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Today the Zinda Law Group team discusses how to evaluate a case. A lot of the time, it’s the case you don’t take, that can make or break your practice. Sharing their thoughts and experience is Jack’s law partner, Joe Caputo, one of the top litigators at the firm, Neil Solomon, and all-star, Christina Hagen, who litigates cases in Colorado and Texas.
Key takeaways:
How to evaluate a case
Sorting fact from fiction
Determine source of recovery
Deciding whether to take the case
The Effective Lawyer teaches ambitious trial lawyers how to grow their skills and create a prosperous law firm. Using lessons learned by accomplished attorneys from around the country, we discuss lessons learned through their trials and tribulations. Our discussions cover a vast range of topics sought out by attorneys looking for advice, from depositions to how to market your law firm.
The show is hosted by Jack Zinda, Founder and Senior Trial Lawyer at Zinda Law Group. In less than 15 years, Jack and his team have grown Zinda Law Group from 3 attorneys to over 30, spanning several states and handling a variety of personal injury cases from gas explosions to truck accidents.
Jack and his guests share their knowledge and skills that they’ve acquired through the process of building one of the most successful plaintiff’s law firms in the country.
In each show we cover a new topic that an ambitious attorney would want to better understand, while providing practical skills to improve their legal practice.
For more information, visit https://www.zdfirm.com/the-effective-lawyer
00:03
Speaker 1
Welcome to the Effective Lawyer, a podcast for ambitious attorneys who want to improve their practice. My name is Jack Zinda, and I'll be your host. Hey, everyone, this is Jack Zinda from the Effective Lawyer podcast. And today we're going to be talking about how. How to evaluate a case. A lot of times it's not the case you take, but it's the case you say no to that can make or break your practice. And as always, I've got with me my three friends. Joe Caputo, a partner at my firm, Zynda Law Group, Neil Solomon, one of the top litigators at the firm, and one of our all stars, Chrissy Hagan, who litigates cases in Colorado and Texas. Hey, guys.
00:48
Speaker 2
Hey, Jack.
00:49
Speaker 3
Hey, everybody.
00:50
Speaker 4
Hi.
00:52
Speaker 1
So talking about evaluating a case and deciding whether or not to take a case, I think that's a skill that a lot of attorneys, it takes a long time to develop. And I know early in my career I spent a lot of time working on cases that I ended up not being able to help the client and not really helping my practice because they weren't financially viable, which isn't a terrible place to be. You didn't want to be able to help the client or be able to make money for your practice. Both of those overlap in what we do, which is contingency fee work. So, you know, the thing that I try to think about when evaluating a case are what are the three or four pillars that help me decide if it's a good case worth taking? I think of liability, damages.
01:43
Speaker 1
Is there a source of recovery? And what do I think about the client? You know, when we talk about liability, who's at fault and why, and damages, are they hurt enough to warrant pursuing a claim? So first off, what stage of the case do you guys evaluate whether or not a case makes sense and how far to take it?
02:07
Speaker 2
Joe, it's the toughest part of what we do, right? Because we have to, in a short snippet of finding out information on liability, damages and source of recovery and a little bit about our client, decide in the moment whether or not we think it's a case worth pursuing. Because we would never give advice to a client, hey, let's have you not be represented, not conduct an investigation, have the insurance company talk to you for six months, and we'll revisit once you're kind of done with your treatment. And we know where things stand. And so I think it's this constant push pull. But when I am hearing facts of a case, the first thing that I'M thinking about is the practical effect, which is this somebody that I am proud to represent, that I feel confident in spending nights and weekends representing them?
03:08
Speaker 2
And are we going to be able to make that meaningful impact in their life? And that doesn't mean that there are small cases that we'll handle, and that doesn't mean that. That it has to be a big case to handle it. But is it going to be worth their while to have us go through our process to try to help them? And so, in evaluating the facts and the circumstances and the damages and the source of recovery, I think it's just as important that you think about from the client's perspective, is this somebody that we want to be attached to. And we didn't always have the luxury of kind of picking and choosing our clients, but I. I think that we have that luxury currently. And then also is the impact that we're going to make worthwhile.
03:54
Speaker 2
And so you have a small time to evaluate whether it's a good case or a bad. And so you kind of have to do this analysis of what's the best case scenario based on what I know, and if it is best case scenario, can we help? And then very quickly thereafter, as quickly as you can so you don't waste time or money, Verify the facts that are going to help either solidify your opinion or move you away from that initial opinion and put the client in a position where they're a little bit more informed about why, but not drag it out so that you don't harm the client and that you don't waste your time and efforts trying to help.
