A-How to Be Proactive Not Reactive 54m PDF

A-How to Be Proactive Not Reactive 54m Mon, Dec 02, 2024 10:05AM 54:29 **SUMMARY KEYWORDS** proactive discovery, reactive discovery, personal injury, employment law, intake process, document requests, client credibility, timeline importance, social media evidence, medical records, internal dead...

A-How to Be Proactive Not Reactive 54m Mon, Dec 02, 2024 10:05AM 54:29 **SUMMARY KEYWORDS** proactive discovery, reactive discovery, personal injury, employment law, intake process, document requests, client credibility, timeline importance, social media evidence, medical records, internal deadlines, privilege log, demand letter, meeting confer, protective orders A-How to Be Proactive Not Reactive 54m ====================================== The webinar, sponsored by Doctors on Liens, focused on the importance of proactive discovery in personal injury and employment cases. Key points included the necessity of identifying case types early, gathering comprehensive client information, and using templates to streamline processes. Emphasis was placed on the importance of timely document requests, both from clients and defendants, and the organization of these documents in a chronological and privileged log. The speakers also highlighted the significance of setting internal deadlines, preparing thorough demand letters, and being strategic in discovery requests to avoid unnecessary objections. The session concluded with a Q&A segment addressing specific queries about handling cases and document requests. Transcript ---------- Action Items ------------ - \[ \] Identify the type of case (auto, premises, etc.) and any overlapping considerations (e.g., workers\' compensation). - \[ \] Gather detailed facts about the incident from the client at intake. - \[ \] Send the client an initial contact letter requesting documents and having them complete form interrogatories. - \[ \] Obtain on-hand documents from the client, including photos, cell phone data, and timelines. - \[ \] Send an initial document request letter to the defendant, including a preservation of evidence demand. - \[ \] Obtain police/incident reports, medical records, and lien information (Medicare/Medi-Cal) early on. - \[ \] Implement a system of internal deadlines to proactively manage the discovery process. - \[ \] Organize the documents in a chronological order and maintain a detailed discovery log. - \[ \] Use the gathered information to draft a comprehensive demand letter and complaint. - \[ \] Propound discovery, including form interrogatories and requests for production, within 10 days of service of summons. - \[ \] Handle meet and confer discussions with opposing counsel proactively and focus on the key issues. Issues & Risks -------------- - Risk of losing important evidence if not collected early, especially from client\'s cell phones. - Concern about clients\' credibility and how it might affect the case. - Risk of missing deadlines for filing claims or responding to discovery requests. - Issue of defendants objecting to everything in discovery responses. - Concern about protecting proprietary information in discovery requests. Next steps ---------- - Paralegals should organize documents chronologically and create a discovery log. - Attorneys and paralegals should review timelines provided by clients. - Paralegals should calendar internal deadlines for discovery processes. - Attorneys and paralegals should prepare meet and confer letters when receiving inadequate discovery responses. - Attendees were encouraged to email the speakers with any additional questions before the next session. Next steps ---------- - Paralegals should organize documents chronologically and create a discovery log. - Attorneys and paralegals should review timelines provided by clients. - Paralegals should calendar internal deadlines for discovery processes. - Attorneys and paralegals should prepare meet and confer letters when receiving inadequate discovery responses. - Attendees were encouraged to email the speakers with any additional questions before the next session. Questions discussed ------------------- - \"Do you call or send defendant a letter requesting information right after auto collision and before filing claim to try to get a statement from them?\" - \"How do you get your hair still on point?\" (directed to Sergio) Timeline -------- - Discovery can be propounded 10 days after service of summons. - Internal deadlines should be set 10-15 days before actual deadlines. - A second session on discovery during litigation is scheduled for August 6. - Clients should be given a two-week deadline to return the \"stage one docs\" after signing the retainer agreement. Timeline -------- - Discovery can be propounded 10 days after service of summons. - Internal deadlines should be set 10-15 days before actual deadlines. - A second session on discovery during litigation is scheduled for August 6. - Clients should be given a two-week deadline to return the \"stage one docs\" after signing the retainer agreement. Outline ------- ### Introduction and Overview of the Webinar - Speaker 1 introduces the webinar titled \"Web Live Program: A Discovery Playbook - How to Be Proactive, Not Reactive,\" sponsored by Doctors on Liens. - Speaker 1 provides information about Doctors on Liens, highlighting their services and benefits for attorneys. - Moderators for the webinar are introduced: Lupe Flores and Rose Gutierrez, with their respective backgrounds and roles in the legal field. - Speaker 2, Rose Gutierrez, introduces the first speaker, Sergio Bucha, detailing his qualifications and professional achievements. ### Introduction of Speakers and Initial Remarks - Speaker 3, Lupe Flores, introduces Derek Tran, highlighting his focus on consumer employment law and his professional accomplishments. - Speaker 4, Derek Tran, begins the presentation by thanking the audience and outlining the agenda for the webinar. - The goal of the webinar is to distinguish between a good paralegal and a great paralegal, emphasizing the importance of being proactive. - The presentation will cover identifying the case, gathering initial documents, and managing expectations. ### Identifying the Case and Gathering Initial Information - Speaker 4 explains the importance of identifying the type of case, whether it is a personal injury or employment case, and the specific details involved. - Speaker 5 emphasizes the need to use templates and prior cases to streamline the process and avoid reinventing the wheel. - Speaker 4 discusses the importance of gathering detailed information from the client during the intake process, including the event details and any witnesses. - Speaker 5 highlights the significance of assessing the client\'s credibility during the intake process and gathering a timeline of events. ### Stage One Docs and Initial Document Requests - Speaker 4 introduces the concept of \"Stage One Docs,\" which involves sending initial document requests to the client and gathering on-hand documents. - Speaker 4 provides an example of an initial contact letter and the importance of tailoring it to the specific case. - Speaker 5 discusses the importance of gathering witness information and timelines in employment cases. - Speaker 4 and Speaker 5 emphasize the need to gather all relevant documents, including medical records and social media evidence, early in the process. ### Initial Document Requests to the Defendant - Speaker 4 discusses the importance of sending an initial letter to the defendant, requesting the preservation of evidence and specific documents. - Speaker 5 shares their firm\'s practice of combining multiple requests into one comprehensive letter to streamline the process. - Speaker 4 and Speaker 5 emphasize the importance of following up on document requests and the potential consequences of non-compliance. - Speaker 4 highlights the need to gather police reports and medical records early in the process to avoid delays. ### Organizing and Managing Discovery - Speaker 4 discusses the importance of organizing documents in a chronological order and creating a discovery log. - Speaker 5 emphasizes the need to create a privilege log to identify any privileged documents and