The Art of Case Budgeting

Episode Notes

Transcript

Jim Reeder:

Hello everyone and welcome to Litigation Radio. I’m your host, Jim Reeder. I’m a recently retired lawyer who practiced antitrust and commercial litigation in the Houston office of Jones Day. In addition to trying lawsuits, I’ve spent my entire career focused on helping young lawyers become great lawyers. On this show, we talk to the country’s top litigators, judges, in-house counsel and academics to discover best practices for developing careers, winning cases, getting more clients, and building a sustainable practice, all while staying well and happy. Be sure to subscribe to the podcast on your favorite podcasting app to make sure you never miss an episode. Litigation Radio is brought to you by the litigation section of the American Bar Association. It’s where I make my home in the A BA, and I’m a huge proponent of the section of litigation. This podcast is just one example of the dozens of resources.

The section of litigation provides litigators of all practice areas to help become successful trial lawyers for our clients. Learn more and become a member at amb ar.org/litigation. Today, our topic is unusual in that it makes most litigators very uncomfortable that in fact, it may actually cause a bit of trembling. The topic is case budgeting. We are fortunate to have as our guest with us today, a great trial lawyer who faces the art and science of budgeting with the same confidence he approaches his cases. Dan Dowd. Additionally, you’re going to want to stay with us as we also bring you another tip from our mental health and wellness experts at the a, a section of Litigation Health and Wellness Committee. This week, Mariza Rodriguez talks to us about the great commitment reset New year, fewer commitments, how to audit your life and schedule yourself less. But first, let’s talk about a topic that involves the converse of auditing, looking forward case budgeting.

Our guest today is Dan Dowd. Dan is a partner and the president of Cohen Dowd Quigley in Phoenix. For three decades, Dan has practiced in the areas of complex business litigation and administrative disputes, and Dan has repeatedly been selected as one of the top litigators in Arizona. He has been named a Southwest super lawyer. In every edition of that publication, he has repeatedly been recognized by super lawyers as one of the top 50 attorneys in Arizona and has been recognized by best lawyers in America every year since 2010 for commercial and bet the company litigation. He is also a longstanding leader in the a, a section of litigation. Welcome, Dan.

Daniel Dowd:

Good morning.

Jim Reeder:

So Dan, first off, even though you and I have known each other for years, I think that one of the things that helps contribute to all of our collective learning and contributes to civil discourse and understanding is just getting to know one another. I think it provides incredible insight into why each of us thinks the way we do and we could all get a little bit more of that. As such, I like to start off by having our guests do two things. One, share a thumbnail of your career path and two, share something about yourself, your background, your childhood and experience that has shaped who you are. So Dan, do share with us who are you?

Daniel Dowd:

Well Jim, thank you first. It is really an honor to be here today and I thank you for the invitation. A thumbnail in my background. I was born and raised in Iowa or God’s country as my colleagues are sick to death of hearing me call it. Graduated from Iowa, university of Iowa College of Law in 1988, and I was lucky enough to receive a job in Phoenix with about a 170 lawyer firm called Strike Lang, which is now part of the Quales and Brady Empire. My first mentor at Strike Lang was a lawyer named Ron Cohen, former chair of this section. Ron was the superstar at Strike Lang and in 1991 he did something that no partner at a large law firm did back then and he left. He left his partnership and his firm to start a small litigation boutique firm because he wanted to administer less and try cases more. And 18 months later, I was very fortunate to be invited to join him and I did. I became the managing partner in 1998, a position I still hold today. And we have just been blessed to be able to build a complex business litigation practice in a small 15 lawyer environment. My story’s a little bit boring. I’ve had two jobs in 37 years and I loved them both and I wouldn’t change anything.

Jim Reeder:

Not sure that’s boring. Maybe in fact, inspiring

Daniel Dowd:

Your second question was a lot tougher. I’m glad you gave me a heads up on it to think about something or some person or some phenomenon that helped shape who I am today. And I gave it a lot of thought and the answer I came to was the game of basketball. I absolutely love to play. I try to play every chance I get at 63 with an artificial hip. I’m so lucky the guys still let me try to run with them. It’s the ultimate team sport. Your success depends upon your teammates playing together as one, sacrificing the individual for the collective and doing whatever you can not to let your teammates down. Plus, while you’re playing you really can’t be thinking about anything else. It requires your undivided attention. And I think some of my happiest moments have come from just playing basketball with the guys and more importantly to my career, I really think these experiences have shaped the way I approach litigation and life in general, that the team’s always more important than the individual. And it may sound a little bit goofy, but that’s the way I’m wired and basketball has a lot to do with that.

