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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
00:10
Jack Zinda
Welcome to the Effective Lawyer, a podcast for ambitious attorneys who want to improve their practice. My name is Jack Zynda and I'll be your host. All right. Hey, everybody, it's Jack Zenda here. And today we're going to talk about errors that plaintiffs lawyers make. And hopefully I haven't been any of these. And to help me, we have one of our best trial lawyers at the firm, Drew Bell. Hey, Drew.
00:34
Drew Bell
Hey, Jack. Great to be here.
00:35
Jack Zinda
Thanks, man. Drew recently joined the team and he has an amazing background. He's tried dozens of cases with millions and millions of dollars on the line. He came from a very good trial firm, King and Spalding, where he was on the other side of the fence. Drew, why don't you tell the audience a little bit about your background?
00:52
Drew Bell
Sure. That's right. I was at King and Spalding for 13 years trying cases for a variety of different clients. Although I had a focus on tobacco cases, so we would represent tobacco companies in wrongful death personal injury cases. As you said, they were high stakes cases with millions of dollars of exposure. And I ended up trying about 30 of those cases throughout my career at King and Spaulding. Very interesting cases, very difficult cases, but learned a lot. And now taking that experience and bringing it over here to the plaintiff side, that's great, man.
01:27
Jack Zinda
We are so lucky to have you. And the cool thing is today he's going to pull the curtain back a little bit and he's going to tell us the mistakes he saw plaintiffs lawyers makes in, you know, his time over there. And so we can hopefully avoid those. So, Drew, you know, tell me what were big picture, some of the biggest mistakes you saw plaintiffs lawyers make in their cases.
01:48
Drew Bell
The number one way to lose an otherwise great case is overreaching. And you can overreach in a number of ways. But the best plaintiff's lawyers that I've seen, when they have a great case, first of all they know it and then they play it down the middle. Just play it vanilla. Let your case speak for you. You don't need to lay it on too thick to drive up the emotion, because a great case will get that result for you. When you're a defense lawyer, what you're looking for is something to grab onto, something in the case that you can talk about to the jury, that you can make a theme of the case that is not the bad stuff your client did. Right. You want to talk about anything else.
02:33
Drew Bell
And sometimes the cases have those intrinsically in the facts, but a lot of times they Don't. And if they don't, you need to find something else. And if the other side, if the plaintiff's side is overplaying their hand or somewhat in some way, then that's what they will grab onto. They will grab onto you, and that's the last thing you want. And I've seen this often with people who are good lawyers, good plaintiffs lawyers, but they have a very dramatic and aggressive style in the courtroom, and they almost can't help themselves. And, you know, I think from our perspective as from the plaintiff side, we just need to be more disciplined than that. Because you can lose credibility.
03:13
Jack Zinda
I think that's right. Credibility, to me, is key. Like, you always got to focus on credibility, especially you said, pointing out facts that aren't, that maybe that you, the plaintiff, doesn't want the jury to focus on. Do you have some examples of that?
03:24
Drew Bell
Yeah, absolutely. Because. And once your credibility is gone, you're not going to get it back. And I think it's actually more important for the plaintiff's lawyer to have credibility than the defense lawyer, because you're the one asking for money. Right. So there's this great example that comes to mind, a case that we tried in Florida for RJ Reynolds. And this is one of the worst counties in the state. In fact, it's one of the worst counties from the defense perspective, in the country. Fantastic. Plaintiff's case on the merits. We had a sympathetic family. Not a good case in terms of awareness of the dangers of smoking or addiction to cigarettes. These are sort of themes of the plaintiff's cases in the. In the tobacco world. But this was a plaintiff's firm as probably the most aggressive in the state.
04:12
Drew Bell
We also had a judge whose philosophy was to let all the evidence in, basically let the plaintiff put on whatever case they want to put on and let the jury sort it out. Okay. And when you combine those things, what you had in. In the trial is the plaintiffs lawyers putting out a whole host of evidence in the liability phase of the trial that would ordinarily not come in. And most plaintiff's firms wouldn't even try to put it in until a punitive phase. Right. Where it's more appropriate for deterrence and that sort of thing. And all of it came in. And then the plaintiff's lawyer just went wild in closing argument. I mean, things like referring to the defense arguments as the last refuge of the scoundrel.
04:59
Jack Zinda
Oh, wow.