avoid inadvertent disclosure. - Speaker 4 and Speaker 5 discuss the importance of using the gathered information to develop the client\'s story and support the demand letter and complaint. - Speaker 4 and Speaker 5 highlight the importance of using case management software or an organized system to keep track of all documents and information. ### Preparing for Discovery and Managing Expectations - Speaker 4 discusses the importance of setting internal deadlines and managing the workload to stay proactive. - Speaker 5 emphasizes the importance of preparing the first draft of documents and demands to be the final draft to save time and effort. - Speaker 4 and Speaker 5 discuss the importance of communicating deadlines and expectations with the client to manage their expectations. - Speaker 4 and Speaker 5 highlight the importance of being proactive in preparing for discovery and managing the case from the beginning. ### Handling Objections and Meeting Conferences - Speaker 4 discusses the importance of handling objections to discovery requests and preparing for meeting conferences. - Speaker 5 emphasizes the importance of not getting upset and focusing on the big ticket items when dealing with objections. - Speaker 4 and Speaker 5 discuss the importance of preparing for meeting conferences with authority and having a clear plan of action. - Speaker 4 and Speaker 5 highlight the importance of being reasonable and understanding the standard practices when dealing with objections. ### Final Remarks and Q&A Session - Speaker 4 and Speaker 5 thank the audience for attending and provide their contact information for any further questions or assistance. - Speaker 3, Lupe Flores, opens the floor for questions from the audience, addressing specific questions about handling cases and gathering information. - Speaker 4 and Speaker 5 provide additional insights and tips for handling cases and managing discovery. - The webinar concludes with Speaker 1 thanking the speakers and attendees, and providing information about the next session in the series. 0:00 Thank you Good day, and thank you for joining us for today\'s seminar. Web live program, a discovery playbook, how to be proactive, not reactive, the first in a two part series. You may submit questions over the web throughout the program by typing them into the Q and A section at the bottom of the screen, and we will address them at the appropriate time. Today\'s webinar is sponsored by doctors on liens. Doctors on liens is a network of qualified medical professionals who specialize in med legal evaluations and treatments for personal injury and workers compensation cases on a lien basis. There is no cost to the attorney, no commission and no hidden fee, because they pre screen and pre approve each and every one of their medical professionals, you\'re always assured prompt and courteous service, same or next day appointments and detailed med legal evaluations completed within two weeks of patient discharge. So thank you to doctors on liens. Our moderators today are Lupe Flores and Rose Gutierrez. Lupe is a senior trial legal trial paralegal with over 20 years of experience in litigation. She started with the firm of Chernoff Bedard COVID area, LLP in 2009 where she works closely with the attorneys of the firm in all aspects of the litigation process, from inception through trial. Mrs. Flores was a member of the 2017 inaugural Cala legal staff committee, and is the current chair of the legal support staff group. In 2018 she was awarded Cal is prestigious Presidential Award. Rose Gutierrez is litigation manager at the law firm of Michaels and Luis, which represents catastrophically injured plaintiffs throughout California in medical malpractice and personal injury actions. For the last 16 years, she\'s overseen and managed the firm\'s litigation assistance and all cases that are in active litigation. Rose is currently the vice chair of the legal staff support group. I will now turn the call over to our moderators. Please go ahead. 01:49 Hi everybody. I\'m Rose. I just want to welcome everyone out to today\'s webinar, and I have the pleasure of introducing one of our speakers, Sergio Bucha. Sergio is a litigation and trial attorney at the Law Offices of model Fiore Junior, where he represents individuals against corporations and employment and personal injury cases. Sergio is a graduate of the California Western School of Law and a member of the American Bar Association, American Association for Justice, California Employment Lawyers Association, Consumer Attorneys Association, Association of Los Angeles, where he serves as co chair of the new Lawyers Committee and is a proud board member of the trial lawyers charities. He\'s a graduate of the Consumer Attorneys Association of Los Angeles, plaintiff Trial Academy in 2017 in 2019 Sergio was selected as the National Trial Lawyers top 40, under 40 and Super Lawyers, rising star Sergio practices in state and federal courts throughout California. Welcome Sergio. Thank you so 02:48 much. 02:51 Oh, hey, serger. Good afternoon, everyone. My name is Luis Flores, and I have the pleasure of introducing Derek Tran. Derek is a managing partner of Rodriguez and Tran with his focus on consumer employment law, he serves as a board member of the consumer attorney of Cal is and CA. He serves as a board member on caoc and Cala he is also he was also named a 2020, Super Lawyer, rising star, welcome Derek and Sergio. Thank you so much for joining us. All right, guys. All right. 03:29 Good afternoon, everybody. Thank you all so much for joining us. I\'m going to go ahead and start sharing the PowerPoint so we can get started, 03:38 just in case there\'s no confusion. That\'s Sergio and Derek. 03:50 All righty discovery part one, intake and pre lit. 04:01 So behind every successful attorney is an exhausted paralegal. And we\'re not sure who said this first, but I know everyone on this webinar, Derek and I, Luis rose, and all of you out there joining us can attest that this is true. So we want to first of all, thank all of you for working as hard as you do. Without your hard work, we could not be successful, and we could not bring justice for our clients. 04:31 So good afternoon. This program is for you. So if you have any question, please, please, please ask us, and we\'ll try to address it Luis Rose, who are very experienced paralegals. Please interject whenever you have a comment, we welcome that as well. So Derek, all right, so what we\'re going to cover today in our discovery presentation, we\'re. We\'re going to identify the case. What are the facts to the case we\'re going to do sign up, stage one, Docs, initial document requests, and what to do with the discovery. So when Rose and Lupe asked Sergio and I to kind of speak on this panel, we kind of wanted to plan out a program where we distinguish a good paralegal from a great paralegal, and it\'s all about being proactive and kind of managing expectations that way. So with that in mind, we\'re going to go right into identifying the case. 05:32 Now, when you identify the case, you want to check the ID right. What? What are we looking for here, I\'m going to be talking more about personal injury cases, and Derek will talk about employment considerations, and we\'ll chime in on each other\'s a little bit, because I do do a little bit of employment as well. But when you\'re looking at a case in pi, first of all, what is it? Is it an auto case? Is it a pedestrian V auto, or auto via are you talking about a slip and fall or a trip and fall in a premises case, are we talking about a dog bite? What are we dealing with here? And then, is there any overlap? There might be overlap with workers compensation, or there could be overlap with the entities that you\'re suing, for example, in a premises case, let\'s say the client trips on a sidewalk. Well, was there an adjacent property owner, you know, doing some construction building a Starbucks. So you got to make sure what your case is from the beginning, add intake, and then talking to your client, so that if there is any overlap, or any considerations that you\'ll need in framing your case and beginning to ask yourself and ask your client the right questions to get