Jim Reeder:

That is exactly the kind of thing I was looking for. And it’s the kind of thing that when we learn about people and if we’re curious about people, we can appreciate so much more about where they’re coming from and judge so much less that I think will resonate with a lot of people who grew up in a certain environment under a certain time and a certain situation and found that there was something that they were good at or that provided them joy and comfort and life lessons that have stayed with them. So thank you for sharing that, Dan. Alright, so now let’s get to the topic budgeting case. Budgeting. When I first started practicing nearly 40 years ago, and probably even for you 30 years ago, Dan, this just wasn’t a topic. I mean I often tried a case that cost a ton more to try than what is at stake.

I never thought twice about it and neither did the client. I never had a client ask for a budget. I’m not sure why. Maybe it was just cheaper, lower hourly rates, not a bunch of expensive discovery, less necessity for experts, less time from start to finish. But as a result, there were fewer variables to control and the cost was just what the cost was and nobody thought anything about managing it today. On the other hand, it seems to be on every client’s mind and therefore on every lawyer’s mind at the beginning it’s how much is this going to cost? And every month thereafter it’s how much have we spent and how much more is it going to cost. So let’s start at the beginning, Dan. First, how often, what percentage of cases would you say a client asks you for a budget at some time?

Daniel Dowd:

It’s really increased over the years, but I’d say 50% of the time now we’re asked to prepare a budget or a projection as we like to call it.

Jim Reeder:

And does that occur at different times or you see it at just at the outset or when do you mostly see the formal request for a budget?

Daniel Dowd:

It really does vary and I think it varies by the client. It’s litigation savvy or litigation experience and its decision-making process. A lot of organizations have internal policies and procedures that require their outside counsel to prepare budgets very early on in the case and other times you might be representing a small company or entrepreneurs who are in it and finally look up one day and say, wait a minute, how much is this going to cost to get us to the finish line? And so you’re doing them midstream, but I’d say we’re seeing a tendency to be asked on the front end whether we’re representing a plaintiff or a defendant to put together some sort of a cost projection.

Jim Reeder:

And do you ever initiate that process and say, you know what? We ought to put together a budget and that will guide us as we go forward, both in how we want to try the case, but also so the client knows more.

Daniel Dowd:

We don’t generally offer to do it unless asked except perhaps in the beauty contest phase. If we know the client’s out interviewing multiple firms, cost is going to be one of the determining factors we will offer to put one together. I’ve never just unilaterally put one together and offered it to the client, but if they ask, we don’t shy away from it. It’s important to them if they ask and we try to ae to their request.

Jim Reeder:

Alright, so let’s get to the nuts and bolts case is just getting started. You’ve been hired, your answer date is a few weeks away. The client asks probably a little sheepishly with a lot of caveats. They say, I know it’s hard for you to do, I won’t hold you to it, I just need something rough. Whatever the caveats are. Alright, so what is the process and what is your response to the client? And then we’ll get into sort of how we put it together a little later.

Daniel Dowd:

First, let me start by saying it’s not difficult but it’s labor intensive and it’s one of those things that the senior folks on the case really need to roll up their sleeves and work with their team to put together. But in that situation, of course you’ve got a lot of variables. Has the lawsuit been filed? I’m assuming we’re the defendant in this scenario. Where has it been filed? What judge has it been assigned to? What’s that judge or that jurisdiction’s track record for motions to dismiss? Are they favored? Are they not favored? Do we have a shot? The one that’s become kind of the bane of any business litigator’s existence is what does the ESI look like in this case? Are we talking about terabytes of information that’s going to have to be called and reviewed in some process? What’s that court’s process for early case assessment, early case management, joint scheduling orders.

