Jurors in traditionally conservative St. Charles County, Missouri, awarded $1.5 million in a complex case about medical negligence. Why? Host Brendan Lupetin invites the winning trial team – Chris Wright and Anthony Laramore – to reveal their strategies. Chris and Anthony recount how they built the case, starting with crafting simple rules that resonated with jurors. One of them? “Surgeons must confirm before they cut.” Tune in for the other.

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1. The surgeon told the team’s client that she had cancer and the only option was a mastectomy. But the surgeon was either lying or too incompetent to realize that her diagnosis was inaccurate.
2. The defense attorney made a critical error in opening statement by framing the case as a one-issue trial: "If you believe our side, you have to find in our favor, but if you think we're lying and you believe them, you should find in their favor.”
3. One defense expert, a pathologist, had been sued by Vanderbilt University for stealing $250,000. In cross-examination, Anthony showed how she couldn’t be trusted to keep her word, a clean fit with the case theme.
4. The defense attorney inadvertently opened the door to discuss the defendant doctor's prior malpractice lawsuits by holding up four fingers and asking her to walk the jury through those four. Problem was – there were actually five prior cases.
5. During deliberations, when the jury asked if they were capped in what they could award, the defense attorney told the doctor she needed to give consent to settle. She refused and walked out of the courtroom.
6. The jury awarded $1.5 million ($500,000 for past non-economic damages and $1 million for future non-economic damages). It was $600,000 more than the attorneys requested.
7. A juror approached Chris after trial and told him she didn’t sign the verdict form – not because she didn’t vote for the plaintiff, but because they weren’t giving her enough money.

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Our bumper sticker was, surgeons must confirm before they cut. Surgeons must give patients accurate and complete information.

She told her client, you a hundred percent have cancer. Their only option is a mastectomy. Both of those things relies.

Welcome to Just Verdicts with your host, Brendan Lupin, a podcast dedicated to the pursuit of just verdicts for just cases. Join us for in-depth interviews and discussions of cutting edge trial strategies that will give you the keys to conquering the courtroom. Produced and powered by Law pods.

Welcome back to Just Verdicts. I'm your host, Brendan Lupin, and today happy to have with me attorneys Chris Wright and Anthony Larimore from Page Law down in St. Louis, Missouri. Joining me today about a great, interesting med mal verdict. You guys got about how long ago was it? A few months ago.

Yeah. November verdict was handed down Friday, November 23rd.

Yeah, the week before Thanksgiving.

Yeah, no, 21st

Right before Thanksgiving. I mean, that's always nice, right? Going into a holiday and get the W.

It was very nice, very surprising because that venue is a really tough, traditionally very conservative venue and Anthony and I have both tried cases there before and we weren't very lucky in those cases.

I think we had a perfect storm come together in this one. Oh, that's awesome. And I was actually trying a case that week as well, literally the same time you guys would've been. And mine I guess sort of fortunately settled right after openings. Whenever you settle it always sort of like sellers or buyers remorse. I'm not sure which one it is, but had a little bit of that until I remembered right before the break. I'm like, oh, this is sweet. The rest of my week is wide open now. So

You guys were in there fighting the real fight for that whole week. So anyway, before we get into the case, just love to hear a little bit about both of you guys. So page law, nice injury practice, med malpractice down in St. Louis. Chris, I know you from the A-T-L-M-G listserv that we're on. We've got some ties of people we're friends with here in Pittsburgh. But yeah, I mean, just tell me about your guys. How'd you guys get into medical negligence? And I know you do personal injury as well, but how'd you find your respective paths to this bizarre area of the law?

Yeah, so I'm going to intro right into that, but it was great because, so I was taught and trained by two guys, actually more than that, but the whole firm in Kansas City called Baris Freckleton, Jim Baris and Jim Freckleton trained me. I was a second year law student working with them. My very first major assignment was handling, putting together a PowerPoint presentation for a really significant surgical malpractice case actually in Carolina where a children's youth pastor at a church was in surgery getting a parotid gland tumor removed. And the North Carolina Hospital's surgical nurse was pregnant. And when they were about to fire the laser, when the doctor was going to fire the laser to remove the tumor, the pregnant nurse inadvertently bumped the laser and it actually, the laser severed his middle cerebral artery and he had a massive stroke. And so that was my first kind of taste of med mal was going there with them and putting together the PowerPoint and Jim Riggle and Jim Baris really taught and trained me how to become a med mal lawyer for the 7, 6, 7 years I was there.

And I just fell in love with it. I was never a science or math guy in high school or college poly-sci major. And Anthony can tell you that I'm not a very good math guy based on what happened in this case. But I just fell in love with it. I really loved Jim and Jim Freckleton. I respected them, loved them, and just loved the way they practice law. And they really taught and trained me. And then other guys in that practice like Steve Gorney, Paul Kavanaugh, Kirk Presley, Peter obs, I just learned to love med mal and was really interested in it. I loved the back and forth. I loved the research that we had as lawyers in Meel. We have to learn the medicine, although we don't ever want to fight the doctor on the medicine. Sometimes we got to know it and sometimes we know it better than them because the docs, they know a lot after being out 20 years out of medical school, but we can really hammer 'em by knowing the guidelines and the literature and all that.

And I just really enjoyed that aspect of it. And so quite frankly, Brendan, I've tried to get out of it over the years because Missouri is just a really bad place for those cases. We've got horrible non-economic damage caps on them. There are other laws in the state that just are really designed to prevent lawyers like me and Anthony filing med mouth suits against hospitals, nursing homes and doctors. And I tried to get out of it and God knows why I haven't been able to because people keep referring me cases and good cases. And so I just stuck with it and I love it and I love my clients generally. They're all good people who have just had really bad things happen to 'em and I just feel like they need representation and I just for the life of me can't get out of it. And so that's kind of how I got into it. And John Page took me on in March of 2020 when the pandemic was just starting because my former law partner Brian Milk, and we were dissolving our firm because he wanted to go in-house and do something with the St. Louis Police Officers Association. And so I've been here since March of 2020 and love it and I will take credit for getting Anthony in our firm. And I'm going to let Anthony then tell you about him

Before joining Page live. I'd known Chris for a really long time. We used to compare notes and talk about cases all the time. I think getting into Medow was just sort of an offshoot of my really strong desire to try cases and of course on the civil personal injury and that kind of big umbrella. I mean certainly here in Missouri, if you want to try personal injury cases, medical malpractice is where you want to go to. And so I certainly have had an opportunity to try many of them, but I absolutely love being in trial. And like Chris said, I mean these cases are very challenging from a trial lawyer's perspective because sometimes they can be so complicated. And I've always felt like that my skill probably from having a dad that was a pastor for 35 years, honestly, but one of my skills was taking things that seemed to be pretty complicated and trying to boil them down to very simple terms.