the case ready move forward. You know what those considerations are and what your case is? Yeah. So 06:47 when you ID the case, the whole point is, you\'re not reinventing the wheel here, right? You want to be able to find out what type of case you\'re dealing with. So in an employment realm, if it\'s a discrimination case with some Wage and Hour issues, you\'re going to follow a template that you\'ve done, that your firms use in a prior case, a year ago, a couple years ago, you\'re not you don\'t want to create extra work on yourself. You\'re going to work smarter, not harder. So very important, find out what the overlap is in types of causes of action, and then you\'re going to use templates. And if your verb not using templates, sorry about that. So 07:27 there\'s no better time to start than that. Look at your prior cases. So what are the facts? The best time to ask your client what the facts are are not once you file the case and you have discovered propene on you. It\'s from the beginning at intake, okay, what? What was the event in personal interview cases, usually you\'re dealing with a single event, the car crash, the trip and fall. It\'s not a long story like you might have been in an employment context, and so you want to make sure that you have as much detail about that story from your client at intake, what did they slip on? What aisle were they in? How long were they there? You\'re going to get these questions in discovery down the road. And so the best time is when your client has that recollection and they\'re able to tell you, I was coming from, you know, my mother\'s house, heading to my sister\'s house, the address is XYZ. Two years later, when you\'re doing discovery, it\'s it\'s too late, they may not remember, and so it\'s going to help your your case, and your client. If you have the information saying, later, I don\'t recall, the client doesn\'t recall. That really minimizes credibility, and we need to establish credibility for our clients in order to bring them justice. Also, you can talk to them about any percipient, witnesses, people that might have come to the scene to help them, family members, tow truck drivers, the police, and if it\'s a slip and fall. Oftentimes, our clients who slip in supermarkets, they have other shoppers who come over and they ask them, Are they okay? Did they get their names or phone numbers? You know, get those facts and get that story early on? 09:07 Yeah, I think at this stage, and I know some firms, they have their own intake specialists that handles the intakes, and some smaller firms might have the paralegal do the intakes, it\'s so important to participate in the intake process, because at this stage, not only are you getting the facts from your client, you that that image says it all, it\'s back or fake, right? You\'re you can assess their credibility, but what they\'re telling you body language, you can assess their credibility and what they\'re telling you later on, which, which will address which, when we ask for the client to provide us with a timeline. So this is the time where you can sit there and listen to the what the client has to say, and make a determination on credibility as well, which is a very, very important thing in what we do. And I 09:53 think there\'s some different considerations when it comes to pi and employment. And pi, you know, what are the injuries? What are the prior injuries? Is get that information from them now so that you know what\'s new and employment, if you\'re dealing with a sexual harassment case, you really want to have empathy. 10:09 Yeah, you really want to identify with that client, and you want to make sure not only will you identify how would that client, how will that client be perceived by the jurors, by the judge, such an important part. 10:20 And we all hear about BS meters, and we have bs meters. You all have bs meters. So make sure that you turn that on, and you try to figure out, you know, fact from fake. And then let us know what you really think about the client. Don\'t just tell us, you know, all the good stuff, but really assess it and let us, as the attorneys, know we\'re a team. We need to know what you think about it, because ultimately a juror might feel the same way, or a judge or the defense attorney on the other side trying to convince the insurance company to not pay out any money because they don\'t leave our clients credible, we can find that out 10:55 now. So Sergio and I agree that the discovery process starts here at intake, because you\'re fine. You\'re getting that information from your your client. You\'re discovering facts at this early stage already. This is where it starts. 11:09 Yeah. So today\'s session is going to be mostly about pre litigation discovery, and there\'s going to be a second session on august 11:18 6\. Six. Loopy, 11:22 yes. August 6, and 11:24 there we will talk a little bit more about discovery throughout litigation. So this is setting us up to be able to have the discovery that we need sign up stage one. Docs, Derek coined the phrase stage one. Docs, I hadn\'t heard of it before, but I really like it. This is stage one. You\'re setting the stage for your client\'s story, and so your client is an invaluable resource. You want to first of all, send documents and document requests to the client. So we have provided for you an initial contact letter that we use at our firm, both in employment and pi cases, there\'s two separate ones. Make sure you take a look at the letter that you\'re sending out and you tailor it to your specific case for your client. Is it an auto case? Is it a dog by case? What kind of documents would you need? Police reports versus incident reports? You know? What do you need there from your client. Take a look at that letter. It goes through everything that you\'re asking them for and letting them know that we\'re here for them. It\'s super important to have your client know that we\'re interested in their case, and at this stage, you can also make sure that your client is interested in their own case, and it\'s going to be helpful, because down the road when your client needs to be a little bit more involved with discovery, depositions, preparing for testimony, preparing for trial, you don\'t want there to be a gap of a year that you haven\'t spoke to them. So this is a good opportunity for you to know that their their case matters, and make sure that they\'re involved with you. So in that initial contact letter of the client, we also send some documents along with it, including form interrogatories. These are judicial discovery forms. The general one is 001, I\'m sure you\'ve all worked with it before, but it\'s a good idea to send it now you know that it\'s a premises case, or, you know, it\'s an auto case. So check the subsections on those form logs and send them to your client and have them answer them to the best of their abilities. They might not be able to answer everything. But also make sure that you don\'t check, you know, the three series or something that doesn\'t apply to the plaintiff. Check, check the boxes that apply to the case. Make your life and your clients lives easier? 