And probably most important right out of the shoot is who are our opponents? Are these lawyers that have a history or that you have a personal history of being able to do business with? Even if you don’t agree on one fact or one legal principle, the lawyers can do business together or are they lawyers that engage in gamesmanship and everything that you should only have to do once? You’re going to have to do three times and then you’re probably going to have to go to the court. So we need to talk with the client very directly about all of those variables. And then the other thing that I try to do sometimes successfully, sometimes not depending on the protocols of the client, is to just let them know that the further in time we project, the error rate’s going to go up significantly. So if we’re a defendant in this situation and we think we really do have a viable motion to dismiss, I will beg the client to let me put together a very granular budget but only through the disposition of the motion to dismiss. I think that budget is worth the weight of the paper it’s written on. If they say, no, I need one through trial and appeal, then it’s whimsical, we’ll do it, but it doesn’t really have any integrity.

Jim Reeder:

I think that’s such an important point that I always wanted to be able to say, okay, well this is what I think it’ll cost a motion to dismiss and then sort of give a general number for phases thereafter, which you could then modify thereafter and hopefully a client is receptive to that. If not, you’re right. It’s just like sticking your finger up into the wind. And I guess also there’s some clients who want to try cases and some clients who want to just get the case resolved. And I suppose you can take that into effect too as to how aggressive you’re going to be or how cooperative you’re going to be with the other side as well.

Daniel Dowd:

I think that’s right and sometimes we’ll do kind of a bifurcated budget. If the client wants to get to early resolution then we might build a mediation path into the budget. There’s all sorts of tactical issues about how you approach early mediation and hopefully you’ve got mature folks on the other side so they’re not going to read weakness into an effort to try to get a case mediated. But we’ve had clients say, that’s really helpful, let’s do an early mediation path budget, which has some of the components of your full scale budget. And then in the alternative they’ve got another budget in hand that takes them through as much of the case as they want it to be budgeted for. And then we break those pieces down into very granular parts and go to work on trying to build up the cost estimate.

Jim Reeder:

So let’s talk about that. You talked about it’s hard work. You’ve got to roll up your sleeves and you’ve got to focus on it, you’ve got to pay attention to it, you need to get others involved in the process. You can’t just sort of say, oh, a case like this costs this or historically it’s cost this much to try a case like that. So let’s start building the variables that you would go through, the hard work you go through when you’re actually putting it together.

Daniel Dowd:

Okay, so upfront and in the budget itself, the first couple pages are qualitative, not quantitative, and we talk about the period that we’re budgeting for. We talk about the variables that we just can’t control. We’ll try, but we can’t control the cooperation or not of your opponent and we can’t control the dictates of your judge or your arbitration panel. And the other thing early on in the case we may not have a good handle on is the scope of ESI, both ours third parties and our opponents. So we just caveat that saying if any of our assumptions are wrong, the budget could change. Sometimes materially

Jim Reeder:

Speaking to that, and you talked about the judge earlier on, you got a big complex case. Maybe it’s a class action whatever, and some judges may stay discovery for instance, while a motion to dismiss is pending, in which case your budget is out the window for a little while and you have no idea exactly when that will stop.

Daniel Dowd:

Completely agree In that situation, the budget’s probably out the window favorably for the party is because you’re deferring expenses that will come if the motion’s not successful. The other thing that we I think is critical in a budget is to tell them what you’re not estimating. We almost never estimate expert fees and costs. Certainly early in the case we can identify the subject matter experts that we think might be involved, but we’re very clear about saying this projection and we hardly ever call it a budget, we call it a projection, does not include expert fees. And sometimes the client will say, no, we need that. So then you have your own set of caveats there. You identify the subject matter experts and then you have to either work with those experts on a budget, which doesn’t come till usually quite a bit later or it’s kind of a thumb in the air based on experience rather than based on the vagaries of that particular case.

The other piece, Jim, I think you identified it is, and it differs if you’re plaintiff for defendant, but you need to break that case down into its simplest parts. If you’re the plaintiff, we’ve done budgets for pre complaint due diligence through the drafting of the complaint, then you have your post complaint either dealing with the motion to dismiss of the answer, then what comes next. What comes next are your court’s pretrial requirements on joint case management schedules and ESI protocols and protective orders. You’ve got your internal diligence working with a vendor to collect the ESI. You’ve got identify third party subpoena targets and the expense of doing that and just all the stuff that we do almost reflexively. You just have to write down on paper as categories underneath which you build your budget and then the assumptions come. This budget assumes each side takes six depositions.