And so I felt like Meow is a good place to have that kind of thought process. But like Chris said, I mean I sort of got roped into it when a mother walked into my office 15 years ago and her son was a victim of suicide. And when we started looking into that case, he was in jail, but there was also a medical malpractice component to it. And when I started looking at that I thought, well, this just can't be right and someone needs to try to do something about it. And that was kind of the first case that involved medical malpractice that I took on. And then I was lucky enough to have a few great mentors and got to do some cases GI and misdiagnosed of heart attack and kind of got thrown into it very early in my career and just loved it and ate it up. But it certainly, it's a difficult area of practice, there's no doubt about that.

Anthony, with your dad being a pastor, two questions. One, it sounds like that had a positive influence on your interest to, I don't mean to simplify it so much as say public speak, but to kind of communicate messages to groups of people. Is that the case for you as a kid growing up,

Me and my wife met in her sophomore and my junior year of college. So we've been together for quite some time and my wife has always commented that I've never had any fear or trepidation about speaking in public, but that was because when I was a kid, I grew up in a small country church. We were up in front of the church all the time from the time we were little kids all the way up and until we were a teenager. So it's just having that experience speaking in front of groups never really gave me any fear. I think maybe it does some people. The ironic thing though is my dad used to preach and he would close his eyes when he would minister. And when I was a kid, I thought my dad was just the world's best multitasker. I thought he was praying and preaching at the same time. And I thought, man, that's really something that he can do that. But I didn't have, I guess the bravery to ask him until I was probably 16 or 17, why that he closes his eyes when he preached. And it was it because my dad was scared to death to talk in front of large groups of people. So kind of ironic.

Yeah,

No, absolutely.

Friend Anthony is not scared death to talk in front of large groups of people. He's really downplaying it because his experience with his pop clearly has driven him to do what he's doing. I will tell you in our case, because closing, we split up closing, I started and he did rebuttal to kind shove whatever the defense black hat said right up their keister without having somebody be able to respond to it. And he actually used a really great story from his experience and life experience with his dad and it really kind of fit. And Jim Reiner, the defense attorney, kind of walked right into it in what he was saying in his closing. But Anthony experience, Anthony just has so many good experiences and I'll call 'em what I call them with my pop and life lessons that we can use. And he uses 'em great. And he used it in our closing in our case, and it really, I think brought everything home with the jury. Anthony, you want to tell him about that?

Yeah, I mean, I really think that one of the hardest things that jurors have to contend with in medical cases, and you can certainly understand it, one is I think they go in generally with the attitude that they want to trust their doctors. And I'll be the first to tell you, I think most medical professionals are good people that are trying to do the right things. And my sister's a nurse practitioner for instance, and she just is a good-hearted person. But at the same time, whenever you go into a medical malpractice case, they have that in their mind as they want to trust their doctors generally. But then secondly, all the medicine is so confusing. And like I said, I feel like I sort of can sympathize because when I first started doing the medical malpractice, I was like, what does this mean? What does having to Google words all the time and things like that?

So it's just story that Chris was talking about. It was just something about when my dad told me when I was a kid. And now granted, we know most of this venue, most of the people on our jury are religious folks, they're churchgoing people. And you have to know that background. You've got to kind of, like I said, I would never do this if it wasn't authentically me. I think it's really important to be yourself. But I told a story about when I was a young man and my dad handed me the Bible and I said, well dad, some of this stuff is just so incredibly confusing. And he said, well, son, the way that you can filter through and make good sense of all this is just to remember the guidepost, and that's Jesus loves you do right? And when you mess up, fess up.

So I told him that and I said, in this case, it seems like there's so much confusion and you've heard all these doctors testify in this medicine, in these articles, you might wonder how can you make sense of all this? It's like you just have to remember the guidepost. And in our case, that guidepost was our rules. You got to confirm before you cut and things like that. And I thought it went pretty well. But then I just got to talk about how the doctor was a liar and it was terrible. Well, and I do think Chris kind of dovetailing on what you were talking about, I think his attorney so many times we get tunnel vision on our cases and we've come to the conclusion that there's something in the case that's super important and we fixate on it. And it's really easy to do that, especially when you're litigating a case for 3, 4, 5 years.

And boy, it's really nice to have a group of, we have a great group of attorneys at page law that we work with and that we can just sit down and say, Hey, is this as important as I think it is? But the nice thing is, is also having a humility just to understand that sometimes the thing that you think might be most important in your case, no one cares about. And being able to pivot like that, because I've certainly worked with many lawyers that just don't have that level of humility and think they know everything. And boy, a lot of times that equals a really bad result. So Chris is certainly, we've worked together several times. This was this the third case that we tried together, Chris

Or

The second?

Second Dan Mann, was it Dan

Mann? Yeah, we've tried two cases together now. Boy, I tell you, I think we got a great result in this case, but some attorney were to call me and say, Hey, should you take medical malpractice cases in St. Charles, Missouri? I'd probably say no, to be honest. I mean, you have so many hills to climb. And like Chris said, I mean I thought we did a really nice job of pushing the dominoes over, but the defense really set it up for us, I think in a lot of ways. And so

Brenda, let me give you some context. So we keep talking about St. Charles County and how tough a venue it is. So you asked at that one case we were talking about Blair County, right? St. Charles and Blair County are pretty similar, I would call it rural. Okay. Very conservative, very religious in terms of the folks that they, they're God-fearing folks and probably you have a good mix of Catholics, Baptist, Methodists, whatever. Same thing with St. Charles just to give you, when Republican presidential candidates come to Missouri, they come to one of three places, St. Charles County, green County, Cape Gerardo County and Boone or four places. That should tell you a little bit about what that venue is. And there aren't a lot of med mal verdicts, plaintiff's med mal verdicts that come out of that venue. I mean plaintiff's verdicts in general, but med mal verdicts in particular. And so it's a tough venue. So Anthony was right about that.