04:59
Drew Bell
Right. Wrongly said that the defense had conceded issues. It hadn't. Right. Referring to the defendant as an enterprise of death. Quoting Martin Luther King's the arc of the moral universe is long, but it bends toward justice as a reason to find for the plaintiff. Quoting from George Orwell's 1984, that's great. Etc. Right now, the jury came back with a $10 million verdict. Okay, pretty good verdict. Pretty good verdict in one of those cases for the plaintiff goes up on appeal and they lose it. It gets overturned on appeal because all these improper closing arguments, they didn't need to do that. Right. And all of a sudden it's $10 million off the board and they have to retry the case.
05:47
Jack Zinda
So in that case, a lot of it was they made created reversible error. Right. Is that the main issue there?
05:54
Drew Bell
Yeah, exactly. I mean, they just had no self control in the argument that they were making. They were just trying to amp up the damages when they didn't have to do that. They could have gotten that $10 million without those arguments and they actually would have collected it. And in fact, that same plaintiff's firm has lost probably about $100 million in similar reversals.
06:16
Jack Zinda
That's so interesting. Yeah. You know, I think overplaying your hand to the jury and the jury really has to give you permission to be indignant. And I agree with you wholeheartedly. Letting the facts speak for themselves and letting them draw their conclusions. And maybe you have one line, but, you know, throwing all those in, plus, you know, you have to be very careful going to quote Martin Luther King. It's got to be the right issue. Right. Case, and make sure it's justified in that situation. Yeah, well, that's interesting. So in appellate issues, did you see plaintiff's lawyers make a lot of errors there where they either didn't preserve appeal or they created error and they shouldn't have.
06:48
Drew Bell
There definitely have been preservation issues that I've seen. You know, I think a lot of the plaintiff's lawyers don't think about the appeal front of mind as much as the defense does. I mean, when we're defending a case, the appeal is always front of mind. Right. Because it's, it's our second bite at the apple to try to get out of a bad result. And yes, I've seen several times when the plaintiffs have either intentionally or unintentionally waived appellate issues because they're just trying to get to a verdict.
07:27
Jack Zinda
You know, something I always think about is getting evidence. Say you win a ruling from the judge that is kind of 50 if it's going to reverse you on Appeal. A lot of times we won't want to even win that argument because it just creates something that's a distraction. So do you see that a lot where maybe the plaintiffs lawyer puts, maybe wins an argument with the trial judge, but it was an error to even bring it up because it's not going to affect the case that much.
07:48
Drew Bell
Yeah. And usually where that happens is on directed verdict and jury instructions. Right. So I had a case in Miami where the plaintiff requested a directed verdict on medical causation, a partial directed verdict on medical causation. Now, this was a case where we didn't have, we, the defense didn't have much of a medical defense, but we did cross examine the medical expert. We did sort of poke, try to poke some holes in the plaintiff's theory. And really that should be enough to survive directed verdict, even if directed verdict had been appropriate on a partial issue like that in the first place, which, you know, that was our first argument that it wasn't. But the trial judge, who's a very plaintiff friendly trial judge, granted the motion. And I was thrilled.
08:41
Drew Bell
I was thrilled because it wasn't a defense were going to present in closing argument anyway. And he just gave us a basically a stone cold appellate issue. And it was just a total error. They should never have asked for that motion in the first place.
08:53
Jack Zinda
But the plaintiffs lawyers that do handle appellate issues, well, what do they do? Well, do they bring an appellate counsel? Usually? Are they just more sharp on civil procedure? What do you see them do?
09:01
Drew Bell
Right, yeah. I think the better plaintiff's lawyers who are aware that, you know, they have a lot going on at trial, a lot to consider, and they don't want to be bothered or hung up or distracted by arguing all of these appellate issues, making sure things are preserved, undermining the preservation attempts of the defense. And so a lot of the very good ones will bring in appellate counsel. And I think the ones that can afford to will have them there the whole time, not just coming in for the charge conference, not just coming in to argue direct verdict motions, but we'll have them especially during jury selection, where a lot of error can be created, especially on cause challenges. And you know, they will be there.
09:46
Drew Bell
They will argue a lot of the sidebars, they'll argue a lot of the evidence, because that's again, another place where there can be a lot of appellate pitfalls. And so, yeah, I think it's very smart to have appellate counsel, whether it's within your firm or whether it's with a specialist firm, either way somebody there who is focusing on the legal issues in the case.