This assumes that each side takes three expert depositions that there’ll be a motion for summary judgment, a dow bear motion, just all the stuff that comes. And when I said it’s labor intensive, that’s where once you’ve got your skeleton, which is all of the granular phases of the case, then what we do is I write down every member of the team’s name, I write the rate next to it and I put the number of hours I project that they’ll spend on that particular item. And I always try to err by being high because it always longer or you get that eight page letter from the other side you didn’t anticipate that’s going to take 40 collective hours to respond to. I’ll stop there. But you build the skeleton, you put the names of the people, including your non-lawyers who bill by the hour, and then you have to work with your team to estimate how much time they’re going to spend. And on the document collection and review the associate time is going to be heavy on the summary judgment process or working with the experts. I think the more senior lawyers’ time is going to be heavy and then you get your calculator out and build up those sub parts.

Jim Reeder:

But you’re right, because there are some things that are more senior heavy, there are some things that are more junior heavy and it’s not a mystery what the sort of phases are going to be generally. I mean most cases have a kind of soup to nuts process. It’s just then applying, okay, well how much time will it take to draft that summary judgment motion? And then that, as you say, is sort of collaborative. You’re going to talk to others about it, you’re going to reach back in your experience file and remember what it cost for somebody else. We often did that. We would go to a case that we just tried and try to gather the information, the cost that it took for a summary judgment, et cetera. If you can do that, that’s always helpful as well. Alright, so you get all that together as you said, the one thing we know is the number’s wrong. It’s really impossible to predict the future, but you’re pretty close for the gut feeling that you have. Do you give a range to sort of cover yourself, okay, it’s going to be 2.2 million to 2.6 million or do you try to be as precise as possible?

Daniel Dowd:

I try to be as precise as possible. If I give a range, it needs to be narrow. I think as you and I were talking about this topic, we both agreed that a range that is vast is not very helpful to the client who’s made the request. So they need it for a reason. The other thing though I do is I always add either a 15 or 20% addition at the end and I’ll say an additional 15% for unforeseen events. And it’s a bold face line item because I think we all tend to estimate low for all the right reasons and in good faith, but we just all estimate low. I think if we took our estimates or our budgets and compared ’em against the final results, they would typically be too low. So I just add that right in. It’s not a surprise to the client because they see it, but you also have to step back and say, okay, why does the client need this?

Do they need it for peace of mind as to whether it’s a good economic decision to go forward? Do they need it because they’re the general counsel who are serving the officers and the board of directors and it’s something that’s going to be discussed. And we always view the general counsel as our real client and if she or he has asked for this budget, we want them to look really good when they present that to the decision makers and never hang them out. So that’s why we build the caveats in and that’s why we add the little premium at the end for unforeseen events just because if that general counsel’s hanging out a little bit because of this litigation, we want her protected

Jim Reeder:

And we know that they didn’t budget for litigation, it came as a surprise. It’s never something that’s anticipated or wanted. They don’t plug in a sort of variable litigation cost into their regular budgets. And so they’re kind of working reflexively as well and you want to try to make their job as easy as possible.

Daniel Dowd:

Completely agree. And then one thing I should add is I think it’s important that you have other members on the team work with you on this so that there can be some knowledge transfer and you’re not the budget guy, they’re not that fun to put together. They make you think about your case, but it’s a very much a learned skill and I’ll typically bring in, if I’ve got a younger partner or more senior associate, I’ll have them in the room with me and we literally either do it on a whiteboard or on a piece of paper, then we go make it look pretty. But it’s that grassroots effort and it’s a skill that you have to transfer onto the next group of leaders of your firm.

Jim Reeder:

Yeah, that’s a very important element of it I think, because it’s not just something that’s preserved for the senior partner and therefore the senior partner should do it. It’s something that everyone can do frankly if they just have got the right foundation and context and have done it mechanically before. So I think it’s a great point to be able to transfer that skill. And in fact, that’s a good place to take a break. We’ll be back shortly with our guest, Dan Dow as we get into keeping up with the budget and communicating with the client when the budget gets sideways. And remember to stay tuned for our mental health and wellness tip from Maritza Rodriguez on how to schedule yourself less by making fewer commitments. And now a quick word from our sponsors. We’re back with Dan Dowd from Coh, endowed Quigley and Phoenix. All right, Dan, you’ve gotten your budget to the client, now you can go back to practicing law. Is that it?