13:42 Yeah, so, I mean, for me, this really boils down to making your life easier, right? You\'re delegating some of this work to the client. It\'s their it\'s their case. You\'re collecting all of this information well in advance from when you need it, because you\'re not you\'re being proactive. You\'re not going to be reactive where it\'s two weeks or one week or two days before the deadline of responding to discovery, you\'re going to have these documents in place already and return from the client. So it\'s all there for you. Some of the things that I want to address in employment cases, we should have provided a witness information sheet. It\'s a who said, what it helps you gather all the witnesses and what the importance of those witnesses are from your client, like John Doe was a fellow colleague, and he said this some racial remarks or something like that, and it\'s all there for you. So you can get declarations. You can make the determination on whether or not. You can recommend to your attorney to your attorney to pull them in for a deposition that\'s going to be on there. And then the additional thing that we send out in an employment case is the right to sue template. So before you can file a civil case in employment law, you have to file a right to school. You have to obtain a right to sue. You have to file a complaint with the Department of Fair Employment and. Housing. And that template is, you know, what happened to you? Why do you believe you were discriminated or retaliated against? And these are all filled out by your client, so that way, when you get that back and it\'s time for you to file that and obtain that right to suit you have all the information there. You know you\'re not going to do this piece mail and you\'re not going to do it last minute. You\'re going to have your client, and at our firm, the minute after we sign the retainer agreement with our client, we hand them the stage one docs, and it\'s all the stuff that they have homework. I tell them they have homework that they have to get access within two weeks. And then we calendar that and we make sure they get that back to us. 15:37 Yeah, that\'s a great tip. They\'re in your office, signing the retainer, might as well get more than for them. 15:47 So stage one docs continued. 15:51 These are to the client. You want to get the on hand documents that your client already has. If they\'re in your conference room, they\'re there with you. What information can you get from them? You want to take copies of their ID, their insurance documentation, if they have photographs, if they have you know any type of documents that are related to the case, if they\'ve already gone and grabbed the police report, if they\'ve gotten any letters from the the adjuster on the other side, whatever they have. You need to make sure you get those then, and literally, on hand. The cell phone, okay, your clients, most of them, have cell phone that they\'ve taken pictures on, that they sent texts with. You can get these documents from them immediately, and anything can happen. They could, you know, be out at the beach like everyone was this weekend, and drop their phone in the ocean, and everything is wiped out because they didn\'t save it on the cloud. You want to make sure you get that early on, because if, if you don\'t get it, and something happens, they break their phone, they lose their phone, you\'re really going to be kicking yourself later, because now all that great evidence, all that great discovery, is not there anymore. Yeah, at 17:05 our firm, we have the initial intake via the phone, and then we ask them if they make it past that point. We asked them to come in for a face to face interview. And now with COVID and all that stuff, it\'s virtual. But at that point where we ask them to come in for the face to face. We tell them to bring every document that they have on hand, because it\'s so much easier for them to come in with, like a box or half a box, whatever, and you scanning that right there, and then then trying to chase them down months from now or months after signing them up. So that\'s one bit of tip that we do. We ask them to bring in all this stuff. So what\'s important? For employment law? Those are like, if they have any policies, any of their payroll documents that they might have, that the pay stubs, you know, witness information, if they have they want to fill something out and give it to us. And then one of the things that we absolutely required from our client is a timeline. I mean, this is in employment law, because there\'s, there\'s a string of activity that happens before it\'s set up for a an actual like termination, for wrongful termination, we put, we have them put together like from the date they were hired, and it ends at like when they were terminated, and everything that happens in between. That\'s, that\'s of that is of issue that is important. I mean, write ups, if they were written up on the good, good side, if they got a certificate for attending some type of training, if they got a bonus. I mean, they\'re putting all of this stuff in there, because you\'re collecting all of this information, all of Discovery now, from the front end right and Sergio, how important is the timeline being reviewed with the attorney or the paralegal? 18:48 I mean, it has to be reviewed. It has to be reviewed. You have to go over it, and then you have to check each and every part. Earlier, we talked about fact versus fake, talk to them about why they put this in there. Have specifics. You know, who are the witnesses that were there, who were the bad actors? Have their names written down. What is their position? Who did they speak to at HR? What was the name of the adjuster that called them? Who else was in the car with the defendant? Was there, a kid, was there, an adult was there, a baby, whatever there was. You need to get all this information from them there and get those details. Because you know, as my boss says, This business is about the details, and if you\'re not about the details, you\'re in the wrong business. So thank you, Marvel Fiora Junior for that, and you want 19:33 to ask them for a timeline early on, because I don\'t know about pi as much, but in employment law, you know you don\'t file your complaint until like, nine months, maybe even a year later. So guess what? Their memory is going to be all like, clouded nine months a year from now, as opposed to, like, Hey, I was just terminated last week or two weeks ago. So put everything down now. Right? 19:55 Absolutely. Social media. Big, big issue. Have that is happening now because everyone has social media. They have Facebook, Instagram, Snapchat, whatever, and the defense companies are entitled to it. So we want to make sure we go through that with them from the beginning and find out you know what they were posting on the date before the date of the date after, and then close in time. I\'ve had situations at our office where, you know, subrosa is a big deal. And the subrosa comes not even from a PI following them around, but from my own clients, Instagram, Crystal and Morrow, had a case where this guy was, you know, holding a barbell over his head. He looked like an Adonis. He looked like one of the strongest men in the world, and that shoulder had had an epi the day before. So check the Instagram always, always, always make sure that you know you have this information for your clients when you can get it early on. I 20:55 mean, yes, so we\'re not saying you have to do this. This is what sets a great paralegal apart from a good paralegal, right? You get, you get their Facebook information, and maybe you go on for like, 30 minutes or 45 minutes, and you look at the date of their injury, or that they were terminated, or whatever it is, and you maybe look three days, five days out, and see what\'s going on in their life. Are they claiming that, hey, you know, I got terminated. I\'m so sad, I\'m depressed, I have all this emotion of distress. And then you go on their Facebook, and you see on social media that post after post, they\'re at the club celebrating table service, you know, like, how depressed Are you? You\'re like, popping bottles, you know, so very important. Saves us a little bit of work. And it\'s you being on top of certain things. And it goes back to credibility. 21:37 You can also use it for good. We\'re giving examples of bad things that are true, but we had a client. She was a pedestrian versus Auto, and she got hit in the middle of the street in Laguna Laguna Beach of pch, and our client herself did some investigation on Facebook, and she was able to find a woman that posted on the Laguna Beach forum or something on the night of the collision and said, you know, oh my god, I just saw this girl get hit by a car, and she flew 30 feet and lost her shoes. I hope she\'s okay. This was incredible for us to have, because it was a percipient witness that was there at the scene who we could contact via Facebook and then have her come in and testify as to, you know, the horrific, you know, pedestrian collision that that we had in our client was pretty severely injured. She was in the hospital for weeks, and so this was really, really helpful to us. So a little bit of digging can really go a long way. You\'ll be surprised what you find out there. And so we highly recommend that you do what you can to spend a little bit of time on the social media. 