04:39
Speaker 1
Yeah, I think that's a great point. One thing that I like to do, and I think most of the attorneys at our firm do, is at the beginning, when you're meeting with the client, have them tell you everything they know about what happened to them and every person involved and every witness and try to think through, does it make sense? You know, occasionally you'll get a fantastic set of facts that actually are true. But a lot of times, if the facts the potential client has given you are very fantastical, odds are it's not exactly the way they laid it out. Chrissy, what are your thoughts?
05:14
Speaker 4
Yeah, I agree. I didn't realize what a skill it was to feel out the client whether or not their story makes sense until I was signing up a bunch of cases. And I remember I would be excited about them and I would talk to Joe about them and he would say, my spidey sense is up on that. That doesn't sound right to me. I'm like, what do you mean? This sounds like an amazing case. It's going to be a million dollar case. There's liability, damages, source of recovery is per. And it was almost always a case that ended up not being anything like what the client told us happened. Because I wasn't asking those really focused and direct questions. Well, how did you leave the scene? Or who was the first one there who called the police.
05:58
Speaker 4
And then when you start getting really into the details about what happened, you'll learn a lot more information, more than just what might be on the crash report.
06:07
Speaker 2
I think we made a lot of bets on how those cases would turn out. And I, I still think you owe me a couple of beers where we're able to get back together.
06:16
Speaker 4
Yes, definitely.
06:19
Speaker 3
It always reminds me I went out to a house to go sign up this couple that said this drunk driver, they had her on video who came and hit their car right near their house. And so I'm meeting with them and I'm actually at their house and we go through the whole story and I really hammer on what's going on here. And just something didn't add up because all of a sudden the story turns into. It was 2:30 in the morning on a Saturday night and the clients just so happened to be going out to run some errand to go run to the Walmart when they got their car got hit.
06:55
Speaker 2
Right.
06:55
Speaker 3
And so trying to suss out, well, that doesn't make sense. Their car was probably just parked in front of the house when this whole thing happened. And so that girl was drunk, but she was too drunk to remember what happened. And, and so we did find out and ended up not taking the case pretty early on. But I think you have to kind of take it from both sides of listen to your client, believe them, but ask questions of does it make sense? And if you really want someone to do that, you can talk to Jack Zinda and he will come up with the most fantastical story of how bad everything is. Even when it is a good case.
07:28
Speaker 2
It's been a blessing in disguise. Right. Jack always plays the devil's advocate. And I think playing the devil's advocate to our client story. Right. It isn't bad for our client. That just means that we're thinking through what the other side is thinking through and probably getting to the bottom of it way sooner. Right. I trust nobody, just as kind of a general rule. But I think one thing I've learned very quickly in this business is independently verify Whatever you can, right? And not just how the crash happened. You know, I remember one of the first dog bite cases I had. This guy had a couple of fingers that were bitten off by the defendant's dogs. And I forget what he did, but he did some handiwork and he brought in his resume.
08:22
Speaker 2
And because it was a low medical damages case, I wanted to make it a big future damages case. And we thought about the medical treatment side, but we really focused on the vocational side of what he could do. And we're looking at a resume that he's provided us. And throw myself under the bus here, I took him at his word for what he told me he did. We get out his resume and deposition prep this guy. His entire one page resume was a lie. He made up positions, he made up dates, he worked at places that never existed. He got his brother's assistance to help him concoct this because he thought it looked good. And this is a nice client who was not lying about how this incident happened.
09:15
Speaker 2
But it just goes to show you have to uncover every rock and independently verify these things. And if you don't, you know, were able to pivot in enough time to not have to deal with the fallout. But if you don't do that early, you're going to end up in a position where you're kind of skunked.
09:35
Speaker 1
And you know, I think it's really important to, like Neil said, to play devil's advocate and to really question all the facts that you're looking at in the beginning of the case. And the reason I got so good at it is I spent the first year of my practice signing up a bunch of cases and then the second year of my practice getting off about 80% of them because they were mostly bad cases where the facts were wrong or the damages weren't there wasn't a source of recovery. You know, one tip is talk to somebody who is really conservative minded and, or skeptical maybe is a better word for it in your practice that can be that person to question it. Because we get into this because we want to help people and I want to believe everyone.