Daniel Dowd:

Oh, that’d be nice. There’s that rare case where the client needs to check the box that it needed a budget and it got one and it goes in the drawer never to be seen or heard from again, that’s not reality. Reality is as our bills come in, the client’s going to have that budget handy and they’re going to start comparing. And of course, monthly bills don’t track the subject matter of a budget precisely, but they certainly give you a feel and you got to get out in front of it. I said, we’ve all had those situations where thinking you were going to get it one motion in li, you got 12 or thinking that the judge was just going to rule on the motion or she decided to order jurisdictional discovery before ruling on it. All these wild cards, you thought that you had six custodians to gather ESI from, but you had 16.

The client’s going to know that as you’re going through it, but they’re not going to attach dollars to the increased scope of your work. So what I do in the cases where I’ve provided a budget, when the monthly drafts come out, I pull out the budget and see where we are and if there are favorable surprises, I usually don’t do anything. We’ll let the client just experience that without me tooting our horn. But if there are issues, if there’s been scope creep or if the activity far exceeds the projection, I pick up the phone and call the client. You just have to, I think you’re in a lot of credibility by delivering difficult news in person and on time rather than sending your bill out, kind of pinching your nose as it goes into the ether and waiting for the call. I think that’s the worst thing you can do because remember that client asked for the budget for a reason. You’re protecting the client by trying to give accurate information and it’s information that’s more art than science. So you need to stay on top of it. You need to have that preemptive call for a whole lot of reasons, but mostly because it’s the right thing to do if they’ve relied on your budget in making their business decisions. So no, unfortunately the game isn’t over when the budget is sent,

Jim Reeder:

Which I think, so a couple of things on that. More and more clients I encountered actually kind of want updates periodically. That is on a quarterly basis, what’s it going to look like this quarter as opposed to tying it to the event itself, which is just good sense for a company that wants to try to project accurately what the costs are going to be, that actually is helpful for us, right? Because it does mean that they get a sort of periodic update as opposed to waiting a year into the case to tell them, oh, this is all costing a lot more. But I think it also, those of us who had that call and had many of them, it sort of just tells you, let’s try to get this right upfront. It’s not doing us any favors if we’re not.

Daniel Dowd:

I agree, and sometimes you need to just revise the budget. When you did budget number one, the case was a certain magnitude and maybe eight months later it’s a different magnitude and I just soon go in and redo the budget so they can digest that news and get used to it until they get that bill from us that doesn’t bear any resemblance to their expectation.

Jim Reeder:

Yep. I love that. I love the notion that particularly if fundamentally the case is changing, you’ve decided to add counterclaims for instance. Oh my goodness. It’s a totally different case and you just have got to be able to share with the client that development and what the impact of it’s going to be. This is great. I think this is very, very helpful, Dan. I think people will appreciate one that this is not rocket science, that all you really have to do is roll up your sleeves and work hard and be collaborative and try to be as thoughtful about it as possible. And so you don’t need to shiver every time the client calls and that you have the knowledge, you have the knowledge to be able to do this. It’s just a matter of taking the time, carving out time for you to do this. And I love the idea of the whiteboard and it’s just a gut check with everybody in the room. What do we think this is going to cost? I love that. Anything else you want to add to what we’ve talked about?

Daniel Dowd:

Just one thing I learned within the last couple months, we were doing a budget and I had a very young lawyer in the room with me as we were building it, and she had some primary responsibility for some early activity, and when I showed her the budget, she came to me and she said, Dan, I hate to say this, but that’s not enough time. This is really hard and I can’t do it within that amount of time. And it really taught me that, okay, maybe the more senior folks and I need to develop the budget, but man, we ought to share it with the team before it goes out the door because I was just unrealistic. And she explained to me the complexity of the issue, and we went in and pretty materially upped the amount of time to complete those tasks. That just went right over my head until I got her very considerate input. I just think it’s important. It should be a team effort.

Jim Reeder:

Yeah, that’s not anathema to what we do. We bring the team in whenever we’re considering, okay, what are our top arguments? What are our best facts? What do we anticipate the reactions going to be? We do that all the time because we just are not the only person that knows the answer. But I do think that for some lawyers that’s difficult. So if there’s ultimately a message here that is, don’t put this all on your shoulders, don’t take sole responsibility for it, get others involved, and you’ll produce a better product just like trial a lawsuit.

Daniel Dowd:

Very well said. I agree.

