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Transcript for Trial Lawyer Talk, Episode 18, with Eric Davis

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Scott: Welcome to Trial Lawyer Talk. I’m Scott Glovsky, and I’m your host for this podcast where we speak with some of the best trial lawyers in the United States. First, today I’d like to thank our exclusive sponsor Traci Kaas from the Settlement Alliance-WEST. Traci is a phenomenal settlement consultant, and I’ve worked exclusively with Traci for the last ten years because she cares. Just like the folks I interview on this podcast, she cares about the clients and does a great job.

Now, at first, I was very hesitant to get a sponsor because this podcast is not about making money and it never will be. So, all of the sponsorship money is going to advertise the podcast, so that we can spread the word and get more listeners. So, thank you Traci.

Now, today we’re very fortunate to have with us Eric Davis. Eric is a gem of a guy, phenomenal lawyer, and a wonderful teacher. He’s an assistant public defender in Harris County, Texas. Truly, one of the best trial lawyers I know.

So, let’s get started. [instrumental music plays]

I’m very pleased to be sitting with a phenomenal trial lawyer. Eric Davis is a public defender from Houston, who’s handled all kinds of cases. It is a tremendous, tremendous human being, has a wonderful presence, and is a great storyteller. Eric, thanks for being with us.

Eric: You’re welcome, and thank you for having me.

Scott: Eric, is there a story of a case that profoundly impacted you?

Eric: Yes, Scott. There is a story that I recall.

Scott: Please share that with us.

Eric: Oh. Several years ago when I was in private practice, I was contacted by a 78 year old pastor … his daughter actually, and he came to my office. They wanted to hire me to defend him in a criminal case. He had been accused of assault and trespassing. My client was an older gentleman. You know, 78 years old, retired veteran, and retired from being a pastor.

One night, he went to sleep. He woke up, and his neighbor had moved the fence two feet over to the left. So, he got out and saw that his fence had been moved over and confronted his neighbor. His neighbor said, “Man, are you crazy? Is there something wrong with you? Nobody ever moved that fence. We didn’t move the fence while you was sleeping.” But, my client was convinced that his fence had been moved.

So, he started mowing the lawn in the area where the fence was. You know, that lawn next to the … I’m sorry. That area of the lawn next to the fence was his, so he began mowing it and caring for it as if it was his. His neighbors would tell him, “Get off our lawn. Stop mowing our lawn.” He said, “This is my lawn.” My client even hired a surveyor. The surveyor came out and, with his survey, found that that land, that stretch of land was my client’s. The original survey, according to the neighbors, was that it was their land. It was the neighbor’s land. So, he had this dispute over this small track of land next to his lawn. Next to his fence. He continued to take care of it as if it was his.

One day, after a couple of arguments with his neighbor, his neighbor set up some water sprinklers near that area of the lawn. Sure enough, my client went to mow the lawn as he always did. Every Thursday, he mowed that lawn. So, he went to mow that lawn. When he was mowing that lawn, pushing his lawn mower himself … And it was a self-propelled lawn mower.  But when he got behind it, he had to push. So, my 78 year old client got behind that lawn mower, started pushing, started cutting that area of the lawn.

The neighbor got up, went outside, and cut on the water sprinklers. The water sprinklers came on and wet the client up. Wet him up so much that his cell phone was broke. Immediately, his neighbor charged outside. You know, she kept … Took care of a bunch of dogs and stuff, so she had some dogs running around with her. So, she charged outside as he’s standing there wet, and he’s got the water sprinkler in his hand. She goes up to him yelling, and screaming, and berating him about being on her lawn. Saying, “Get off my lawn, you crazy old man. You shouldn’t be on my lawn, you crazy old man.” He does what any 78 year old pastor in that situation would do. He went upside her head with the water sprinkler. After he did that, of course, her husband came out. They argued, and they called the police. The police came out, arrested my client, and charged him with assault and trespassing.

Then, he and his daughter came to my office. His daughter happened to have been married to a doctor, an orthopedic surgeon. They came to my office, and she says, “My dad wants to hire you in a case.” It was strange to me because the guy was really old, but I could tell that the elevator didn’t go all the way upstairs, you know? It was a little different, Scott. So, I’m talking to him, and we’re having conversation. Then, they say, “Well, you know, he insists on hiring a black lawyer. He wants to have a black lawyer.” The client tells me, says, “You know, I wanted a black lawyer because your people fight. You fight.” And then-

Scott: What nationality was he?