10:23
Speaker 1
And that's how I started my practice. And I got burnt a lot because I didn't ask the right question. It's not always the client is being deceptive. They could be mistaken. If it's a wrongful death case, they don't really know the facts. You're getting things second, third and fourth hand. And a lot of times when you sign up a case, you'll hear information from the client. And if you don't verify it, that becomes then an assumed fact in your head. And you could get six months, a year, two years into the case. And you never vetted that. And it actually wasn't a fact, it was just someone's opinion or hearsay that someone heard second, third, fourth hand. We recently were looking at a case that was a really tragic case involving a gas explosion.
11:06
Speaker 1
And we got brought on by the uncle and we thought, you know, he represented that this gentleman had a great reputation, a great relationship with his family. And you know, about a month into the case, it turned out well, actually he hadn't seen them in, you know, 25, 30 years and had a terrible relationship with them, which really affected what we could do in the case itself. So I think really vetting that information, you know, one tactic that our firm uses is we have an investigation stage when a case is open where the attorney's required to look at the case every day to see, have we established liability and you're not allowed to use the client's testimony to establish your liability facts? Damages? Do the damages meet the threshold necessary for you to pursue the case? And have you found a source of recovery?
11:59
Speaker 1
So we talked about the client a little bit and somewhat on liability. Talk about source of recovery. So first off, you know, how do you guys go about identifying if a case makes sense from a source of recovery standpoint, especially when someone comes in and you don't know much about the case?
12:16
Speaker 3
Yes. I mean, the first thing to start out with is do you. It really depends on the type of case. Right. So most of our practice is going to be either, you know, a large corporation or corporate defendant that's self insured or an insurance company that's behind whoever the person or entity is that's going to be footing the bill for what went wrong. And so, you know, in a motor vehicle case, you know, trying to confirm whether or not there's some sort of insurance policy that applies. And that's where it goes to, you know, really digging in. You know, don't just take the word from, you know, the officer in the crash report, but, you know, finding out, running a little background, do they live with anybody else? Are there any other policies, context clues? Do they appear to be younger?
12:58
Speaker 3
So maybe they're under a parent's policy. What are they working at? The time is obviously one of the bigger ones. And you know, just recently it was pretty surprising on a case with huge damages, you know, and we just come to find out that it's the defendant driver. They listed their small insurance policy through a normal insurance plan. Afterwards, the client had already been through another attorney that had basically they dropped the case because they thought there was no insurance. And through. One way to find out, like we talked about is filing a lawsuit, come to find out that the girl was absolutely driving for a national commercial pizza delivery chain. And so there's plenty of insurance available and there's something to go after. And so I think just really digging in and looking at all those different areas is really important.
13:49
Speaker 4
Yeah. What kind of car the defendant was driving? You know, I get a ton of potential client calls where they're like, I have a copy of the police report. The other driver didn't have insurance. Is this still something you can help me with? And so don't ever get hung up on the fact that there's just no insurance listed. He could have just not had it on him at the time. And then I'll ask what kind of car was that person in? And they'll say, oh, a 2020 Volkswagen. Well, it's almost guaranteed that a 2020 car is going to have insurance. So just make sure you're getting all the details and then take the time to look into it further. Was this a younger driver on their parents plan, their insurance policy.
14:31
Speaker 4
I mean, so going that extra step and not just taking everything at face.
14:35
Speaker 1
Value, especially a Volkswagen. I mean, you're not going to drive a Volkswagen. I mean, you're already safe. You're not going to drive Volkswagen with that insurance. There's no way.
14:42
Speaker 4
Exactly.
14:43
Speaker 2
No, you're 100% right. The most important thing that we need to confirm is that source of recovery. It's going to determine our strategy, it's going to determine the time frame in which we can try to get a case resolved. And it's going to dictate what, sometimes what medical care our clients are able to receive. And so don't just go look at that crash report and see a blank insurance policy. You know, I don't think it's a bad idea to send letters of representation to Lyft and Uber. In every case, go to LinkedIn, go to Social media, figure out where they work, send a spoliation letter there. You know, there was a case that we recently had with very significant damages where this guy's driving like a 1980 truck that I've never heard of.
15:33
Speaker 2
And the crash report says one of the fly by night insurance companies where, you know, it's a minimum limit policy. Typically what we realized though, because we Wanted to take that next step and investigate is that was his personal policy. This was an enterprise rental car. And for some reason, when we got in touch with Enterprise, this guy who has no insurance any other time he's driving, who has upsold a $1 million policy while he was renting a car for two days. And all of a sudden, the trajectory of the case, the timeline, our strategy, completely changed. We thought the source of recovery was $30,000. All of a sudden, it's a million dollars.