Jim Reeder:

All right, fantastic insight. Thanks, Dan. I want you to come back anytime to share further thoughts on keeping the client happy when you’re handling what is invariably and unhappy matter. And so we probably will hear from Dan Dowd again. Thanks again.

Daniel Dowd:

Thank you, Jim. Really appreciate the opportunity.

Jim Reeder:

Now I want to welcome Maritza Rodriguez of the Rodriguez Law Firm and a member of the A BA Litigation Section’s Middle health and Wellness Committee who’s going to provide a tip on how trimming your resolutions and commitments can lead to a happy and healthy new year.

Maritza Rodriguez:

Hi, my name is Maritza Rodriguez and my tip today is spring cleaning your health, making sure you’re scheduled. Spring is when we clean out our closets. We delete our old emails and we reset routines. But the thing most of us don’t spring clean is our health. We take care of everyone else first, our clients, our coworkers, kids, parents, and we put ourselves last usually until something breaks. So today I want to give you three simple systems to make healthcare automatic instead of optional. Plus, a few quick bonus tips that you can start using immediately because motivation can sometimes be unreliable, but systems actually work. Tip number one, tie your appointments to a life anchor. Behavior science tells us that we follow through more when we attach tasks to something that’s already happening every year. So try this. Schedule your annual physical or your dentist appointment around your birthday month or an anniversary.

Schedule your mental health check-in, or a therapy refresh at the start of spring or fall. Now, it’s not another task, it becomes a ritual. You don’t ask, should I schedule this? You begin to think, oh, it’s March. This is what I need to do. Tip number two, book the next appointment before you leave. This one is simple and it’s incredibly powerful. Before you walk out of your doctor’s office, your therapist’s office, your dentist’s office schedule, your next appointment. Why this works, you eliminate decision fatigue. You don’t rely on the future. You’re remembering it’s already on your calendar. The hardest step is done. The future, you will be grateful. Tip number three, create one annual health admin hour. Instead of spreading this out across the year, just batch it once a year, block an hour on your calendar and use that time to schedule your physical and your special visits.

Use that time to refill any prescriptions, check your insurance coverage and book your therapy check-ins. Label it an annual health admin hour, one hour once a year. It’ll be a massive return on investment. Now, let me give you a couple of extra bonus habits that make all of this sometimes even easier. Turn on automatic reminders. Use your patient portals, the calendar alerts, the pharmacy auto refills so that technology carries the mental load and not you treat mental health as preventative care. Therapy isn’t only for crisis. Think tuneups not breakdowns. Maintenance matters schedule during low resistance times. Try to schedule your appointments early mornings or during lunch hours so that way you can remove as much friction as possible from your calendar. Try to stack your appointments on the same day. If you’re already taking time off of work, maybe you can bundle appointments together and you can just ask yourself, what would the future me? Thank me for scheduling this week spring. Cleaning your health isn’t about perfection. It’s about choosing systems over stress. Your work matters, your family matters, your community matters, but none of it works. If you’re running on empty this spring, don’t just clean your house, clean up your calendar and put your health back on it.

Jim Reeder:

Our thanks to our guest, Dan Dowd of Endowed Quigley in Phoenix for providing important guidance on creating case budgets for clients as well as Maritza Rodriguez for another tip to help improve our emotional wellbeing. Thank you also to the a b ABA Litigation Section Premier sponsor, Berkeley Research Group for sponsoring this podcast. BRG is an award-winning global consulting firm composed of world-class experts in accounting, damages analysis, economics, finance, intellectual property valuation, data analytics, and statistics who work across industries, disciplines, and jurisdictions, delivering clear perspectives that you can count on. Their guiding principle is intelligence that works. Learn [email protected]. A reminder to be sure and subscribe to Litigation Radio on your favorite podcasting app so you don’t miss our next episode and spread the word. If you like the show, please help spread the word by sharing a link to this episode with a friend or through a post on social media and invite others to join the show and community.

If you want to leave a review over at Apple Podcast, it’s incredibly helpful. Even a quick rating over at Spotify podcasts. It’s super helpful as well. Finally, I want to quickly thank some folks who make this show possible. Thanks to Michelle Oberts, who is the producer on staff for the litigation section. Thanks. Also, go out to the co-chairs of the litigation section’s audio content committee, AI Maple and Mike Staiger. Thank you to the audio professionals from Legal Talk Network. And last but not least, thanks to you for listening. I’m Jim Re, I’ll talk to you.