I mean, the takeaway too is you have to just be that much more judicious in the type of case that you would ever consider taking. I literally, before we got on, I am going to be filing a case in a very conservative county outside of Pittsburgh, about an hour and a half from here. I don't think I've ever heard of anybody getting a verdict there. I've lost a trial in this county before and this is to me a slam dunk case. But just for instance, the patient was older and I'm like that in and of itself might not be enough. So it's just crazy when you see how bad the care was admitted fault in the medical record and you're still thinking yourself, this is going to be a grind. We could lose this case even despite all this. But I liked the idea of us starting with the end in mind and we're talking about the rebuttal closing to start, but can one of you give us a little, because a really interesting case that you guys tried.

So can you summarize for the listeners what this case was about? And I'll also make the point as was the case with you guys, a totally agree with the team approach to trying cases in particular medical negligence cases, but all cases. And number two, I think like you guys did, I think there's a great benefit in having the one lawyer who's kind of worked the case up the whole way and the second trial lawyer coming in close in time, they have a different perspective, they have a fresh perspective, they're going to help you unsee some of the stuff that you're maybe fixated on that is counterproductive and help you see the big picture. I can think of so many instances in which either I jumped in late with my partner Greg or vice versa, and that same, and there was almost even arguments at times when you're like, dude, the case is about this. I'm telling you, you have to forget about that one thing that you keep fixating on. But it's so

Important we fixate on things that could you imagine, don't care. I've never heard that before.

We think we're right,

Particularly when you're, I was literally litigating that case for 10 years. 10 years. And Anthony really agree with you so wholeheartedly that with Brendan. So I'm super thankful for Anthony. So let me tell you the case. Our bumper sticker was, surgeons must confirm before they cut. Very simple, took a little while to get there, but Anthony was instrumental. And the other little, we do a round table with cases like this where we have all the attorneys and we almost do it like an old Philip Miller or Rodney Jew case planning session where we go around and we just spitball. And the first things we talk about are the rules, and we try to figure out the rules based on the facts. And then we come up with the bumper sticker after that. That was our bumper sticker. And our rules were surgeons must confirm the diagnosis before removing a patient's body part.

That's one. That was the one rule. And the second rule is surgeons must give patients accurate and complete information. Who's going to disagree with either of those? And I will tell you honestly, their expert surgeon, every one of their experts agreed with those in our crosses of them. We put our rules up, just two of them and said, do you agree with these? And everybody, including the defendant doctor, we'd had to preface it as a factual question, do you agree with these in general? Yes. And so those were the guideposts. And with those kind of rules in play, really the case was about a doctor who was very concerned that a mass above our patients left breast that was in her chest about right here was cancer based solely on what the x-rays and the imaging was showing. She got one biopsy and unfortunately that biopsy was inconclusive and the pathologists were telling her, you need to get more tissue to definitively diagnose with this thing is, and she unfortunately didn't get a second biopsy.

And she quite frankly concluded even before she had her informed consent meeting discussion on October 10th with our client that she was going to do a mastectomy. And then what she then tried to do once a lawsuit was filed is reverse engineer the wreck, telling what the records mean and what she was thinking. And oh no, I disclosed with her that I recommended both a mastectomy or a lumpectomy she could do either yet. There was no documentation of that anywhere in her record. What she said was discussed mastectomy, and that's it. And the day before, she had sent a letter to the primary care doctor who had referred the patient over. She dictated it the day before saying two things that were false, one that the pathologist had ruled out fibromatosis, which they hadn't. And secondly, that after discussion with an oncologist, the decision was made to do a mastectomy.

This was all before the day before she had ever even talked with the client about the surgical options. And also that same day she had the informed consent discussion. She actually, in her own handwriting, sent the scheduling sheet over to the hospital and it said, diagnosis left breast cancer. And so what we really showed was that this doctor had already made up her mind she was going to do a mastectomy when all of the experts including their own, and she admitted it said, imaging can make benign things look scary. Okay, benign things can look scary on imaging. And that's why the standard of care never allows you to diagnose something a mass based on imaging alone. You can't do it. And so the fact of the matter was she was relying on, she made a decent appearance, she didn't look like an ogre, she wasn't overbearing, obnoxious, arrogant, like a lot of doctors and surgeons come across sometimes she wasn't. She was very soft spoken.

I thought she would be very believable to a jury. And quite frankly, once we kind of got done showing all the inconsistencies with the documentation, and then once Anthony, Anthony Cross, they had actually three retained experts. We only had one. And I did that on purpose because I think we just got to do our cases quicker, simpler, more streamlined than they do because if we start going into second weeks in jury trials, it's almost always in Med Malin, Missouri, the okay. And so I had two breast surgeons, general surgeon, breast surgeon on the case, and ultimately I withdrew one so that we would only have one. And he was actually a local guy from across the river named Doug Ash, and he was just a phenomenal expert. But really then Anthony really killed their other, they had one general surgery breast surgeon expert from Kansas City who I think was not very good.

And then they also had two other experts. One was a radiologist who we did think made a good appearance who Anthony basically turned her kind of into our expert and actually proved what we were saying on a couple of issues. And then they had this pathologist expert from Nashville who was retired and among other things had been sued by Vanderbilt for basically stealing $250,000 from them because she didn't keep her word with her contract with them. And Anthony really cross examined them both and it's such great, totally different though, the radiologist, he was so nice to her, so got her to give us things that she probably didn't really want to give, but she did because she's honest. But then he flipped and we saw he was good cop Anthony with the radiologist, and then he was bad cop Anthony with the pathologist and shown a spotlight on her and her misdeeds in her relationship with Vanderbilt and that she couldn't be trusted to keep her word.

And it fit into our theme that they're asking you to trust her about what she said when she didn't document it. She said all these different things in other records, but they're asking you to trust her and they bring these people that aren't trustworthy to come and testify for them. It really was about a doctor who didn't confirm before she cut. And when that happens, Anthony said, if you mess up, you should fess up. And she just could not fess up and could not admit that she made a mistake and just wouldn't. And it was consistent with how they approached the whole case. She never once gave consent. Even during the course of the trial, when the jury came back in deliberations and asked the question of the jury or the court, are we capped in what we can award? The plaintiff and the defense attorney, we all heard him.