16:20
Speaker 2
We can go perform an inspection, we can hire some experts, we can make sure that we're working up the future care and the future damages so that we can present it. And if you don't do that in a quick amount of time, you may lose out on the opportunity to do some of those things. So really identifying the options and knowing what to look for and what outside the box ideas, as far as source of recovery that exist are the better position you'll be in to take those next steps forward.
16:54
Speaker 1
And I've seen that so many times. That reminds me of a case that Joe and I worked on a long time ago, where it was a pedestrian that was hurt really badly in a parking lot, and a teenager was on the crash report in a really old Bronco, and he was ignoring our letters of republic. The insurance wasn't listed on the police report, and it looked like they didn't have insurance, given the address he lived at. And everything else was a teenager, college age. And we did some more background research, and it turned out their parents were executives at one of the major financial institutions. And lo and behold, he was covered by an $11 million insurance policy, which this client had been turned down by a couple of the law firms because the crash report listed no insurance.
17:49
Speaker 1
So when you've got big damages, you've got to do your due diligence to make sure you're looking under every rock with what is the actual source of recovery. You got to be really careful if you've got a death case or a catastrophic injury case to accept limits if they're not a lot of money, because you could be missing something and waiving your client's claim. So I'd be very hesitant to ever settle a case like that without getting into at least litigation and doing some formal discovery to, you know, ferret that out.
18:18
Speaker 4
And that's also where dash cam and body cam footage can be really helpful, too. I know we had a case where it looked like it was a minimum limits policy, and on the officer's body cam, the defendant's on there saying, you know, I was on the job, I was just coming from work, I'm a janitor, as you can see in my uniform and points to the name of his company that he was driving for. And so kind of like what Joe said, a case that you think is only a $30,000 policy, that one turned out to be a million dollar policy because we knew from further investigation that he was on the clock at the time and was covered under this commercial policy.
19:02
Speaker 5
Zynda Law Group is a plaintiff's personal injury law firm made up of over 30 lawyers that handle catastrophic personal injury and wrongful death cases throughout the United States. We regularly counsel and joint venture with firms across the country. Over the last several years we have paid millions of dollars in joint venture counsel fees to the law firms we work with. If you are a law firm or attorney and have a catastrophic personal injury or wrongful death case you would like to joint venture or work with Zynda Law Group on, please reach out to us at 800-863-5312 or email us at infozdfirm.com and we can set up a time to discuss your case.
19:43
Speaker 2
And sometimes I'm amazed at what information I get just by asking. Right. So be aware of the rules in whatever state you practice as far as reaching out to potential opposing parties. But phone calls, letters that we will send asking them to turn over this information with the self addressed stamped envelope letters that obviously make sure they know who we represent and that we'd be proud to show in court if necessary. But that information gets back to us all of the time. There's also depending on what state you practice in, there may be some statutory help that certain states can assist you with enforcing. Insurance companies once you find them to disclose not only limits but excess and umbrella policies.
20:36
Speaker 2
And that's one trick that in practicing for a decade or so I've seen it a million times, is just because they turn over an insurance policy and litigation, especially if it's a larger insurance policy, make sure we're going to that next step. Is there an umbrella or an excess policy? Let's figure out how we can make sure there isn't one. Because if your case is worth in excess of this $300,000 policy and you haven't verified if there's an umbrella, you have some explaining to do.
21:11
Speaker 1
And a lot of these tips are really useful in identifying the source of recovery. I think what can be challenging as well is when you have a non motor vehicle case in trying to evaluate liability Whether it's, you know, we've had some construction cases or premises liability cases where it's not laid out in a crash report. And, you know, especially if you're talking about the premises liability context or a workplace injury, I think it can be really helpful to write out the charge to figure out what are your elements that you need to show, especially in a premises liability case. Make sure you can show notice, make sure you can show that it was a hazard, that it was unreasonable.
21:51
Speaker 1
And so what are some of the tips you guys have for, let's say it's a premises liability case or a workplace injury case about trying to establish liability outside of just your client's word? Because that can be tricky.
22:03
Speaker 3
Yeah. So I think in those types of cases, one of the most important things is a lot of times getting out to the scene and doing an inspection and potentially hiring an expert in whatever field it is that you're working in. And I'll say it's why I often like a lot of these cases, because you learn so much about a different area, whether it's how to build a hotel or how the training process is related to operating a truck crane or how to hang a chandelier. There's so many different things that you kind of get able to get to see over the years. But I think you have to get to the scene so you can lay eyes on what you're talking about, and they get an expert to talk to you about what could have gone wrong and what the parties are.