10:06
Jack Zinda
And we've done that in several of our cases. We will both have someone who at the firm is just focused on the procedural appellate issues. And then for larger cases, especially if it's in a jurisdiction we haven't tried a lot of cases, we'll hire appellate counsel to be there the whole time. And usually you can get them in on a contingency fee basis, so they get a percentage of whatever the recovery is at the end. And it's definitely worth it because the worst thing that happens, you try a case, get a big verdict, is reversed or reverse and rendered, which is even worse, which happens quite a bit in Texas, unfortunately. Well, tell me for void dyer, that's interesting. So what are some of the mistakes you see from an advocacy point of view that plaintiffs lawyers making? Bordeaux.
10:47
Drew Bell
So I've seen a lot of great plaintiffs, jury selection processes a lot of great voidir from the plaintiff's bar. The mistakes that I see are generally from lawyers who are great advocates because they can't help themselves. Right. In jury selection, you know, the way I like to think about it's opposite day.
11:09
Jack Zinda
Yeah.
11:09
Drew Bell
Right. We're trying to. You almost beat up on your own case so that you can identify the people who are going to be bad for you and try to get them off the jury, get rid of them. Right. Send them home. And there are a lot of lawyers that struggle with this, because we're advocates, we're trying to advocate for our clients. We're passionate about that. And if you do that during jury selection, if you try to precondition the jury too much by arguing your case too strongly to them, you're not going to get them to identify themselves as people who are hostile to your case because you're being too persuasive.
11:43
Jack Zinda
Yeah.
11:44
Drew Bell
Which is not the point. What you want to do is actually be not persuasive to your side of the argument and have people say, yeah, I don't, you know, I don't know if I can be fair to that, you know, to your point of view. And some preconditioning, you know, is probably, is probably fine, but you don't want to overdo it. You want to use your time wisely. And the smarter thing is to get rid of those jurors who are going to be, you know, deadly for you back in the jury room.
12:10
Jack Zinda
Does it seem like a lot of them that practice their void hour before they're going, or does it seem like it's the first time they've done it in that particular case, because that's. I find that's an error. I see a lot of trial lawyers make is they don't practice their board hour opening, so they don't really anticipate what they're going to say or how they're going to say it, or they have a, a template they use every single time.
12:27
Drew Bell
Yeah, I think I've seen more of the latter.
12:29
Jack Zinda
Yeah.
12:29
Drew Bell
You know, I've seen a lot of plaintiff's lawyers have like a script, and I think that's generally okay. Defense lawyers do that too. But you do have to be able to pivot. You have to be flexible, especially if you start running out of time. You have to know what's important, what you can skip and what you can't. You know, I've seen plaintiffs lawyers also use jury consultants and not, you know, I've seen it both ways, and it's hard to say how helpful or not helpful it is. I know from the defense side, I think it's, you know, it's very helpful to have somebody who is not as familiar with the case as you are judge the reactions of the people out in the panel and offer their sort of expert opinions.
13:13
Jack Zinda
Yeah, that's great. In a practice tip, you can have people from your staff, either paralegals or other lawyers, watch your board or even other colleagues. I know our trial bar is very friendly. And if you put on the listserv that someone, you have a jury child, they'll come and show up and watch and help you pick a jury. People love to do that. So. And I think that's a great point because you know the case so well. You have embedded facts in your head that you're assuming or biases that you assume people are going to agree with you what they think of your client or the situation. And you really have to take a step back. Okay. What is someone. The first time they're going to hear this case and someone who's not a trial lawyer is going to think of it, Right?
13:50
Drew Bell
Exactly. Exactly. And you have to understand that these people, they don't want to be there, right?
13:56
Jack Zinda
Yeah.
13:57
Drew Bell
And they're barely listening. The instructions go right over their head. And so you really have to take your time and be careful and understand where they're coming from when they're giving their responses.
14:11
Jack Zinda
If you'd like a copy of any of the things you heard about here today or to set up A time to talk about one of our team members about a case. Please go to Zendalaw IO and we have amazing resources, downloads, guides and you can set up a time to talk to us if you want to talk about how we handle things or any case in particular. Well, another thing that I think I see, plaintiffs lawyers make mistakes a lot is the story they tell and how much time they take to tell it. You know, if you have an expert witness and you put them on the stand for a day and the six hours of testimony, people are just going to fall asleep.