He went over to the doctor and said, that's not good. You need to come out and give me consent to settle this case. And she said, no, flat out no. And walked out of the courtroom. It's 30 minutes later, the jury came back, gave us 600,000 more than we asked for, and I think I firmly believe this. Juries only do that stuff like that when they are pissed. Okay? Who gives plaintiff's lawyers like me more than we asked for? And I think they did it because I don't think, don't they trusted her? I don't think they trusted the defense attorney. I don't think they trusted their experts. And Anthony really brought that home in the two experts crosses, and then in his rebuttal closing argument,

Crossing those experts was really a lot of fun. I got to tell you, first of all, I love crossing defense experts. It's one of my favorite things to do. But I do think, like Chris said, the case was about of course, not confirming a diagnosis but then also just overtly telling the patient, she absolutely has cancer. She told her client, you a hundred percent have cancer. Their only option is a mastectomy. Both of those things were lies. And when she uttered those words to our client, she knew she was lying. And to us that was unbelievable. She either knew she was lying or she was so incompetent that she didn't realize that she was giving her inaccurate information. Either one of those things is absolutely horrific. Then the defense set out in the case, and the defense attorney really did us a huge favor in opening statement.

He made the case a one issue case. He told the jury, if you believe our side, you have to find in our favor, but if you believe think we're lying and you believe them, you should find in their favor. And boy, you bet. We brought that up in closing because not only was there the lies in the medical record and then the letter that she wrote to the doctor, and then in her testimony they brought in an expert, the one expert that we were really hard on that had stolen a quarter of a million dollars from the university where she worked. And in closing, it's like these folks ask you to trust 'em. And they brought in someone who stole a quarter of a million dollars from Vanderbilt University and they're saying they're the side with integrity. That doesn't make sense. And in fact, Chris alluded to it earlier, Chris had made a math error when he filled out the jury verdict. In his part of the closing, he put the,

Yeah, I have a blow up. I have a blow up of the verdict, and I write in plaintiff. And then I wrote the numbers. We were only asking, we only submitted past noneconomic damages and future noneconomic because the medical bills for all of her reconstruction surgery, she got a bad infection following the mastectomy and had to have five reconstruction surgery. It was only like 25 grand. Medicaid paid 25

Grand. You're not going to put that in

No. So I'm adding the two line items and it was four 40 and four 50. So I was really wanting to ask for eight 90 and what I said was nine 90, and I go sit down and my client, who quite frankly we should talk about, Anthony did a great job putting her and her sister on the stand. That's another side, kudos to him. But Kimberly, who she may have some issues in terms of she's got bipolar disorder and there may be some issues of understanding that were clear in the case. And the jury picked up on and she kind of nudged me, poked me, and she said, Chris, your math's, not math,

You carried one too many ones.

And she goes, it adds up to eight 90, but you asked for nine 90. And I looked at Anthony, I said, Hey, you've got to bring that up. You've got to make fun of me in your part about that. And I got to tell you, dude, tell him Anthony. But it was perfect. It was just Anthony just handled it perfectly

When we got in, we were talking about the lies. I said just, I pointed to his, I left the big blowup up while I was talking and I said, folks, just like Chris writes math that just don't add up. And they all started laughing. In fact, one of the jurors asked us after the case if we had set that up intentionally. And I said, no, I wish we would have. It's just all about, I think the other part of trial is just being in the moment and paying attention to what's going on instead of worrying about, Hey, what's the next scripted thing that we need to do? I really think that it was the seven, we really identified seven big lies in the case. And even in addition to all the lies that were told in the record and to our clients, I really thought the jury needed to understand the manipulation that the defense had tried to pull on them during the trial.

And one was bringing that expert in that had no integrity or credibility at all. And I had a hard time understanding why you would doing that. But then you have the expert Chris talked about who was a radiologist, a very sweet lady, very nice. And the jury got to hear how she had goats and pigs and lived on a farm and she just came across a very genuine person. As we started walking through her testimony, it became clear to me that she had no idea what the defense was trying to use her testimony to do. And they were trying to use her testimony to say that our client lied about where the lump was and the lump was up here by her collarbone versus down here in the breast. And they were trying to say that they were trying to use her testimony to prove, but she didn't know that.

I mean, the expert didn't know that. And so at the end of her testimony, I'm like, are you aware that these folks are trying to use your testimony to say that our client was deceptive or lied about where the lump was? She said, no, I didn't know that. I was like, let me ask you. So we had this picture that our client had drawn a circle around where the lump was, and I said, if our client said that's where the lump was, is that true? And she goes, yeah, absolutely true. And I It's not deceptive. No, it's not deceptive. That's not even wrong. You actually agree with that. And so in closing, we got to bring, and so they tried to put this nice young doctor in front of you and they tricked her. They tricked her too. They brought her in here and had her give this testimony and then they tried to use her testimony to pull the wool over your eyes and she didn't even realize that she was complicit in their deception. And I thought that went over pretty well because the jury really liked her. You could tell they were all setting forward and taking notes. And I thought when we were able to turn her, that was a pivotal moment too. Yes,

Brenny, can you see this? Did I

Yeah. Yeah.

So this is the history and physical form that our client that the defendant filled out for our client the very first day she saw her, and this is the handwriting where, this is what the doctor wrote where the mass was, right? And they kept trying to tell our jury in us that actually it was in the breast. They kept saying it's in her breast tissue like here. And the radiologist actually was showing the image. She was trying to suggest why the imaging shows it's actually in the breast, the meat of the breast tissue. I don't know any whether to say it other than that. So Anthony, she was showing her exhibit of the actual imaging, and it was actually of the ultrasound imaging trying to show what's in the breast. Well down here, and it's not this, but down here at the bottom left of the screen on her image of the imaging, it showed a torso, a chest like this, and it had where the ultrasound probe was and it was like right here, same spot where this is.