Eric: He was a Caucasian male. So, I said, “Okay.” I didn’t have a problem with that. I took it as a compliment and took it in stride. I quoted him a fee, and his daughter had her checkbook out and asked me how much would I charge him. I quoted him a fee, so she put her checkbook back in her purse, pulled out cash, and paid me in cash.

I thought … First thing I thought, “Man, I didn’t quote enough. I didn’t even quote enough. She put the checkbook back. I didn’t quote enough.” Then, she started to tell me. She says, “It was between you and Rusty Hardin.” In the Houston area, Rusty Hardin’s a high profile attorney, a very expensive lawyer, and they were considering hiring Rusty Hardin or me on the case. Then, I said, “Man, I should have added another zero to the fee. I didn’t charge enough. I didn’t get enough of the fee.”

But, it was what it was.  I was committed to defending him, so I went to court on his very next court date. We hadn’t yet been set for trial, and the judge called me up. She said, “Mr. Davis, you’re on this case?” In the courtroom, we were in Judge Diane Bull’s courtroom. Judge Diane Bull was a judge who actually went to TLC. She actually went to Trial Lawyer’s College. She was a judge that cared for defendants. She was a judge that really saw behind charges and really tried to look to the truth of a situation. So, she tells me, “So, you’re representing this case? So, you’re on the case for the pastor?” I said, “Yeah, Judge Bull. It was interesting that it came to your court.” She says, “It’s in my court because he had gone to trial a couple years ago and represented himself, and he was convicted in that case and I never sentenced him. I deferred. I set his sentencing out 20 years or so, and I never intended to sentence him. So, when he was arrested for this charge, it automatically came to my court because I had that other case that he was never really … A judgment was never entered on or anything else like that.” I was like, “Wow.”

She said … She told me, “Mr. Davis, if you can get him to agree to go to a mental facility, a mental health facility, I will convince the D.A.s to dismiss this case. I’ll talk to them and put pressure on them to dismiss this case if you can get him to agree to to be involuntary committed.” I said, “Hey. He didn’t even need to be involuntarily committed. If you can get him to agree to go and see a psychiatrist and be involved with a psychiatrist, I can convince them to dismiss this case.” My client was adamant that he didn’t have a mental health issue. He was adamant that he was not mentally ill and had no problems with mental illness, and we were not pleading insanity. We were not doing competency evaluation because he was competent, so we asked for a trial date.

Judge Bull gave us a trial date immediately. We got a quick trial date. I remember doing my preparation for trial, and I remember sitting down with the client and talking to him about the case and talking to him about what would happen during a trial. So, trial date came.  When we went to trial, you know, the pastor wore his suit and I had dressed for trial. We showed up in court. Usually, in misdemeanor court, you pick juries. When you pick the jury, each side has an opportunity to strike four people. We can strike any four people we want. They can … The other side can strike any four people they want as well. You don’t have a huge panel, but you have people that come over on a panel.

I remember before the jury being seated, turning to my client and saying, “We can strike any four people we want to. No questions asked. We find out those that we don’t like. Those we think that are adverse to our case.” The client turns to me and says, “The Holy Spirit told me to strike the first four people.” I said, “Excuse me?” He said, “The Holy Spirit told me to strike the first four people.” I said, “Pastor, we can’t do that. We don’t know who they are. We don’t know who those people are, what they’re going to say. We don’t know. They could be favorable to us. They could be against us. We don’t know what they’re going to say. We don’t know anything about them, so we can’t strike them that way.” He said, “The Holy Spirit has spoken. The Holy Spirit told me to strike the first four people.  “So, I said, “All right. I figured, you know, we could go ahead and go through the trial. Then, after we see what happens with the jury, we can talk about this again in terms of which ones we strike.”

Sure enough, you know, we were making a claim of self-defense. Sure enough, those first four people was solidly in favor of us. They were great jurors. They would be great jurors for the pastor. They were solid self-defense jurors. They were there. They were with us. So, I turned to the pastor and said, “Pastor, we can’t strike those people. Those people are solidly with us. Those are defense jurors all the way. We got to keep them and look at other people possibly to strike. He told me, “The Holy Spirit has spoken. Let’s strike the first four people. We got to strike the first four people.” So, we struck the first four people, and we proceeded to the trial.