22:47 So as part of the initial document requests, there\'s 22:50 two sides to a great coin, right? So we\'ve already talked about what you send to the client. What about the initial document requests to the defendant? You want to send an initial letter to the defendant letting them know that you are the representative. It\'s an initial rep letter. But what else can go on there? I know Derek at your office. You guys have an all inclusive letter, and so do we. So I\'ve provided both a PI and an employment initial document, initial letter, the defendant, for you guys to all see what goes in there. Asks for those documents. You know, it lets them know that they need to preserve the evidence. It all goes in together, and it all gets sent off right away. 23:32 Yeah. I mean, in the beginning, our office used to do like, three separate letters. We used to do a rep letter, and we would send out a preservation of evidence letter, and then we would send out a letter requesting the employee or clients personnel records and their pay pay records. So that was like three letters, and a year into it, we\'re like, why are we doing this? Let\'s just combine it into one get these documents that they\'re entitled to and ask for it in one document. Work smarter, not harder. So when we did, when we do that, we\'re able to just put together our requests, and then we can immediately schedule the internal deadlines that we have, like they have a certain period of time, 2130 days to get us their employer e records to us. And if they don\'t, we follow up with the labor secretary and get them fine, because these are hard deadlines that they have to provide these documents that you know that meme is my my mind, that\'s that\'s the client\'s documents that belongs to them. They are entitled to that, to those discovery of those documents. So you do that, you file with the labor secretary. They\'re late. But at the end of the day, how important is it for us to get the documents, as opposed to getting them fine. Yeah, 24:43 you the fine is just a way to try and get them to come to the table and so that you can get those documents. But \$750 a fine, and you can collect up to 1500 bucks that goes directly to the client. By the way, most firms, that\'s what we do. We don\'t keep any of that that fine money. But my client is going to be served so much more by being able to get those documents and having that information early on, rather than being able to cut them a check for, you know, \$1,500 because the company didn\'t provide the issues. So follow up, calendar it and make sure you get the information that you deserve. 25:16 Yeah, and work with them. And sometimes they didn\'t get that request, and we at our office, we give them a second chance, we give them five additional days in a letter that they can produce those records to us, because, like Sergio said, that\'s the at the end of the day, the client\'s better served by with us getting those documents than them getting that \$750 or \$1,500 in their pocket. 25:37 Yeah, yeah. And employment, you can get a lot of stuff from your client, and for the defendant in pi, you can get stuff from third parties also. So here we have the police or incident reports. If it\'s a police report, make sure you if your client hasn\'t gotten it or they can\'t get it, you do everything you can to get that. There\'s letters and there are fees to be able to get these police reports, but make sure that you know what city or what Sheriff\'s Department, what each requires and what the correct address to send that letter to? I provided a couple letters here. Hector, our office has a list of, I don\'t know, 10s and 10s of city police departments and Sheriff stations, and each one has a different address. So I provide a city of LA and County of LA, make sure you have the right address on the form, send it out, send the check in and follow up. Make sure you get those police reports. Send if you have a person, a personal, you know, investigator from your office that kind of, you know, does these kind of things. We have a guy and she goes out to the police departments, you know, with the checkbook and the letter, the authorization, whatever you know the police department requires, so that we can get those police reports early on. You need them. You don\'t want to wait until you know discovery and you get them from the defendant, get them early, get on yourself, do that little extra work so that we were prepared moving forward on the case. Another really big thing in PI cases is the medical records. You want to get medical records from your client, make sure that you know who their primary care provider is. Have they had similar injuries to to to those parts of their body, and get those records from from their their doctors. You know, if you need to hire a record company, get that record company to get those records for you, and most important is Medi Cal and Medicare, you\'re going to need to make sure that those liens are closed out and there\'s nothing outstanding, or else it\'s going to hold up settlement at the end. So make sure you go on the portal and you get those documents from them, for the medical records and for for Medicare, and then for medical as well. You need to make sure you send in the letter so that you can get that information early on, and if your client is still treating well, then set yourself a tickler. You know, what are those tickler things everyone talks about? You know, tickle I don\'t know, put them on your calendar. Make sure that you follow up later on. If for whatever reason you can\'t get them early, there\'s there\'s sometimes reasons you can\'t, but don\'t just let it go. And two years later, when the discovery comes in, it\'s like, Oh, I forgot to get the DHCS. That\'s not acceptable. We need to have it early on, and we need to make sure that we follow up. 28:24 So I think the tickler system leads into this slide, which is internal deadlines. So we have hard deadlines. Those are deadlines where you you know that\'s a statute limitation. You blow that, boom, boom, you know your clients rights and their access to justice is gone. But then there are internal deadlines to make your life a little bit easier for you to manage and be proactive. When can discovery go out? That\'s an internal deadline. When do you plan on starting to submit and propel discovery? You know, those are internal, internal deadlines that you can work with your attorney, or maybe you just have your own deadlines, but you know, that\'s how you proactively manage your workload and the discovery, so that you\'re not behind the ball, you\'re in front of it, and you\'re controlling it the entire time. So I\'ll give you an example. At my firm, we have deadlines for almost everything. We put an internal deadlines. We put internal deadlines 10 days before. It\'s actually like our actual internal deadlines, because that\'s a reminder that the staff needs to start working on that so they\'re not behind the ball. And the one thing I hate the most is we put something in the letter like, Hey, we\'re going to file the DfE H and retain the right to sue, or we\'re going to file the complaint on this date in our demand letter, and then guess what? We missed it because we were behind the ball. You know, why do that to yourself? Internal deadlines. Schedule it 1015, days, whatever you feel comfortable. I don\'t know what your workloads like. And then start working on that and getting it to that to that point. And instead of having your attorney, hey, where are you on this? You know, you\'re going to have that already. That\'s that\'s a great paralegal. And talk, talk to 29:59 the. Attorneys in your office, talk to your attorney, make sure that you\'re on the same page and that what works for both of you is what\'s implemented. Because we do things our way, and we\'re still, you know, changing our procedures, preparing for this webinar, actually, I\'ve implemented some new things at my office that I think is going to help us, you know, be be better and manage our case is much better. We I got to practice what I preach, right? So you