But the defense didn't ask her about that, didn't pull it up, nothing in their direct of her. Anthony had the IT guy pull that little tiny torso up at the bottom left of her exhibit and blow it up and then put it right next to the one I just showed you. And you could see the defense lawyers were like, they're like doing this. And Anthony said, so you agree that where the probe was for this image showing the lump is exactly where our client told Dr. Yeager it was, and Dr. Yeager. And she goes, oh yeah, that's the same place. And that completely destroyed. They were trying to put fear in the jury that this was breast cancer, right? And it's in the breast, it's not, it's in the breast tissue. And that makes it very scary, okay, this is a very bad thing. And Anthony got that very nice, very credible defense expert to basically show the Dr. Yeager and her other expert lying about that it was in the breast tissue. And so I wish you could have seen how he handled her versus the other gal, the older retired pathologist that stole 250 grand. It was just

Masterful. What I'm hearing from you guys, it goes back to a point you made at the very beginning, Chris, about in med mal you have to learn the medicine inside and out. And sometimes there can be a curse of knowledge because we forget that the jury does not have that level of analogy get into the weeds and it can cause problems for the case. And you said, despite the fact that you've got to learn the medicine inside and out, that generally speaking, as a rule of thumb, you typically don't want to fight the doctor on the medicine and everything you guys are talking about, obviously it all has to do with the medical aspect of this case, but it's bigger picture issues. It's telling the truth, it's misrepresenting, it's inaccuracies, but that seemed to be what the overall, you had your rules, you had your bumper sticker, people get it. But probably what moves the needle the most are, we'll call it the medicine adjacent issues, the bigger picture issues in the

Case for sure. I'll tell you Anthony, we did not understand why because the pathology expert, they had come in the radiology expert, they were basically saying the same things that the treating pathologist and radiologists were saying in the records. And so Anthony was like, why are they calling these two? What are they doing? And ultimately what they did is what they really tried to do with the pathologist was their breast surgeon expert would not admit or say, and that's what they were wanting her to say, was that she was going to need a mastectomy anyway, even if they removed, tried a lumpectomy because it was so large and where it was located, they were going to have to ultimately do a mastectomy. That's what they wanted their breast surgeon to say. And she wouldn't say it. She couldn't say it. She actually said that in her deposition.

Oh no, I think either one would've been appropriate, and I can't say if she would've needed a mastectomy anyway, if a lumpectomy had only been done. And our expert said clearly no. And he explained it actually. He did an ease on Drew why a mastectomy was actually the worst possible approach to try and remove the lump because you couldn't get clear margins by doing a mastectomy. And that the only way to really get clear margins of this lump is by doing a lumpectomy where a lumpectomy, you're basically going at it like a target, whereas a mastectomy, you're removing the breast and then coming at it from the side. And he actually drew that out, explained it to the jury, and their expert would not go as far as they wanted her to go. And so they got this pathologist to do it who had never done a surgery, but like this. But she said, because I consult with breast surgeons, I can say that a mastectomy would've been needed.

Yeah, pathologists are often called on to do that.

Even though the radiologist, Anthony got the radiologist to admit, I would never tell a surgeon what to do or what's going to work, even though she had general surgery residency experience, she said, I would never tell a surgeon surgery to do or what surgery's going to work or not work. That's their decision. And so I think they brought the pathologist because she was willing to go and say that. And they had nobody else willing to say that

By the time we dropped the credibility bomb about her stealing money from a university and having, and her lying about it initially, because the way we approached that was to build it up to her crescendo a little bit. And so I went over and as I started, I said, doctor, thanks for your time today. You understand I have to ask you some difficult questions. And so I walked over by the jury, so she had to look at all of them and I said, do you want to tell all these people why you were fired by Vanderbilt University? And she said, we had a disagreement. And I said, doctor, yeah, listen, I'm like, either you're going to tell 'em or I'm going to have to tell 'em. I was like, how do you want this to go? And she goes, they said something about me taking business and money.

And I said, I'm like, doctor, do I have to get the court records out before you'll level with these people and tell 'em what happened? Not only was she, did she steal, she then used the court process. She went back and sued the university for discrimination. And that case was dismissed on summary judgment. And so it just made her look very bad. And so we went through all of the testimony, but then one of the guys, I started trying criminal cases when I first came out of law school and there was a guy here on St. Louis, St. Brad Kessler, that was I second chaired five murder cases with him when I was in a law school. And he always told me, he said, if someone uses an exhibit, he said, you figure out every way that you could use that exhibit against him. And as I was sitting there during the defense attorney had brought in this doctor's book that she wrote on pathology and about specifically breast cancer pathology and fibromatosis.

It actually had two chapters on fibromatosis. And so while they were finishing the direct, I asked his associate, I'm like, Hey, let me see that book. So I got the book and I had not seen the book before the trial, but I just looked in the index to see if there was mastectomy or breast removal surge or anything in the book. And so we got, part of her cross was me taking that book marking the exhibit, and I handed it to her and I say, show me one place in this book that you wrote that it says you treat fiber mitosis with a mastectomy. And she couldn't show it because it wasn't there because it isn't true. But I thought it was a very, and I even opened to the chapters and I said, you wrote two whole chapters on fibromatosis in this book and not one mention that you do mastectomy.

And she had to admit that was the case. But by that time, we had already taken her credibility down to zero. And I think that was just hitting the point home. I think, I'm sorry, I'm at home today, Brenda, because we had a babysitter cancel. So if that's all the noise and kids and dogs, but at the same, but once we destroyed her credibility, the jury just disregarded I think everything that she said. But even when you have those credibility issues, you still have to push home your case. And one thing I thought the book into all of that when Krista is closed was bringing it all back to our expert, Dr. Ash and everything that he said, and what a wonderfully credible and just nice man that he was. And you put together that dichotomy and all of a sudden the jury is on our side when normally maybe they wouldn't be. So it was just a nice way that it all played out.

They really, Brendan and we don't want 'em, Jim Reinert and Jeff Atkinson who defended this case, they are, think of the top med mal defense attorneys you run into all the time in Pittsburgh. That's these guys. They defend and try so many cases, quite frankly, I just think they're used to winning and they're really good. And I've tried four cases, med mal cases against Jim Reiner. This is my first win and they're really good. But they really fed into this really our theme because they were attacking our expert. For example, Doug Ash, he is one of the best experts I've ever seen, and he does 50 50 plaintiff defense in terms of reviewing cases, 60 40 defense in terms of testimony at trial 60 40 on behalf of plaintiff when it comes to depo testimony. And that all kind of makes sense if you really how these cases work.

And he also, significant part of his practice of general surgery is breast surgery. It's actually very similar to the defendants, but they tried to suggest right away in their opening that Dr. Ash was not a breast surgeon and I showed him his cv. He told him that a large percentage of his practice is breast surgery. He's one of the only two general surgeons in Illinois on his side of the river that actually does biopsies. That's a surgeon because most of the time on the Missouri side, radiologists do the biopsies, but he's one of two surgeons in that whole community where he practices where he is doing bio. And he's been doing that certified since 1995. But that was the first thing. One of the first things they said about him in their opening was he's not a breast surgeon. We're lying about his expertise. And I asked their breast surgeon on her cross, what were you doing in 1995, doctor?