As it would have it, when we got through the trial, it came time for the pastor to testify, and the pastor took the witness stand. As he was testifying … you know, we were making a claim of self-defense. So I asked him, I said, “Now, she was charging towards you, ain’t that right, pastor?” “Yes sir, Mr. Davis. She was charging towards me.” “When she’s charging towards you, you were worried about your safety?” “Yes sir, Mr. Davis. I was worried about my safety when she was charging towards me.”

“And she charged towards you as she was coming out there, ain’t that right?” He says, “That’s right.” Says, “You had been soaked up with the water sprinkler, and she’s charging towards you, yelling at you and berating you, ain’t that right?” He says, “Yes sir. That was absolutely right. She’s yelling at me, berating me, calling me all kinds of names. Everything but a child of Jesus, she’s calling me. She’s charging towards me.”

So, I said, “Pastor, at that point in time, fearing for your safety, you hit her. Isn’t that right?” “Well, no, Mr. Davis. I’d never hit a woman. I didn’t hit her, Mr. Davis. I’d never hit a woman.” I said, “Wait a second, pastor. Now, you know, you’re saying this is self-defense, that you were defending yourself, so you had to hit her in defense of yourself.” “No, Mr. Davis. I didn’t hit her. I’d never hit a woman. No siree. I’d never hit a woman.”

So, after about five minutes of me trying to get the pastor to agree that he had hit her in self-defense, the judge looks at me and says, “Mr. Davis, you look like you need a break.” I said, “Yes, yes ma’am. Yes ma’am. I need a break. Yes ma’am.” She says, “All right. We’re going to take a break.” She says, “Jury, all rise.” So, the jury all stood up, and all of the jurors started walking out of the courtroom.

One juror, one lady juror who I remembered being from Louisiana. And, I remember telling the stories of what I did because I’m from Louisiana. I remember telling some story of what I did about Louisiana and finding out about her being from Louisiana. She was an older lady as well. She had to have been in her late fifties or so. So, she’s walking past the witness box. She stops right in front of the pastor, goes up to him, taps him on the arm, and says, “Now you behave, you hear. You behave. Now you behave, you hear.” Then, she just files out of the courtroom with the other jurors. I thought to myself, “Man, we got to get to closing argument as quickly as possible.”

So, the pastor … When the jury came back in, I asked the pastor a couple of follow-up questions and then passed him as a witness. Then, the next witness we put on was his daughter who established a few facts real quickly. Then, we got to closing argument.

In closing argument … Before closing argument, the judge was to give us a jury instruction. When we got down to the charge … Now my whole [inaudible 00:12:34] for the most part was based on self-defense. My [inaudible 00:12:39] was self-defense and a few other issues as well for self-defense. So, we get to the charge conference with the judge, and I request an instruction on self-defense. The judge says, “No, Mr. Davis. You don’t get that for self-defense. He says he never hit her.” I said, “Well, judge, no. The evidence seems to suggest that maybe he did hit her.” She says, “No, Mr. Davis. The defendant can’t have his cake and eat it too. He says he didn’t hit her, so there’s no self-defense.”  So, we did not get a self-defense instruction. Here I was, trying a self-defense case, trying to pick a jury that was a self-defense jury, and we don’t get a self-defense instruction.

I’m feeling defeated, and I get to closing argument. I remember a situation that happened, and I started my closing arguments with the words, “Butter beans and cucumbers.” Butter beans and cucumbers. I said, “Have we strayed so far from the path? They hosed him down like a dog.”

I remember the story from my life. I remember when I was a kid, we had a neighbor, an older man that lived behind my dad, named Mr. Goodwin. Now, Mr. Goodwin was a mean man. He was as mean as a rattlesnake, and he was a guy that all the kids in the neighborhood hated. We did not like Mr. Goodwin. He had to have been in his seventies or so, and he lived in the house behind my dad, alone with his wife.

If we ever were playing baseball, and we hit the ball and it went into Mr. Goodwin’s yard, Mr. Goodwin would get the ball and keep the ball. If we were throwing our football around and somehow it went into his yard, he’d get our football and keep the ball. He wouldn’t give any of our stuff back. If we ever went in his yard, he’d threaten to shoot us. He’d threaten to harm us. He’d threaten to hurt us. He was a rascal of an old man.