14:52
Drew Bell
So this is tied into what were talking about at the beginning with overreaching. I have seen expert witnesses on the stand for four days on direct and it is too much. There's really, I mean unless you are trying a high profile securities case that's going to be like a multi month case, there's just no reason to do that. Now you do need to make sure you're putting in enough evidence to justify your damages request. And so you do need to be thorough, but you need to not waste the jury's time because that can really backfire. In fact, that same case that I was talking about before, when it was retried, we retried it last summer. And in that situation, the plaintiff's lawyer was able to put on again a lot of the evidence pervert basically as much as they wanted to.
15:51
Drew Bell
And they did too much. They did too much with the plaintiff. Right. They had all of this physical evidence that they were going to use to support non economic damages. They had the blanket that her mother died, you know, died using. They had an old rocking chair that was stained with nicotine supposedly. Right. And they had letters from her and they had her jewelry. And I watched this testimony and I could see the energy leave the room as they went on and on and gilding the lily with this. Right. They should have picked one or two of these items, walked through it. That would have been very powerful. But by the time you get to the fourth, it becomes transparent what you're trying to do, right. And it just loses all of its punch.
16:38
Drew Bell
And so it's just another way that you can overreach and undermine your own case.
16:42
Jack Zinda
I think that's a great point. And you know, something that you can do on your own is if you watch Netflix documentaries, some of these criminal ones, they do a great job of concisely making an argument one way or the other. And our job is to make an argument in a concise way. And if you beat a dead horse on that, you agree. And also it just kind of takes away from the power of those stories, you know.
17:03
Drew Bell
Absolutely. And, and you know what the jury did the second time that case was tried, they came back. Instead of awarding $10 million, they awarded $30,000.
17:11
Jack Zinda
Wow, that's a massive difference. Holy cow.
17:13
Drew Bell
And that case is currently on appeal, but they don't have any good appellate issues. So it's probably going to stay that way.
17:20
Jack Zinda
Well, and let's talk a little bit about asking for money. So in the Times you've seen plaintiffs get big verdicts and times you've seen them not get the verdicts of one. What's been one of the things you've seen about asking for. I know that's something people always want to know. You know, do you mention the number? Not mention the number and opening, like what have you seen work and not work from your point of view?
17:40
Drew Bell
You know, that's really interesting and I think, I'm not sure that there's one right or wrong way to do it. I think it's very, I think it's essential to preview it to the extent you are legally allowed to do so in your particular jurisdiction. In Voirdir. Right. Get people's reaction to a big request if you can, in Voirdir. And a lot of places won't let you test specific numbers, of course. But if you can characterize it as, you know, I'm, you know, we may be asking for eight figures or something like that. That's not a specific number. If you can get away with it, you know, it's really important to try to identify those low damages jurors. So that's one thing. And I think most of the plaintiff's lawyers I've seen do not throw out specific numbers in opening.
18:37
Drew Bell
And I think the reason they don't do that is because they don't want the defense to spend the entire trial attacking the number. Some of them will refer to a, we're going to be asking for a large number at the end of the case to just sort of, you know, take the sting out of it. So the first time they're not, they're hearing it isn't enclosing. Yeah, right. But it's a balancing act. It may depend on who your opponent is and what their style is and how prepared you think they are. Right.
19:05
Jack Zinda
And in rubble of death cases, what do you think are some of the most effective non economic damages witnesses? I know a lot of your cases involve those who did you find were the most effective in those situations?
19:17
Drew Bell
Yeah, absolutely. Yeah. No, the vast majority of the damages in our cases were non economic pain and suffering damages. So sometimes the plaintiff's lawyers were able to bring like long time friends. Right. These kinds of people who knew the survivors for a long time and are still in touch with them today day and really have a deep knowledge of their character and who they are. Because that kind of genuine affection for a person comes out on the stand. It really does. And the jury can tell. But it's also helpful that they have no stake in the outcome, no direct stake in the outcome anyway. Obviously they want their friend to win, but they are not standing to make millions of dollars themselves. So their testimony just becomes very credible. And I would say the same is true for like distant relatives. Right.
20:16
Drew Bell
If you have a nephew or something, someone who's not likely to inherit money or be given a large chunk of money, I see that as basically the same as like a friend. And it's very difficult to do anything with this. Those witnesses. Right. From the defense perspective, what are you going to do? I mean, you know, a lot of times you just preserve your credibility by not asking many questions and not and trying to get them out of the room as quickly as possible.