She was a sophomore in high school. And I said, so when you're a sophomore in high school, Dr. Ash was certified as a breast biopsy provider and has been doing it since then. I said, is there any doubt that you were here for his testimony that he's a breast surgeon as part of it? She fought me on it. She would not agree to it. I think it's those kinds of things that added up to you can't trust them. And they didn't have to lie about, they didn't have to do that. They didn't do that to do any of that. They could have attacked them on other ways and they didn't. And then there was the issue of, so the doctor, the defendant doctor, she'd been sued five times in addition to our case for medical malpractice. And there's some law in Missouri that says if you put the defendant on and ask them expert opinions as opposed to just ask them what happened, what'd you do?

That type of stuff. And it's a very recent case, and it was actually, Jim Reinert was on the other side of it where the court said, when you do that, you are opening that expert up or that defendant up to all the ways that plaintiff lawyers like Anthony and I can cross examinee them, bias, interest, credibility, all that stuff. And so they filed the motion eliminate to keep us from asking that stuff of her and the judge really surprisingly, because we're always so used to getting these kinds of rulings going against us in medow cases because they just almost always give the benefit of the doubt to the defendants even when the case law is clear that they shouldn't. The judge actually, we argued it on a Thursday before trial and he said, listen, I'm going to read the cases. They submitted their cases to him by a week.

Anthony submitted our cases to him and by gosh, we showed up Monday morning expecting we had already prepared. We weren't even sure what we're going to do to be honest with you on that issue if they were, but if they allowed us to. But we thought for sure he was going to say, you can't do it. Monday morning we go on the record and he says, listen, my gut says I shouldn't want to do it because it's prejudicial to the defendant. But Jim, as soon as you ask her an opinion expert opinion, I think you open it up. And so he denied their motion to eliminate, but as we're walking back to the tables, I said, so what are you going to do? He said, I'm going to ask her the question I got to ask her. He has to have her say, I met the standard of care.

I didn't breach the standard. You don't. I had plenty of cases where the experts, their retained experts said that and the doctor just said, I did what I felt was appropriate. That's not an expert opinion. He could have done that, but he didn't. And it's because I think she was just so heavily invested and involved and just could not admit that she did anything wrong. She had to say, I didn't breach the standard of care and by God he did. We were, what are we going to do? What are we going to do? And what's he going to do? And on cross on her direct, he actually, he opened the door to it. He raised his four fingers up and said, now doctor, it's true. You've actually unfortunately been sued four other times for medical malpractice and besides this case, and can you walk the jury through those cases, what happened?

Nothing happened. They either got dismissed or one of them was tried to a defense verdict, but we had done some digging and actually found there were five cases, not four. And she also had not disclosed that case in her interrogatory answers. And so as soon as he held up four fingers and said that, I remember nudging Anthony and saying, did he really just say four? He didn't say five, right? Just said four. And so I wasn't going to go into the particulars of the cases. I just hammered her on the fact she just, not only did she lie in her interrogatory answers, I said, you just lied to the jury under oath right here with Mr. Reiner. You told them you only had four cases, and in fact the most recent case you've been sued on for medical malpractice was this one in the city of St. Louis that you didn't tell us about. And all she kept doing was say, we looked it up. We looked it up, we looked them up. You can look up Missouri and find out how many times somebody's been sued. And I said, doctor, I'm not talking about you looking up. I'm saying times where you've been sued for medical malpractice and you just told this jury you've only been sued four times when in fact you've been sued five times. And it's the most recent case.

And no one believes that. At least I don't think anyone on a normal jury would believe that you could be sued and not remember. I just have a hard time thinking that people will believe that. And I don't know, it would be an interesting question for the people on the jury. It's like how big of a deal would've that have been standing alone if we didn't have all of these other lies that were told? But it certainly, because even by that time, I think the jury was really questioning her credibility with the issues with the letter and the medical records and her lawyers telling them, don't believe what she wrote in the record, believe what she says here in the trial, which was just like, boy. So we did have a lot of good lies

That, yeah, I think in that scenario, it's interesting in the sense if most of the prior instances that had been dismissed or it was the defense verdict, could that come off as just, oh, here's another doctor getting frivolously sued too much. On the other hand, one of the biggest things that juries are always asking about in focus groups and so forth are prior acts, prior instances, whether it's on the defense or the plaintiff, all that kind of stuff. And in your situation, I just think the killer then is like, then why are you hiding the fifth? And to Anthony's point, no doc, nobody's going to believe a doctor doesn't remember where you get sued that much. You can't even keep track of it anymore. It definitely does not. That's what we phrasing and look good. I think we're

All taught to try the lie. I think another guy that had been a mentor to me for years was a guy in St. Louis, St. Matt Padberg, and he used to say, try the lie if it matters. And what he meant by that was if it's a mistake that you could wrap your head around like a normal person making, hey, you checked the wrong box in a form or something, that's one thing. But if it's something someone should remember and they're trying to hide the ball because they want to make themselves look better, which is certainly the lawsuit thing seemed to do, then I think you just hammer 'em. And Chris did a great job doing that. We were both, man, how many gifts are they going to give us here? But at the same time, we got a lot of it, but I thought we did an effective job of really driving a truck through it too.

Brendan, Brendan, you brought up the really, the biggest concern I had was if he doesn't bring it up in direct, how was I going to bring it up and cross the prior lawsuits so that it didn't look like what you said? I was concerned the jury would make it look like poor Dr. Jaeger. She's been sued all these times that from these frivolous lawsuits and these dang plaintiffs, and they didn't go anywhere. Honestly, I wasn't sure if I was going to even ask her about those things because I was concerned about that. And I think we're right to be concerned about that because you know how it is the lawsuit, lottery thoughts and these poor doctors and my doctors, they get sued too much from frivolous stuff. They're going to leave and I'm not going to have a doctor. So quite honestly, until he was done, until he held up his fingers and said four and went into it, I was not going to really ask her about any of those lawsuits because I just didn't know how it would come off to a jury.

And I thought we had 'em by that point. I thought we had a majority of the jurors with us, and I didn't want to then I didn't want to go on code and be the plaintiff lawyer who's hammering her over these frivolous lawsuits that didn't go anywhere. And once he did that, I didn't make it about the lawsuits. I made it about that. She just lied about the lawsuits. And in fact, the lawsuit she lied about was actually one where the lawyers who were sitting at that table, who were defendant her in this case actually represented her and filed. And I had the answer. I had both the petition and the answer. And when she kept, we looked it up, we looked it up, she's like blaming it on the lawyers. I said, no, they're not the ones on the stand who just told this jury, you only have been sued four times.