My dad grew butter beans as well, and the fence that bordered our house and Mr. Goodwin’s yard, he grew butter beans that grew up on the fence and they covered that back fence. I remember one day sitting in the den, which was the last room of the house, and I remember looking out the window and seeing Mr. Goodwin with a bowl picking my daddy’s butter beans. So, I went running to my dad and said, “Daddy, daddy, daddy! Mr. Goodwin picking your butter beans. Come on, dad. Come on.” So, my dad goes back and peeks out of the window. He looks out and sees Mr. Goodwin picking the butter beans because I look out of another window below him and see it happening while he’s looking out. He closes the window blind, closes the curtain, and turns to me and says, “Hmm.” I said, “Hmm? That’s all you’re going to say? He’s picking your butter beans! That’s all you’re going to say is ‘hmm’?”

The very next day, my dad took me down into the garden. In our garden, you see, on that fence that bordered Mr. Goodwin. The butter beans bordered his house, but on the fence that was on the side that Mr. Goodwin couldn’t get to, my dad grew cucumbers. There were cucumbers growing all over in that area. So, he and I went down in the garden with a huge grocery bag, a brown paper bag, and we filled that bag up with cucumbers. He turned to me, and with the cucumbers in his hand … That bag of cucumbers in his hands, he thrust it to my chest and told me, “Take that to Mr. Goodwin and tell him if he needs some more just to come on in and get some.”

I argued to the jury after telling them that story, “Have we strayed so far from the path? Wasn’t there a time when we had weaker people, older people in our neighborhood and in our community that we cared for them and took care of them. We looked past any of their idiosyncrasies, and we attributed to their age and we still honored them and cared for them, and we gave them cucumbers and butter beans. Butter beans and cucumbers. Have we strayed so far from the path?” That was the focal point of my argument. I argued to the jury that they should find him not guilty, and the jury deliberated less than five minutes and found him not guilty.

It was a case that had a profound impact on me because, here I was, I was setting out with a defense and because of the Holy Spirit in terms of my client not wanting to go with the defense and eliminating all the jurors who were in favor of that defense he ended up getting acquitted.

Scott: So, what was the impact on you?

Eric: Oh, I learned, man. I learned that the jury had the power. The jury had the power, and that well-meaning people, people who were in-tune, and people who were well-meaning would do the right thing. So, when I’m setting out to pick a jury, I’m not always caught up with a person’s race. I’m not always caught up with a person’s age. I’m not always caught up with the exterior of a person. I’m trying to find out about whether or not they are a well-meaning person. If I can get to someone who’s a well-meaning person, I know they’ll do the right thing because that jury saw my client and saw the injustice of the situation and they did the right thing. It was a situation where we achieved jury nullification because we didn’t really have a legal defense. I mean, she had welts all over her face. The client denied hitting her. The jury thought, “Hey, there’s some reasonable doubt about whether or not he hit her. Even though, she testified he hit her and she had the bruises and everything to support that as well. You follow me? I took away from that that if I can get some well-meaning people on a jury and buy that, people who have a sense of justice, people who know right from wrong, that they’ll do the right thing in the case.

Scott: What’s your proudest moment as a trial lawyer?

Eric: My proudest moment as a trial lawyer? This was one of them. I’ve had the opportunity to try murder cases. I’ve secured acquittals in multiple murder cases. I’ve even tried federal cases, large federal conspiracies, and secured acquittals in those cases. But, this case, representing the pastor was one of my proudest moments because it was a situation that I wasn’t supposed to win. We weren’t supposed to win, and we pulled back and looked at the humanity of the situation. That this was just wrong on different levels, and the jury responded in kind. I learned that, as well, with cases … That if you can find that element in a case where it’s wrong and you can find an element in a case that will connect with the jury, that you can move mountains … That you can do many different things in a case.

Scott: Tell me more about that.

Eric: I’ll give you an example. I represented a woman that was accused of killing her husband. You know, she killed the husband. We argued that it was self-defense. He had been shot in the back, and he had been shot in the back of the head. But, the client had been abused by this man for years and his abuse was extensive, we called more police officers in the case’s witnesses than the state did. In other words, we called more witnesses that were police officers to talk about his bad conduct, all the bad stuff, than all the witnesses that the prosecutors called in the case in its entirety.