20:45
Jack Zinda
Do you find, did you see maybe not in your cases, but others where defense lawyers would attack a non economic damage witness and hurt their case or their credibility because they kind of like get the anger of the jury for attacking this person that really doesn't have skin in the game.
20:57
Drew Bell
Yeah, were always very afraid of doing that. I mean that was always something that I was, you know, I would rather do less with the damages witness than too much because it's sort of a do no harm kind of approach. Now if that witness has other material evidence to give, obviously you get that, you treat them with respect. But yeah, I mean I've definitely seen it where the defense is overreached and attacked. Something like, you know, maybe, you know, did you see the plaintiff drink alcohol on XYZ occasions when there's no real evidence to support the idea that the plaintiff had a drinking problem? Yeah, right. I mean, yes, they may have had some alcohol, but so what? It's not really that important and it just makes you come off like a jerk.
21:51
Jack Zinda
I remember I had a case one time, one of the very first cases I tried. It was a, it was a car wreck and our client had some physical therapy, went to the yard. I think this Is like, my second first year of practice, I think, and super nice guy. He had immigrated from Africa with his mom, and his mom had got arrested for shoplifting. And it had nothing to do with the case, but he came on his depot, and I eliminated it out. But the defense lawyer still brought it up as some like, aha. And it made the jury so angry that they brought up the mom's shoplifting charge to, like, discredit this guy who had nothing to do with it.
22:30
Jack Zinda
And it backfired so bad, we got a. I think we had a much higher verdict because of that mistake by the defense lawyer.
22:36
Drew Bell
Yeah, I'm not surprised. I mean, you know, anybody can overreach. It's just a problem that I have seen. Seen more often coming from the plaintiff side than from the defense side. But, yeah, that's a great example of a defense overreach. And I think when the defense overreaches, they're in a lot of trouble.
22:52
Jack Zinda
Yeah, well. And, you know, what about in discovery battles, you know, because I think on our side now, your side, we don't get paid extra for the more, you know, hearings we have and motions we file. But at the same time, you don't want to let the defense get away with hiding stuff. So did you ever see plaintiffs lawyers maybe not be aggressive enough or maybe, you know, and forget, leave something out or maybe too aggressive and waste a lot of time trying to have fights over things that didn't matter?
23:16
Drew Bell
Yeah, that's a. That's a great question. I mean, I've seen a lot of different approaches. There are definitely plaintiff firms who have a sort of scorched earth approach to discovery, going after everything, trying to take all of the 30 B6 depots that you can. You know, trying to get the CEO of the company in a deposition. And to be honest, I mean, that. That can create a lot of leverage. Right. No. No company CEO wants to sit for a deposition in some case, you know, across the country. At the same time, I'm not sure that I would say I've seen outcomes that are better because of that. You know, it's. It's more of a pain for the defense.
24:02
Jack Zinda
Yeah.
24:02
Drew Bell
And it gives the defense maybe a greater incentive to resolve the case sooner when you do things like that. But at the same time, I don't necessarily see better results at trial because of that. So I think there's. I think there's a balance. I do think there are other plaintiffs lawyers that I've seen who are good lawyers. They're good lawyers, but they just Run their cases more efficiently, and they're not interested in all of this extra stuff. What they want is to identify the clean cases with good liability, ask for a reasonable amount of damages, get their damages, and if they're in Florida, hopefully get their attorney's fees.
24:42
Jack Zinda
Yeah, that's a really great point too, because I'll find sometimes new trial lawyers will get caught up on some issue that's not that important because they want to win the issue versus winning the case. And they'll spend hours and hours, like, arguing at some point that not even that important in the whole grand scheme of things, which is time they get put into prepping for trial.
25:01
Drew Bell
When you do that, you are playing on the defense turf. Right. The, the defense will, you know, because they need to have something to say, throw out sort of issues that are, it's not that they're irrelevant, they're just not the main point.
25:18
Jack Zinda
Yeah.
25:19
Drew Bell
Because the focus, if it's on this side issue, is not on the defense conduct. And so it's best, in my view, to try to brush those things aside as much as possible. If you can get them knocked out of the case through pretrial motions, so much the better. But at trial, if you have to deal with them directly, but quickly.