You're the one under oath. And I will tell you this, you asked for tidbits or nuggets. Anthony gave me this nugget in trial, and I actually used it with the defendant doctor because she was so soft spoken, really so nice looking the way he approached the pathologist. He just, right off the bat, he's asked her, you understand, you're here being an expert, you're giving expert testimony. You understand that I representing Ms. Kennedy, I have to ask you very tough questions. And he basically asked her for permission to do his job, to ask her tough questions. And what's she going to say? No, she said yes. And so I stole that with Dr. Yeager because she was very soft-spoken in her direct. I was scared to death the whole trial that if, and I'm a pretty bulldog dude, and if I did that with her, it was going to be a mistake.

So that was the first thing I asked her is I said, I don't want to be here asking you these questions, but we are. I have to represent Ms. Kennedy. You understand that you have put your credibility squarely at issue by what you're saying happened in this visit when it's not documented. So you understand that your credibility is clearly at issue or yes, I have to ask you really hard, tough questions and I will do my best to do them respectfully. Do I have your permission to ask you those tough questions today? And she looked at the jury and said, yes. And I will tell you the one thing that Jim Reinert, and he's a great lawyer, said to me during deliberations when we were talking, he said What Anthony did with her and what I did with his doctor doing that at the outset was genius.

That was the quote. That's what Jim Reinert said. That was genius because you didn't look like an asshole who was just attacking her. You look like you didn't want to be doing it, but you just have to do it. It's your job. And I said, Jim, Anthony gave me that. I've been doing this, watching really good lawyers for 28 years. And that was the first time I'd ever seen that. And I was like, holy crap, that worked. I'm going to try that with Yeager. And it was great. So that's a nugget that I would really suggest to lawyers try and use is it's like what we do with jurors in voir dire, right? We ask them for permission for certain things, like when we don't want our client there, every day we tell 'em, we tell 'em they're not going to be there, and do we have your permission to do that? Or is anybody going to hold that against her? So now what's the witness going to do when you ask them permission to just do your job and represent your client and ask you tough questions? Are they going to say, no, no, you can't do that?

Yeah, no, I think really classy approach. And I think that's something I think sometimes think maybe we've inadvertently done that in a couple of situations, but you should do that always because that is just such a better natural start, I think normalizes the situation and helps the jury understand that, look, you're doing your job and part of your job is zealously advocating and maybe being a little tough on this witness doing it for your client. Now, we've covered a lot of territory. I'd like to wrap up by you guys just telling me, how did you approach, you're given all these gifts, A lot of it just seems like a situation where this doctor just could not accept, couldn't fess up, and just leads to all of these different gifts for you guys and landmines for the defense. How did you approach presenting your client and her story juxtaposed with all of this in a way that was going to resonate or not backfire in some sense?

And Brendan, I'll tell you the story here, and like I said, I apologize if there's any background noise from all these little kids, but I took the same approach with our client. Our client had some mental health issues, had some communication issues, had a stutter that was pretty serious, especially when she would get nervous. Our client was scared to death to get up in front of a group of people and talk about this. And even in the best case scenario, you can't imagine anyone wanting to get up and talk about this and having to show pictures of mutilated breasts and stuff like that to a jury, to a bunch of people that they don't know. And so we really had to do a lot of work with her. It was just hours of us talking to her and making sure that she was ready to go.

But I, and then we also had her sister that was part of the treatment and also helps her navigate through a lot of things in her life. Not really, she wasn't formally appointed as a caretaker or anything, but her sister helps her do a lot of things. So we had her sister testify first and we had her explain to the jury the difficulties that her sister, that our client has with communication and things like that. Also how that we were really worried about our client getting on the stand and getting really angry because she had before with us in preparation. And so I tried to diffuse that with her sister. I said, she obviously very upset about this. I said, is she angry? Yeah, she's angry. Tell me why she's angry. This a little bit of life that she thought she had romantically and privately.

Now she thinks that's completely gone. Someone who's had all of these difficulties already because of the conditions she already did have. Now she feels, and what she said on the stand was, it makes me feel like a monster. And when we were in going through and trying to figure out like, Hey, how to tell her real story to the jury, I think, and I think this isn't anything that you all haven't heard before, but it's telling about the pain and suffering through stories. And I always like to have the client get a story from each different aspect of life that I think people on the jury will relate to. One from private at home, one thing that happened at work, one thing that happened around the holidays and then one thing that's a more intimate thing with an intimate relationship. And her stories were just gut wrenching.

And she had this one instance where she was working at the baseball stadium downtown and the prosthetic breasts that she had to wear after all this, it fell out onto the grill in front of her fellow employees and her talking about how embarrassing that was. And she had an issue at home where her dog got ahold of it and ran out the door in front of all of her neighbors. And just this level of embarrassment and fear about going out in the world. And the jury could really feel it and you could tell, and thing is one of the reasons we had such a great result is Chris did such a wonderful job of Ward Dyer. We ended up with seven women on the jury. And I felt all of them, you could just tell were just related to her so much. And those issues that we thought were going to be big issues like her stutter and her mental health issues, they endeared her to the jury.

Those folks thought that this woman, one of the people even said it during voir dire, they said, I can't believe how courageous that this lady is to come in here and do this. And that's what we ended the whole trial with. Was the word courage written up on the screen really big? I think the jury really, and then again, the defense stepped in it. Man, all this is going on. And I think anybody who was watching knew these folks really seemed to be relating to this lady very well. And then the defense attorney got up and attacked her and just was not reading the room. And something that, this is kind of a little off topic, but something that I've never had happen before in a trial. And it was the defense attorney got up and tried to insinuate her sister was lying because at one point in time they had shared a checking account.

She was helping her pay her bills and learn how to do things, manage money because she does have mental health issues. They don't have one anymore and didn't for five years before the trial, it made me upset. And I did something that more out of anger I think, than real thought process because I always believed that if you're going to call someone a liar, just call 'em a liar and don't beat around the bush. Be a man and stand up and say what you think. So I got up and redirect and our client's sister, I said, did you understand what he was just trying to insinuate about you? And she goes, no. And I go, he was just trying to say that you're doing this for money. Why did you hear when he asked you about your checking account and everything, that's why he was doing that. He was trying to get these folks to believe you're doing this for money. Do you stand to gain anything financially from this? And she said, no. The defense attorney got up and apologized to her

In his redirect.