know, Wendy and Lily on my team, we\'re going to do different things now in order to have a better management of our cases and have better results. So make sure you talk to your attorneys, and you make sure that you guys are on the same page and that you\'re doing what\'s best for your office and for your cases when it comes to internal deadlines, you know, they\'re soft deadlines, but they should be hard. You know, they should be deadlines that you are focusing on and actually complying with and making sure that it gets done by that day, because that\'s the whole point of it. You don\'t want to be rushing to get something out at the end when you could have done it early. Anything else, yeah, 31:08 just on this one final note, on this slide, at my firm, we have this practice where the submission, the first draft that\'s submitted to us by our staff, should be the final draft. It should be ready to go. I mean, it\'s like, if you get the okay from your attorney, then it\'s ready to go out that day. So we\'re not asking for like, I\'m doing, I\'m going through the motions. I\'m just putting this together, because we\'re going to go through three iterations of this draft. That\'s It\'s not like that. Work smarter, not harder. So if you put, you know, effort into it, and you you make that first draft, your final draft, it\'s going to save you a lot of time. It\'s going to be a lot easier for you to make a couple corrections, as opposed to doing draft after draft after draft with your attorney review. 31:53 So a couple things on this slide, just what do you need? The information by calendar that make sure that you know when you\'re getting it, like the DHCS letter that I was talking about earlier, and then for hard deadlines, government claims or private claims, you know, what is your different deadline for? You know, a trip and fall on a la sidewalk versus a slip and fall inside of botaga Latina, right? Make sure that you know what the difference is, and that you communicate that with your attorneys, and that you know when things need to be filed. So then you can set up your internal deadlines and the government claim you\'re going to want that those those incident reports or police reports, or whatever, way sooner you need to make sure you have them in so that they corroborate your evidence, your story, and that they are within the deadlines. And employment cases, yeah, 32:39 employment you want to schedule those deadlines where you have to file the DF, eh, to get the right to sue. You know, want to file when you need to put together the complaint and file that when, when this service of summons do and you know, that\'s that\'s all important, hard deadlines, and then internal deadlines, what we discussed before. I mean, just suppose that and 32:59 your clients expectations too. You got to make sure you communicate that with your clients so they know that, you know they\'re in this for the long run. Communicate those deadlines with them so that they know, you know, we have three years to file a DFH, but our practice is to file within six months, or nine months, or whatever, after getting the documents or we\'re going to negotiate. And then, you know, file no client wants to wait three years to file a case, you know, so make sure that you communicate that with with them, and you\'re all on the same page, all right. So you\'ve got the documents now, what well you want to organize? And in our experience, the organization really is best in chronological order, whether it be, you know, a single event, like in a PI case, or it be in an employment case where someone was there for a long time, you want to make sure that the documents that you know that you have, are organized well, make a discovery lock. You should be going through every single document that comes in. We need to know what\'s in there. We need to know, you know what the police report says, how many pages it is? You know, if there\'s, you know witnesses, who they are, all that stuff needs to be organized. And a discovery log is really simple. You have the Bates numbers on the left hand column. You have, you know what the date of the document is, who the author is, who the recipient is. You know, is it good or bad? And then, you know, what is it? You know, just a quick little one or two words if you can describe what it is. You know, police report, incident report, whatever it might be. And you want to be able to have that ready and have every single document that\'s in on an Excel spreadsheet or Microsoft Word document, whatever it is, but organized so you know what you got. Yeah, and something that goes hand in hand with the discovery log is the privilege log. 34:50 So there might be some 34:53 some info, information that you ask from your clients and documents that you need that are that are privileged. And, for example, the timeline. So when you ask your clients, put together the timeline, make sure on there. You don\'t have to, but you should, as a good practice, put on their privilege toward a client communication, because that\'s a privileged document. You know, you don\'t want to hand that over to the other side. You know, maybe it\'s communication, text messages regarding the incident with the between the client and their spouse, you know, that\'s protected, that\'s privileged, that\'s marital communication that\'s going to go on your privilege log. And something that I want to bring up is when you create and when you base stamp and there\'s privileged documents on there, just make sure you don\'t put the, you know, those privileged documents in the front or in the middle. You know, I always try to, I tell my team, put it at the end, because it looks odd when you produce documents and then all sudden, like Bates, stamps, 00, whatever to 100 is missing. You know, then now you got to explain the council and all that stuff you just put at the end. You\'re good. It\'s just one less headache you have to deal with. 35:56 And so once you have your timeline, you can really develop your story with the supporting facts. You already got a cohesive story from your client up front in the intake. Now you want to be able to take those documents and support that with your evidence. Because, well, we want to use this as our sword. That\'s Lady Justice there holding the scales of justice and the sword. Because, you know, justice is swift, so long as you use the tools for you to bring justice to your client. And so there, how do you use the information for your demands and the aviation plan? Exactly, 36:33 quick. Can we just go back to the last slide? 36:38 So one example I want to give is when you develop the story, you know, like your client tells you, like, oh my god, I was such a great employee for like, you know, 10 years. And then now you get all the documents in and their performance review, it\'s like, meets, meets, meets, meets expectations. Come on, you weren\'t really great employee. You were average, you know, so and then on the on the other side, you know, they might be a great employee. You see exceeds, exceeds. Why were they fired? This was an amazing employee. That\'s that\'s the connection here. That\'s what you\'re doing. You\'re asking your client for that timeline. You\'re going over with them. You\'re getting the supporting docs that evidence to support all of that. And it makes our case stronger. Or worse, it could be the case, but we need to know about it. Sorry. Now we go down slide. Well, 37:21 no, I forgot something to enter it into your case management software, if you have one, put it in the file. Whenever you get these documents in, scan them, name them, whatever you you are used to naming them. I like having the last name of the client and then the defendant\'s name and then whatever the document is, police report, right? I like to have that in the file so I can browse and I know exactly what I\'m getting when I open it. Usually scanners. Name is some weird thing, like zfv one to whatever. I don\'t want to ever see that in a file because I don\'t know what it is, and it takes so much longer to have to open it see what it is. Let\'s take that extra step and that extra moment to call it what you want to call it, and that way it\'s going to help so much more in the future. Do you guys use case management software? 