25:46
Jack Zinda
Yeah, right.
25:47
Drew Bell
I mean, we had a case, this was about nine years ago now. We had a case, it was a lung cancer case and that we had a very serious medical defense in that case. Not that the cancer wasn't caused by smoking, but that the cancer was not the right type of cancer. But that's not really what this story is about. This story is about the fact that one of these medical records in the case mentioned asbestos in the smoker's work environment. Right. And so we just kind of threw it out there as kind of an evidentiary grenade. Right. Because everyone knows asbestos. Everybody's seen the asbestos commercials on tv. There's no evidence that this guy had, as, you know, mesothelioma or asbestos related disease. But the medical expert for the plaintiff had to concede that, yes, asbestos can cause lung cancer.
26:40
Drew Bell
And the, and that, and, you know, it was not going to be a major issue in the case, except that on redirect, the plaintiff lawyer didn't really handle it very well. He addressed it, but not in a strong and direct fashion. And then all of a sudden, what did you get? You got jury questions about it.
26:56
Jack Zinda
Yeah.
26:56
Drew Bell
All of a sudden the jury's interested in it, and now it's in the case. Now it's a real issue in the case when it really, I mean, it was such a minor thing.
27:04
Jack Zinda
That's a, that's a great point. You know, in something we do to try to counteract that is one, having a colleague pretend to be the defense lawyer if you're prepping for trial or with your expert witness. And then two, think about the defense theories of the case. We spend a lot of times thinking about what we want the case to be about, but try to think about what the defense wants the case to be about and then you can make sure you've inoculated yourself for that. And that's a tactic I've seen defense lawyers do really well from time to time. That's great. And what about in mediations or negotiations in general? That's another question. I know a lot of plaintiffs always wonder, are they negotiating, leaving too much on the table, like negotiating too strong, too weak?
27:43
Jack Zinda
What do you see some mistakes in negotiating from the plaintiff's point of view?
27:47
Drew Bell
Well, I think it depends on how much you actually want to resolve the case. I mean, most of the offers that we saw in our tobacco cases were just very far from. Yeah, they were just very far apart and mediation wasn't going to help them resolve at all. I think that the plaintiff's lawyers in certain cases where there was a possibility of resolution still were asking for maybe too much at the beginning and it just shut down the discussion because, you know, what happens from the defense point of view is you have to take that offer to your client and it's almost a waste of the client's time to consider it. Right. And so the defense, you know, you have to say it and then you have to say your client. Obviously this is ridiculous.
28:44
Drew Bell
I don't think we're getting anywhere because that's what you're, the in house counsel you're talking to is probably going to want to hear. They're not going to want us here. We should take a lot of time to deliberate and come back with an offer that's a quarter of what they just offered because it's just not a good, efficient use of the client's time. Right. So you don't want to leave things on the table, but you have to understand where the defense is coming from. And so if you really think that there's a chance of resolving the case for a particular number, don't highball them. Right. Don't, don't come in with something completely unrealistic that could chill the discussions.
29:27
Jack Zinda
That's Great. Is there any parting thoughts you want to leave with our listeners?
29:32
Drew Bell
Well, I think it's, I think the most important thing is actually the defense side and the plaintiff side. We're not so different, you and I. Right. You know, we are susceptible to the same mistakes, and we want, we both want to do the best for our clients. Right. And so I would encourage all of us to try to think more about the perspective of the other side because it will help us both prepare for trial and prepare to beat them. Right. You have to know your enemy, but also it can give you creative ways to resolve disputes before trial. Right. If you understand where the defense counsel is coming from, it can help you maybe approach a discussion in a different way to help you reach positive results.
30:28
Jack Zinda
That's great, Drew. Well, this has been an awesome conversation. I know I got a lot out of it, and I'm sure our listeners did, too. And I'm really glad we have you on our team now.
30:36
Drew Bell
Yeah, me too. Glad to be here.
30:38
Jack Zinda
And if anyone any additional questions, feel free to reach out to myself or Drew. Always happy to help on these topics or any others. And until next time, thanks. Thanks for listening today's episode of the Effective Lawyer. You can learn more about our team.
30:55
Drew Bell
And find other episodes of our podcast@zendalaw.com.
31:00
Jack Zinda
As always, we'd appreciate that you subscribe.
31:02
Drew Bell
Rate and review the pod.
31:03
Jack Zinda
Thanks,