22:45
Speaker 3
And then I think a lot of times you'll find, and especially in a lot of those types of cases, you know, whoever the target defendant or first person you're going towards, they'll be the ones that point you towards the direction of who else is maybe at fault, because they want to point the finger at whoever that person is, and so they'll point you in that direction. And so even if you just file against the first party, you can bet there's going to be some others that are going to have to be brought in or they're going to try to bring in to establish it as somebody else's fault.
23:13
Speaker 2
You hit the nail on the head. You know, you've got to get out to that scene and preserve it and get it inspected because you're not going to be able to prove your case otherwise. You've got to send disfoliation letter to preserve that evidence, especially video evidence, if it exists. If you know it's a premises case at a grocery store or a large chain of Some sort. And you got to try to find, if you can, some witnesses. Some witnesses that will help prove up your case, whether they're co workers, bosses, onlookers, something that help prove your case. If you don't have a combination of those in your arsenal, on these types of cases, you are playing from behind look.
23:59
Speaker 1
I mean, when you go out to the scene, don't just focus on where it happened. I think it's important to try to go at a similar time as when the incident occurred. So you can see who else would be there around this time, what other witnesses, who else is working there. And I'm making mental notes and physical notes of everybody. I see that I might make a potential witness later on the case. Also, look for cameras in there. Almost every case where we find great camera footage, they say there are no cameras. Then we go to the inspection. We're like, what is that? Like, oh, we didn't know that camera was there. Yeah, I guess there is a camera.
24:35
Speaker 1
And we've had cases where we've had to get the court to order us to go back into the control booth to be able to see what they see. And lo and behold, we get some great camera footage. Joe and I had a case where the defense was hiding the. I'll give them the benefit of the doubt. They could not find the camera footage up into a year and 10 months from the date of the incident. So two months from the statute of limitations, and lo and behold, we finally get the court to order them to turn it over, and it shows a third party cleaning the floor, waxing it about 10 minutes before our client walked and slipped over the wax on the floor. So you got to be persistent and know that evidence is there.
25:18
Speaker 1
We would have been in deep trouble if the statute had run.
25:21
Speaker 4
Yeah, that's a good point. Taking a look at other factors other than just the defect that you're there to examine in the first place. For example, I know I had a premises liability case at an apartment complex in a mountain town. And so I remember going there with our premises liability expert. She's an engineer, and she was there to inspect the stairwell where our client tripped on loose carpet and fell down and suffered some pretty catastrophic injuries requiring multiple surgeries. And just while were there, we made sure to go around the same time of day that this occurred. It was, I think, 6:00pm or so. And the exit lights weren't illuminated, doors were broken, the laundry room had broken tiles on the floor. And our expert took note of all that stuff, too.
26:12
Speaker 4
None of that was stuff that she was there to examine, but it's all going to be in her report. We found that's actually really big to a potential jury and doing some focus groups on that case, they wanted to know what the general condition of the premises as a whole was like. And when they started seeing that, it looked like from all these other factors that the management company really just didn't care about the premises, they definitely got angrier with them and were more inclined to award higher damages for our client.
26:45
Speaker 2
I'm sure we've all seen this too, but I always think one of the keys in these types of cases is file it early. It is a rare circumstance where I am in litigation against for a premises case or a construction company or construction site, and there aren't fingers being pointed. It is a very rare circumstance. And so the danger of doing that is if you don't file early, you are not going to have enough time to figure out who all is involved, what fingers are being pointed, and get all of those entities in your suit so that regardless of who's at fault, as long as it's not your client, you should be in a good position.
27:27
Speaker 3
Well, to bring it back to whether to take the case or not. So how do you decide whether or not you want to take that case and even file suit on it? Like in that construction context, Joe, how.
27:37
Speaker 2
Do you know that you want to file suit on it?
27:38
Speaker 3
Yeah. How do you decide you even want the case to go file suit?
27:41
Speaker 2
I think that how I always approach it is let's assume best case scenario in terms of liability, damages and source of recovery. And then given that and how much money I can afford to spend on the case, can I file a lawsuit and conduct an investigation without taking a crazy risk? And sometimes that involves, you know, how much do we believe the client if we don't have independent knowledge of some of the facts we need on liability? So we're going to have to meet in person with the client or have zoom interactions to get a sense of the client. We don't want to just have, you know, my brother in law column and have a signed contract in hand and then get to work.