38:06 So we\'re a smaller firm, and the number of cases we have, we don\'t require any type of case management software. So no, okay, but you have 38:13 an organization system on your on your hard drive, yes, yeah, whatever works for you. Make sure you\'re using it. If you\'re paying for software, use the software. All right? Lady Justice, Swift demand and dfvh complaints, how do you use your timelines to to be able to use the sword? 38:32 Okay? Life is so easy. You got this timeline from your client that you went over and you reviewed with them. You\'re now going to use that those facts in your demand, and then a properly put together, well written demand letter can be used to in your complaint as well. So it just goes hand in hand, like you do things right? The first way you get all the information with the with your client on their timeline, you flush out a lot of the stuff it goes into the demand and same thing, you\'ve identified the issues you you went above and beyond. You\'re a great paralegal, you know, you know the causes of action that\'s that\'s going to be in your demand letter. Identify the facts that support each one of those demand letters, and then you put it into the complaint if you ever reach that stage. So you know, work that you put up and you do upfront is going to pay off for you later on, and saves you a lot of time in personal 39:27 injury cases, you might learn demand, but you don\'t have all the medical records. That\'s not going to be a good demand. The insurance company isn\'t going to be able to assess what the damages are here, and if it\'s a policy limit demand, well, they\'re going to be able to truthfully and honestly say, well, we can\'t tender the policy because we don\'t have enough information. You don\'t want that. You want to be able to hold them to it. And if there\'s a policy that they need to be paying out, you need to make sure that you have that discovery done early and have all of the information in there so that we can send those demands complete and. And then that same thing happens for the complaints. You know, once you have the timeline, once you have your information, it\'s going to make it much easier, like Derek said, to to draft those complaints. 40:08 So in my office, when I get the demand or the complaint, the staff has already put together their final draft of what should be in there and what causes of action should be in there. And they\'ve used their common sense and their experience in putting all of that together. And all I need to do is usually two things. I put a deadline in there for the demand letter and then the amount that I\'m demanding to settle the case. And that\'s on the rare occasion where I need to, like, Hey, you forgot these two positive action I\'ll tell them to add it in, but it helps, and it\'s so important, when they take the initiative, they use common sense, they use their experience to put together something that is comprehensive and substantive, as opposed to like, Hey, I\'m just going to give bare bones and let my attorney figure it out. That\'s not really a great paralegal, in my my opinion. 40:59 Well, now pi is a little bit different, because we can have form complaints, right? You check boxes, you say where the incident happened, and that\'s pretty much it, and it goes out, and it\'s great. It\'s easy, but especially now during COVID. I don\'t know if you all have this experience, but we\'re getting demurred a lot because these people need to build, and so they come up with ways to build, and demurs is a great way to build. So we\'re getting these Demers, and usually they\'re just nonsensical, and you meet confer, or you do what you can, but I had filed a couple first amend complaints, and I looked at the intake, and it was a great intake, and I was able to figure out exactly what went on. I called my client to make sure that I had the story straight, and we were able to find file a pled complaint on a trip and fall at John Wayne Airport. And we avoided demur. They filed an answer. And now, you know, we\'re negotiating to see if we can\'t settle the case pre discovery. But you know, these are ways that if we do it right, and we set ourselves up early, it\'s going to make it that much easier for us to have the information we need to get the cases moving, 42:13 round one, sub zero and scorpion. You guys. You think these guys knew what they were doing, wearing masks and keeping six feet apart. Yeah, yeah, they\'re trying to stay alive round one. So, when can you propound discovery? You know? Well, it\'s right there in the code. You know, California COVID Civil Procedure 2030, is really the Bible for discovery. You really need to know the subsections of that, of that Civil Procedure Code, because it tells you what you can and can\'t do. 10 days after service summons, you can start preparing discovery. Is there a reason not to do that? There might be. But if you can start being on the offensive and use that sword, discovery can be a sword too. Use that sword and get those things out in pi. We send out form rocks, special, rogs and request for production. Derek talked about this earlier. Don\'t reinvent the wheel. You have these templates. You\'ve done these cases before. Most likely there\'s very few novelties in pi. And so what did you send out before? Make sure that if it\'s a trip and fall, it says trip and fall, not slip and fall, because it\'s not a slip and fall. If it\'s an auto case, make sure you\'re sending out auto request for production. Don\'t send premises request for productions on an auto case. It\'s happened, and I know we\'re all busy and exhausted, but again, it\'s about the details, and something so simple can make us look like we have no idea what we\'re doing, and it reflects poorly on us as the attorneys and at our office as a whole. And so we want to make sure that when we send these things out, they are correct. It\'s my job to look at it before it goes out, right? But I\'m not perfect either, and I miss things. So we need to make sure that we have a double set of checks and balances here, and it goes out right the first time, and if I miss it, then it\'s my fault too. But hopefully we don\'t have these situations because we took the time to make sure that the right form goes out, the right interrogatories go 44:14 up right. And one of the things that you\'re not you didn\'t see on here is the RFAs, which we\'ll address on the august 6 webinar. But my takeaway from this is take the time to review the form rocks and make sure everything on there, it\'s supposed to be checked off, and if it\'s not, take it away. Take it off. Your life is very easy when it comes to just taking a complaint or a template form template and just changing the names on there and the captions, but just take a moment and read through it. Make sure like everything you\'re asking for makes sense in this for this case at hand. So that\'s it. You know, for me, it\'s that simple. Of course, you\'ve got 1000 other things to do, and we recognize that. But 44:59 I. Yeah, and deadlines are important here, because, you know, when is your when do you want to send discovery out, put those internal deadlines or those ticklers, you know, inside of your of your calendaring system, make sure that you have the review dates service due dates. Because ultimately, if your attorney likes to look at things before they go out, like I do, and then Derek, does we want to, you know, a few days in advance, because we might be working on something else and we might not be able to turn it around in 24 hours. So find out what that deadline is, so that they go out on time and that we\'re proactive and not reactive. A good friend of ours, moussuki, who practices employment law, actually had a good tip when it comes to asking for production today, so many things are stored electronically, and defense companies and insurance companies and lawyers, they try and hide things often. I\'m not saying they all do, but it happens. And so we have some literature for you. I think it\'s part of the materials, if not call us or email us and we\'ll provide it to you. But what language you need to put it in there so you can so you can get the electronic data in native format? 