That's what he did. He got up, he got up and apologized. He said, I'm so sorry. That wasn't my intention. It was, but he said it wasn't his intention. I've never seen that happen, but

Which only highlights it, which only highlights it again. And Anthony, I think said something about that in his rebuttal cross.

But here's the thing that I've been telling people, and like I said, I didn't make this. Some of this is from the edge when trial by human, it's just like things that you wrap your arms around, but the importance of having your clients write this stuff down. And so we always have the clients fill out a form before they're about to testify where they write down what are the 10 ways that your life has changed? Give us specific stories that illustrated what are the five fundamental truths of this case. And even with someone that was challenging and that had some mental health issues, what gets during cross-examination is they write it down. Something happens in their brain that I'm not smart enough to explain, but something happens. And even our client in this case when in cross-examination when she was testifying, when she felt stressed and you could tell they were getting on her nerves a little bit, she reverted back to the things that she wrote down before the trial and have him write it down more than once.

I had to write it down a couple of different times. It just commits it. And then when the nerves come, it's okay. And I don't know, it's almost like a miraculous thing because so Chris, I always have those things. I have those stories so I don't forget to ask about them in direct. And I even showed one of our paralegals and I was like, she said it almost word for word as she had written it down while she was on the stand. And I just think it's real powerful because one, it's in their own words. So you're, we're never telling people what to say, but two in that cross-examination where they're in the arena with the other attorney and you have to step out of the way and can no longer be the protector or they've got that shield if they've gone through that process. I've just noticed it really over the years, the last 16 years of trying cases. I've noticed that helps a lot. That's

Awesome. So you guys have a set form that then you have them homework, you got to sit down.

Yeah, Anthony, you

Got to write out your, call it homework too. That's great.

It's Anthony's form. It's great. And Anthony, thank God for him because he spent literally what, probably seven hours with those two witnesses for maybe a grand. I think our client was on the stand direct 15 minutes maybe, and her sister was on maybe 20, but we were very fortunate. A lot of times you'll have these, he said, she said cases about what's not in the records, and it's only doctor versus our client. Kimberly, thankfully, her sister was actually at the informed consent meeting that happened three days before the surgery and she was just a really credible person. Okay, she's a paral. She's been a paralegal at different law firms. She's a paralegal at a family law firm in Texas right now. Her husband is a US Air Force person, and she just was, and Anthony just did a great job preparing them. Short, simple, sweet in their own words, and they just looked credible.

It didn't look rehearsed when they were being crossed. They were just very short, simple, answered the questions. Our client did not agree. We were both very concerned that Kim would get upset and angry and she didn't. And I think the jury really did connect with her because I will tell you, the Friday night after the jury verdict was read, and I'm going out to my car in the parking garage, one of the jurors that we were extremely concerned about, and we could not get her off the jury, she and her husband own a physician staffing company. Okay? So they're putting physicians in employment places, but she said they didn't have any clients here in town. They were all out of St. Charles. So it wasn't involving, but I just don't believe that I've had people on there before that actually were in a case with Jim Reiner that actually were rats and the husband in a similar situation was a rat.

And we could not get her to give us the language to get her off for cause and we did not want to use a peremptory on her because there were people that were actually clearly much worse. She came pulling up, she's in her maybe late thirties, early forties. I'm loading stuff in the car. She comes pulling up in a brand new Mercedes G wagon, not what I was expecting from a strut county juror. And she comes pulling up, pulls over to me, stops, rolls down her window and says, Mr. Wright, you are going to help her with this money. And I'm like, do you mean investing it, putting it into a structure? She said, absolutely. She goes, because it's clear she needs help. And so we didn't bring up a bunch of her mental health issues. We presented her and they saw that she needed a little help.

And then she then goes on. And so we had 10 signatures out of 12 on the verdict form she offered without me even saying anything. I just said, I really appreciate what you guys did. And she goes, I'm going to tell you I didn't sign the verdict form, but the only reason I didn't sign it was because if you had only had eight, I would've signed it to give you nine because that's what we needed to get a verdict. And she said also the other juror who didn't sign it, didn't sign it, not because she didn't vote for the plaintiff. She thought we weren't giving plaintiff enough money.

I love that. I love

That. That told me that Anthony, what he did with Virginia and our client really resonated with the jury if it resonated with this person who owns a physician staffing company. And that was the whole reason why I tried to get her off. I said, isn't this going to be difficult for you to explain to your clients potentially if you are signing a jury form, awarding a verdict against a defendant doctor? And Ver was like, oh, no, I'd have no problem. I didn't ask her why she didn't sign it, but I knew why she didn't sign it. One, she didn't have to, and two, she didn't want her name on a verdict, a 1.5 million verdict hammering a surgical group. But I just think that told me that what Anthony did with our client and sister was really, and how this goes to get a verdict in a MEbA case, whether it's in a great venue, what we think for us are bad. A lot of things have to come together for us to get that. And I really do think we had two really good folks, Virginia and Kimberly and Anthony really did a real good job putting them in front of the jury. So

Amazing. And yeah, we'll wrap with you guys. You asked for what, eight 50? Eight 90?

Yep. I asked for eight 90 on the board. I verbally asked for nine 90, and so they gave us 1.5 million, 500,000 for past non-economic damages and a million for future non-economic damages.

Amazing. Your client must have been thrilled.

Anthony,

Was she happy? She hugged me and was sobbing uncontrollably. So yeah, we had a group of paralegals there too that were just really, so I can't tell you of the great team environment we had there, and we had a group of paralegals that were just bawling. And it was so nice to see something like that because they all really cared about our client and understand the difficulties that she had and stuff even outside of this case was just tremendous. And so, yeah, it was just a tremendous experience to be a part of.

Amazing, awesome guys. Very great story, great outcome. And you guys shared a ton of really, really thoughtful insight and advice on things that worked in that case that I'm definitely going to apply in my next trial. So thank you for that. That's Chris Wright and Anthony Larimore from Page Law down in St. Louis, Missouri. Find these guys you ever any great lawyers in Missouri and hit them up and pick their brains because clearly you guys, you have a lot of great stuff to share. So thank you both for doing this.

Thanks, Brendan.

Thank you, Brendan.

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