28:29
Speaker 2
You know, sometimes you're not going to have all the information you want, but you're going to have to take a chance based on the information you do. And I would just encourage anybody making that decision to try to make the most informed decision they can, because you're going to kick yourself if you should have asked that question that you didn't think of until it was too late.
28:51
Speaker 1
Yeah, that's a really great point. I think you've got to envision what's your best case outcome if you're going to decide on what to do and how much money and time to invest. I mean, I see a lot of attorneys will spin their wheels on cases that even the best outcome is not going to be a meaningful outcome for either the client or. Or their law firm. And it makes no sense to pursue it on that front, or they shortcut the investigation stage and jump right to filing a lawsuit. I had a case, and I learned a lot of these lessons the hard way. I had a case really early in my career where the client's brother swore that he had a TBI from this truck wreck. And, you know, we filed a lawsuit.
29:42
Speaker 1
We spent a lot of money in the investigation of the case. And it turns out that he actually was a drug addict who had some serious dependency issues that was creating some mental problems. And I hadn't taken the time to talk to his other family members to really vet this story. And the way that it came to my attention was I got a request for admission from opposing counsel that says, admit or deny that your client had drank prior to the wreck. And that was the only question. So obviously they knew something about my client. And sure enough, he had drank quite a bit prior to the wreck. And, you know, several, you know, probably 100 hours later of work and several thousand dollars, you know, we end up withdrawing from the case because were going to lose on liability.
30:34
Speaker 1
So do that due diligence on the front end to save money on the back end. Guys, this has been an awesome conversation. I could talk about this for hours and hours, especially all the mistakes I've made. But before we go, what's one last tip you would give a young trial lawyer on what they should think about when deciding to take that next case?
30:57
Speaker 4
Chrissy, I would say don't think that you're helping the client by taking their case automatically, Because I know for me, at least, it can be really difficult to turn down cases because I always want to help the client or the potential client. But I've come to realize that by taking a case and then inevitably having to reject it later on doesn't make it any easier to reject that case. So just really trying to look at it with that perspective in the beginning, and the client's going to appreciate you being upfront and honest at the very beginning and letting them know if you don't think it's a case that they're going to be successful rather than that false hope of them thinking you can help them when you know it's not a case that you can to piggyback.
31:49
Speaker 3
On that, I think that's a lesson that everyone can learn and it's really smart. And I think the other part of it is that my main takeaway would be moving forward. Number one, if it is a tough case and you're going to take it, just being open and honest with the clients about that as you conduct your investigation. And then when the time comes, if you do need to move off of the case after you found out that it's not going to be successful, they're prepared for it and it's an easier conversation to have versus you sign them up on a promise of a million dollar case when it doesn't work out. And so I think trying to be open and honest about how difficult it is if it's going to be and then if it works out, then all the better.
32:29
Speaker 3
That's obviously your goal too. But I think just letting the clients know if you're going to take on a tough case and then there still may be a chance that we end up telling you that we can't move forward but being honest about it.
32:41
Speaker 2
Yeah, I think in that same vein, I'm always thinking of the best case scenario when we're first taking a case and I'm hoping that the outcome is rosy. But the best advice that I received as a young attorney was you can't fit a square peg into a round hole and you can't change the facts once you've established what they are. And even though you may wish that the facts showed what you wanted them to show prior to that investigation, if it's conclusive what the facts are, change that analysis and come to terms with the fact that the outcome may be different.
33:19
Speaker 2
But you need to reassess the next moves of the case and not have that constant thought that you did when you first got the case, when things were different, that the outcome was going to be one way or that we needed to make this next step to have a successful outcome for the client. So just always be willing to be on your feet and change your game plan depending on what you've uncovered.
33:46
Speaker 1
Well, guys, this has been a lot of fun. I appreciate you all getting together and I hope the listeners have found this helpful. If you need any more advice or questions or help evaluating the case, please do not hesitate to reach out to our firm. We're always happy to help younger attorneys or people new to the plaintiff's world on a case or help them evaluate if it's a case that makes sense for them to pursue. Until next time, guys, thank you very much. Thank you for taking the time to listen to this episode of the Effective Lawyer. If you enjoyed this podcast, please take a moment to rate it 5 stars and leave us a review. To get notified about new episodes that are upcoming or have been released, go to zdfirm.com/podcast to sign up for our mailing list.