Alexandria Avera on a Trip & Fall Jury Trial in Gainesville, Florida

[Music] This place was in really poor condition. The stairs were essentially falling apart. I kept trying to tell the property owner. This was a problem. This was a problem. This was a problem. And my attempts at communicating that just went unanswered. We are going to unilaterally schedule an inspection. If we do not hear from you within 15 days, when they got that letter, then they had the stair-spect. They didn't notify us. They didn't tell us. When we went out there to do our inspection with our expert, who came in from out of town and the whole thing, the stairs had been repaired. I mean, it was almost like you could still smell the fresh paint. And this kind of kicks off what I think was like the overarching theme of the case, which was the spillation of evidence. The Thursday before trial sent to start on Monday, late at night, get an email from their lead trial council, saying, you know, essentially, hey, I just got this information and here it is. And among that were emails and photos that we have been asking for since March of 2023. So at the 11th hour before trial, where we're going into a holiday weekend, where we essentially have a limited number of hours to create a response and file it before the court closes. You were listening to On-Premises, a podcast where you go behind the scenes and beyond the news articles, hearing directly from the nation's leading civil trial lawyers about their clients most impactful premises liability cases. I'm your host, Landon Stinson, trial attorney at Beacon Legal. Alex Abre is a trial lawyer at Abre and Smith in Gainesville, Florida. Alex is well known in the trial lawyer world. She's been recognized numerous times by the National Trial Lawyers Association as top 40 under 40 for civil plaintiff lawyers and has been on trial teams that have achieved multiple seven figure verdicts. She's also the president of Gatla or the Gainesville Area Trial Lawyers Association. Shout out Gatla. She's on the board of the Florida Justice Association, her FJ's Young Lawyer section, and she serves as a foster for Alachua County's Animal Rescue Groups. I did not know that. That's really sweet. Something I'm really happy for is Alex and her husband, recently welcomed their first child to the world, which is amazing. Make it in the way of the fostering of the animals a little bit. If you're anything like me and my wife. But we're here today to talk about the premises liability jury trial that Alex prosecuted for Amy Osteen in 2025 against defendant J.R. Lawrenceville, LLC, and J.R. Lawrenceville investments with Jennifer Kate's Lester, another lawyer who I admire very much. Shout out Jennifer. On September 11, 2020, Miss Osteen's walking up a stairway with Oaks Mall Plaza and Gainesville, Florida, to buy medical scrubs. When her shoe gets caught in some really negligently maintained stairs in my opinion, and Miss Osteen falls, she suffers life-changing injuries, requiring multiple surgeries and a hip replacement. So, Alex, before we get into the case that you prosecuted with Jennifer for Miss Osteen, can you tell us what inspired you to become a trial lawyer in the first place? Sure, Landon, and thank you. That was a very kind introduction. I came by, and I suppose, a bit naturally, most of my family are lawyers or judges. My grandmother is a retired judge. My grandfather started, Avera and Smith, my dad and uncle, currently practice law with me here, which has been a wonderful experience, getting to practice with them and be mentored by them, similarly to how my grandfather mentored them. So, to become a trial lawyer, because that's a very specific area. You can be a lawyer and do transactional or not regularly appear in front of a jury. It is something I thought about long and hard because my dad and my uncle, Mark Avera and Lance Avera, they are both trial attorneys. And we have the conversation of, is this something that you want to do? And I grew up watching my dad try cases. And the answer to that, I batted it around a little bit, was yes, because there is something special about being able to stand up in front of a jury of peers and tell them your client's story. It's the face-to-face interaction, the real person interaction, and real time communicating to them what has gone wrong, why it happened, and what can be done about it now. So, that is something that I wanted to do as well, similarly to how my family before me have done it. And I'm blessed to have ex-selementors that can assist me. And I have big shoes to fill, let's just say that. So, again, I'm blessed and very fortunate to have the mentors that I do and I genuinely enjoy what I do very, very much. Yeah, I remember a couple of years ago, your father, Mark Avera, sent me a handwritten note. I met him one time at a networking event, and then I get this handwritten note from him to my