something and that we get organized. And there's lots of ways to do it and we've talked about some of them, but I'm looking for that kind of conglomeration of we get a lot of people that care about doing the right thing together. And if you do that, I think you can accomplish great things.

Alicia Campell (00:57:35):

I agree. I'm looking forward too. Maybe we can start it in Madrid because that's where we're going to

Thomas Dickerson (00:57:41):

Try. I think we already started. I think you already started it in Madrid. I told you this story, but I was one of my favorite places in the entire world now is Rotiero Park, Madrid. It's the most beautiful place on earth. It's beautiful. You walk into this place, there's nobody working on anything, but you have these beautiful botanical gardens and you have this beautiful lake and there's people out there with rowboats. It's like just right out of a painting is how it looks. And I was sitting in the park at Jury Ball. We had just done our first day of continuing legal education out there and you all did presentations and my mind was absolutely blown by everything that I had kind of taken in. And we're sitting there at the park and I'm like, wow, this changes things, I think. Not only what we're learning here, but the people here, because in order to get to Spain, I'm sorry, you got to pay for the ticket, you got to take the time out of your life.

(00:58:36):

And so in order to get out there, I mean, you got to be pretty motivated to do it. So the group of people that was out there was pretty special. And I was sitting in the park there overlooking that beautiful lake where all the robots are with the beautiful sculpture. And I was talking to Sean Claggett and Nick Rowley about what it looks like in the future with tort reform and coming down the pipeline and what's going to happen once the focus group results and everything that's happening that you all are doing that is absolutely cutting edge right now, eventually it'll be mainstream. And I think that what's happening in Kansas right now is just going to get amplified. I mean, they're going to be passing tort reform in all states. And so I hope this podcast and the conversation might motivate some people and get them interested in what's happening in their state because what's happening in California, what's happening in Kansas, what just happened, unfortunately in states like South Carolina and Florida and Georgia, that's coming everywhere.

(00:59:32):

And we just got to be prepared for it. We have to be prepared for it because we're the only people that will stand up and stop these unjust laws from taking away people's constitutional rights.

Alicia Campell (00:59:41):

That's exactly right. Well, that's a good wrap-up point, I think. We've been talking a while. It's been easy.

Thomas Dickerson (00:59:47):

Sorry, I've been talking way too much.

Alicia Campell (00:59:49):

No, no, no. This is wonderful. This is wonderful. Nick, do you want to do the close?

Nick Schweitzer (00:59:54):

The close.

Alicia Campell (00:59:55):

Yeah. Do you want to do like-

Nick Schweitzer (00:59:56):

Well, thank you, Tom, for being here. I mean, this is great. I mean, I love hearing about all of this. I'm not a lawyer, so I get to learn a lot about all of this by speaking to people like you and being at Jury Ball. I get to talk a little bit about data and science and all that sort of stuff, but it has really no context without really hearing it and understanding the landscape of all of this from folks like you. So really appreciate it. So I guess thank you and thanks everyone for listening and we will be back shortly probably with another podcast.

Thomas Dickerson (01:00:30):

Appreciate it guys. Thank you so much.

Alicia Campell (01:00:32):

Thank you, Tom.

Voice Over (01:00:35):

Thank you for listening to The Fred Files. If you found value in today's discussion, please subscribe and share this episode with your colleagues. To explore how Fred can transform your case preparation, visit us at focuswithfred.com. Produced and powered by LawPods.

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