So, when the jury saw all of the abuse that he had inflicted upon my client, even though he had been shot in the back of the head and in the back, they agreed it was self-defense. They filed her not guilty of a murder charge in that case. That was a situation where we had jurors that had a sense of justice, who knew that it was wrong to convict this woman after all she had been through and everything else as well and given the facts that he was coming at her at the time that he was killed as well.

Scott: It sounds like you trust the jury.

Eric: In a lot of cases, I do. I spend … We spend a lot of time trying to get a jury that we can trust.

Scott: Can you share with us how trusting the jury is important?

Eric: Well, trusting the jury can be important because the jury’s the one with the power in the courtroom. No matter how hard you try, no matter what you do, the jury’s the one that has the power. In other words, I’ve tried cases where I’ve fumbled around and I made mistakes and I thought I did a terrible job but the jury saw it. Then, when we went afterwards, they told me. They said, “Hey, look. You know, we know you were struggling with it but we could see where you were headed and we could see what was right.” So, trusting a jury is important in the sense that the judge has a limited amount of power, can hamstring a lawyer, but the person who has the power over the verdict is the jury. They’re the ultimate decision-makers in the case.  They have the power.  If you can get them to realize that they have the power, not the lawyer, not the judge, but each individual juror, you’ll end up with some hung juries in cases, you’ll end up with acquittals in cases of defense, you’ll end up with plaintiffs’ verdicts as a plaintiff’s lawyer as well.

Scott: What was your worst moment as a trial lawyer?

Eric: My worst moment was when I had lost a case. I had lost a case, and I felt ill-equipped to really defend the client well. I had an abusive judge. A judge who is now no longer a judge. But, you know … He’s off the bench, but I lost that case, and I wanted to quit and stop being a trial lawyer.

Scott: Can you tell me that story?

Eric: Oh, sure. I was defending a lady who was a jailer. We fought the trial. She was accused … She was a jailer, and an inmate came into the jail and was abusive towards her in language. The inmate ended up with a fractured skull, and the allegation was that my client had hit her in the head repeatedly and there was some other jailers who had testified against my client. We went to trial. Argued that there was reasonable doubt. The client was assertive that she had never struck the lady. That they were trying to subdue her, she came in combative and so forth, and that during the course of that, she may have fallen and hit her head on a wall.

So, we went to trial and the jury was deadlocked on the client’s case. They were deadlocked six to six. The judge we had held them over another day, so they deliberated a second day. They still were deadlocked six to six. He brought them back a third day. Then, they were deadlocked seven to five. They sent out a note saying, “We’re hopelessly deadlocked.” He gave them, what we call, a dynamite charge and brought them back, yet, another day. A fourth day. On that fourth day, they went from seven to five to eleven to one in favor of guilty. After about four hours or so, they returned a guilty verdict. Of course the client was sentenced to probation, and the judge gave her jail time as a condition of probation. So, here I had the single mother … My client was a single mother, who had had to go to jail in a case I didn’t believe that she was guilty on and in a situation where we were totally unprepared for her to go to jail. While she’s in jail, who cares for her children?

I felt that that was all on me as her lawyer. That I was inadequate.  That if I knew more or if I was better, that I should have won that case is what I felt. So, I was ready to quit. I was on the courthouse steps crying. Here I am, a grown man … I was a grown man, and this was years ago. This was years ago. Maybe about fifteen years ago or so, but I was on the courthouse steps crying and one of her family members came by and started talking to me. I told him, “Man, I can’t do this anymore. I can’t do this anymore. I need to give this up. I need to do something different. If it wasn’t for me, she would’ve gotten acquitted. But I wasn’t good enough, so I’m going to stop doing this and do something different. I can’t do this anymore.” He told me, “Mr. Davis, don’t give up. Get better. Get better, Mr. Davis. Don’t give up. Get better. You’re one of the few lawyers that genuinely cares about the client. We see how you care about her. We see about how you approach this case. We see how hard you worked on it, and you fought. You were fighting. You were doing the best you could. We saw that, so don’t give up. Just get better. Do everything you can to try and get better. We need more lawyers like you.”