46:14 I don\'t know why I\'m so disappointed. I expected nothing, and I got just that in abundance. So what happens 46:22 when you get your responses back from opposing counsel and they object to everything, and they don\'t respond to anything you knew that was coming. You\'ve been doing this for a while. You know that that they\'re not going to give you certain things. You know, don\'t get upset. Good evening. You know, you set up the meeting, confer letter you\'re going to do you\'re going to do it with authority. You\'re going to put everything in there, because you\'re that because that meeting confer letter again, if you do it right, and you do it up front, and you spend the time that motion compel 30 days later, or whatever it is, it\'s going to be that much easier for you to put the authority and the arguments in there. Okay, so don\'t get upset. You know that it was coming, that they\'re not going to give you chat, so you just deal with it, and you set up that meeting. Confer, yeah, calendar, 47:04 the deadlines. You know, I like to handle my meet and confers with with council on the phone first see what I can do. And so when do I need to, you know, have my meeting, confer by. When do I need to actually file? What\'s the hard deadline for the motion to compel? Are they? Are they agreeing to supplement? You know, make sure all these deadlines are on calendar and that they\'re in a time frame that works for you and your attorneys, but that what needs to get done can get done, forget the small stuff. Yeah, 47:35 I agree with that. I think you guys spend your time in when they give you discovery that\'s not to par, not to standard, not what you\'re expecting. Don\'t waste your time on the small stuff. There\'s another way for you to get that information later on, maybe it\'s through deposition, and that\'s something you make a note of, and you\'ll tell your attorney, but don\'t sweat over the small stuff. Just ask to the big stuff and focus your energy on that. 47:59 Go for the big ticket. If I\'m an apprentice case and they don\'t want to give me their sweep sheets because Costco or Walmart or whoever is saying that has proprietary information, well, do they have a point? You know, is there authority on that? Do I need to go before a judge and do an IDC in order to resolve that issue? Or should I be reasonable and, you know, understand that there are certain things that I don\'t get until and unless we either sign a confidentiality agreement or protective order or some kind of hybrid of both, whatever it might be. In some cases, it\'s standard. In some cases, we need to understand that that is something we\'re going to have to deal with in order for us to get the information we need for our clients. And that\'s okay. I\'m not opening my own Bottega Latina where I need to know what their procedures are. I don\'t need to know how you know what the what the technology is for these places. I just want the information so I can help my client. Now, it\'s standard, or is it? Yeah, 48:54 so when you when you get these protective orders and these confidentiality agreements, you know what\'s what\'s gonna set you apart from the good paralegal. The great paralegal is the one be like, Hey, this is a target protective order. Like, two years ago we had same case, similar case against target. Pull up the productive order. See red line, what\'s different for your attorney? You know, you\'re not required to do that, but it\'s just one step. Like, hey, I looked at this protective order that we recently got in our case, and one from two years ago. And here\'s a red line of all the things that are in there that\'s different and you might want to address, or you might it\'s not a big deal. And that\'s something that you can do for your your your attorney. That\'s one less thing off their plate, and it just makes you look so much better, and you deserve 100% of your bonus at the end of the year. Right? Luis, so you know, do your cursor review Red Line them and, you know, do work smarter, not harder? Yeah, yeah. 49:54 That\'s all we\'ve prepared for today. We wanted to leave some time for questions here. I think we have about nine more minutes. This next session will be a lot more diving into you know, once you\'re in litigation, responding to discovery and round two of discovery, but we just wanted to make sure that we don\'t lose out on the understanding of how important it is to set yourself up at the beginning of the case. So we hope it\'s been helpful for all of you to have a little bit of these insights. On this last slide, we\'ve put our contact information. I noticed, you know, Bob, Simon, Gary, Doric, all these guys are putting their Instagram handle. So I wanted to be kind of cool like them, and put mine too. You guys can either call me, email me, whatever, any information you need. We\'re here to help. 50:41 I put my phone number. That\'s my personal cell. Feel free to call, text, ask for stuff. I\'ll do my best to help you. Alright, I\'ll know very questions rose with Bay. That\'s you guys might have, and you want to chime in on how Sergio and I did the horrible in this presentation. And that\'s not how it\'s done at all at real law firms, they\'re 51:01 getting someone else. 51:07 No, you guys did great. Thank you so much. We have a couple questions, one directed specifically to Sergio. Daniel is asking, how do you get your hair still on point? 51:21 Well, Daniel, you\'ll see 51:23 I\'ll send you my Barber\'s number. That\'s the best I can answer that question. 51:29 We have another from Roy that says, do you call or send defendant a letter requesting information right after auto collision and before filing claim to try to get a statement from them 51:43 to the individual defendant. Yes, usually we don\'t. We try. We deal, usually, with the insurance company right away. We want to make sure that we get it out there and we have somebody who is going to be responsive to us on the other side, oftentimes, the individuals, you know, they\'re going to go through their insurance at some point anyway, so we usually deal directly with their insurance 52:07 company. What do you all do? Rose and Luis, 52:13 well, we do bad faith, so we don\'t normally send them directly like that. And then the last one, the sample forms, I believe calla will go ahead and send an email to everyone, but I\'ll confirm it\'s going to go out with materials. 52:36 I think that\'s it, yeah. 52:38 And if there\'s any other questions or any other documents that we could potentially provide, we\'ll be, we\'ll be doing a whole nother set for the second round of this. But if there\'s anything pre lit that you all might need or in the first round of lit discovery, please feel free to reach out to us. If we got it, we\'re more than happy to share it with you all you know, I think it\'s important for us to maintain the legitimacy of our practice, and so the more help that we can give to you know, our colleagues, the better it\'s going to be for Our our clients and our laws moving forward, absolutely great. Okay, 53:27 was there anything else y\'all wanted to share before we wrap up? 53:29 No, just, I think Sergio and I would like to thank everyone for this opportunity, presenting and spending your lunch time with us. So thank you very much. And hopefully you return for part two. 53:39 And since there will be a part two, if there\'s anything that you know, any questions you all have before, then also that you come up with in the next, you know, couple of weeks, make sure to email us and we can address them. They might, there might be some glaring issues that we forgot to mention today. So Don\'t, don\'t be shy. 54:00 Okay, thanks. Well, then that will conclude our session. I\'d like to thank our speakers for their participation and thank all of our registrants who attended today\'s program. Certificates of attendance and evaluation forms will be emailed to live attendees within 24 hours, and we ask that you take a few moments provide us the evaluation of today\'s program. I invite you to visit the Cala website for list of more upcoming programs and have a wonderful day. Thank you. Thanks everyone. Good day. Bye. Be safe. Bye.