That encouraged me and spoke to my soul. I took it to heart, and I started to look for every opportunity I had to get better. To get better. I ended up, one day, getting an email. I don’t know how they got my information, but I got an email from the Trial Lawyer’s College. This was years ago, so I went to a regional … The email was about a regional from an organization called a Trial Lawyer’s College. So, I went to a regional in California, and at that regional I saw people who were like-minded and I learned about some different methods and some different techniques that I had never seen before. It intrigued me, and they talked about this three week long college in Wyoming. I thought to myself, “Man, three weeks is a long time. I don’t know if I can get away from my practice that long.” But, I looked into it a little more and found out who all the lawyers were that went to the college and about how they experienced success. So, I applied to the college.

I went to the three week program and graduated. I left feeling energized. I left the college as if I had more tools for my toolbox, some more arrows in my quiver, some more weapons in my arsenal. I left feeling equipped, and I also left feeling better as a human being. I realized that I needed to take care of myself as a human being. I felt better equipped as a storyteller as well, and I tried cases after that. I think I won, like, several cases immediately after the college and experienced a great deal of success in my practice and my practice grew. I haven’t looked back since.

Scott: How do you deal with seeing the misery and the pain and the mental illness, being a public defender, that you deal with everyday?

Eric: That’s a good question, Scott. I’ll tell you. It’s hard. A lot of times, I have to take steps back. Sometimes, I even have to take a day off every now and then. I see a lot of pain, a lot of misery, and I like to say it doesn’t affect me, but it still does affect me. I try to keep balance. I try to keep reminding myself that I’m a litigator and not a litigant. That I’m the voice for people. You know, on the side … One of the things that we have that no other profession can claim … One of the things that we, as lawyers, have that’s a sacred and a beautiful thing that we have the ability to do that nobody else … Doctors can’t say they do it. Architects can’t say they do it. Engineers can’t say that they do it. We’re the only category of professionals that can represent individuals in court. We’re the only category of professionals that can go to court and actually stand in the shoes of somebody in court.

I came to the realization, even though I’m dealing with a lot of painful stuff and a lot of misery that people experience, that if I, as their advocate, am to caught up in their misery, I’m really no good to them. I’m the litigator, not the litigant. I’m not the one that’s suffering and hurt. I feel their pain and I have to communicate their pain, but if I get caught up in their pain and buried in their pain, then I’m no good to them as a litigator.

Scott: That sounds like, sort of, a contradiction in that you’ve got to feel their pain to communicate it but not feel it too much so you go crazy.

Eric: That’s right. That’s why you got to strike that balance. You got to strike that balance, and I had to come to that realization. It happened to me because I saw an older lawyer … I was in the trials. I was in the middle of a trial, and it was a hot contested trial. An older lawyer, who had been watching the trial, came up to me and said, “You got to realize or remember that you are the litigator, not the litigant. Don’t get too caught up into it.” You got to keep a cool head is what he told me because I was getting fired up at a bad ruling we had received. I took that to heart, and I got an acquittal. That was in a murder case that he came up and talked to me. We ended up getting an acquittal in that murder case as well. It was a double homicide, an alleged double homicide that we got an acquittal in. I took those words to heart, and I keep that with me now. I know I’ve got to feel for my clients because I do. But I got to … If I don’t keep a level head as their advocate, as the person who stands in their shoes in court, then they’re doomed.

Scott: I know you’ve got four beautiful children. When they were, let’s say, in kindergarten, what was the advice or words of wisdom that were most important to you to share with your kids?

Eric: That I still, to this day, I live life with no regrets basically. I communicate that to them as often as I can. To live life without regret. I mean, you’re always going to have some regret, but if you live life with a mindset that “I don’t want to have any regrets”, then you’ll live life to the fullest.

Scott: Eric, thank you so much for being here. I’m very proud to know you. You’re a wonderful lawyer. You do wonderful work. You’re great trial lawyer. A great human being.

Eric: Thank you for the opportunity, Scott.

[instrumental music plays]

Scott: Thank you for joining us today for Trial Lawyer Talk. If you liked the show, I’d really appreciate if you could give us a good review on iTunes and I’d love to get your feedback. You can reach me at scottglovsky.wpengine.com. That’s S-C-O-T-T-G-L-O-V-S-K-Y.com, and I’d love to hear your feedback. You can also check out the book that I publish called “Fighting Health Insurance Denials: A Primer for Lawyers.” That’s on Amazon. I put the book together based on 20 years of suing health insurance companies for denying medical care to people. It provides general outline of how to fight health insurance denials. Have a great week, and we’ll talk to you in the next episode.