office on his personal letterhead, and I was like, "That is so sweet and thoughtful." You never get those anymore. What was it like growing up as the child, you know, trial laws, the family business? What was it like growing up from a child's perspective watching their, your father, you know, litigate these personal injury cases and be a well-known trial lawyer? Candidly, I don't think I had a great appreciation for it until I got a little bit older because it was just, that's what dad does. And it wasn't until probably that I got into my high school years where I really understood what that meant and started, you know, working at the office as a file clerk a little bit and starting to get my toes in the water and understand the gravity of some of these cases and what he was doing for people. So that perspective of, you know, switching from a child's watching their dad do their job into being a professional and trying to walk a similar path as he has, and he is. It's been interesting and I think it has helped me as a young lawyer have a really good understanding and appreciation for not only what he does and what it means to be a trial lawyer but the amount of work that goes into it to be really good at what you do. It's not something that you cannot fully commit to. It requires for every single case a full commitment not only to your client, the facts, the importance of that I don't think can can be understated, that that personal connection because that's what you need to be able to effectively tell their story. I agree with you completely. I didn't realize that your grandmother is a judge. Where was she a judge? She was a judge in Kasimi for for quite a long time. She's retired now but she was in out in Kasimi and in Orange County. Okay. Was she doing circus civil or was she? She rotated. She did some family, her criminal, she said her most rewarding work was probably the dependency cases and handling adoptions. Is that something that you ever want to do is to be on that side of the bench? Was that a desire you have? I mean never say never but I don't think so. Okay. Yeah. I feel like you have a dead demeanor for it. I've watched you in many hearings and we've done cases together and you kind of just like you just explain you're very kind of methodical and you I can tell you think through things in an orderly fashion and in going through this docket. It was really helpful this Osteen case. You know you guys are not leaving stones unturned and you just look at some dockets. I mean the docket tells the story. You guys are filing things every single month. There's so many docket entries. They don't give you the discovery. You filed motion to compel. Right. You you're not you know like you said kind of halfway doing this. You're fully committing and it showed in the results you got from a sostein. So you grew up in Gainesville did you what high school did you go to? I went to PK Young. Okay. Okay PK Young and then the obvious choice for college right. Yeah growing up in Gainesville you are I don't want to say required but it'd be really unusual if you weren't a Gators fan and given how excellent the university is that made sense to to go there and PK was kind of nice because it offered a great opportunity where I could actually start attending UF when I was 16. So I did that. So by the time I graduated high school and applied to actually attend UF as an incoming freshman I had almost completed my freshman and sophomore years of college technically. Wow. Did - Did you graduate early? - I did. - Okay, okay, how old were you when you graduated? - I was 20, I believe. - Wow, so you graduated college before you could legally buy alcohol? - Yes. - That's helpful. - Now graduated, let me see. I think it was December, my birthday was in April. - Okay, wow. And then you went to law school, so you went to law school at Stetson. I have many people in my circle, Blaine McCarthy, Dan Drake, Aaron Watson. I know a lot of people who've gone to Stetson and loved it. - And I genuinely can say I did. I, and I don't think very many people can say that they really enjoyed law school, but I did, it was a great experience. And I think their classes and the way that they teach them helps set you up, especially for trial, to be a trial attorney. - So what year did you graduate from Stetson? - 2018. - During the summers and things like this, were you always interning and summering at Ayrin Smith? - No, I, so I took a year off in between undergrad at UF and going to Stetson to work at a law firm in downtown St. Pete. It was a PI firm as well, but they did a lot of tobacco litigation, which is what we do as well. We're actually in trial right now on our very last tobacco case. - Oh really? Wow. - It's been something that we have been trying since I was in middle school. So we've been a long, almost 20 year road of us trying those cases. But during the summers at Stetson, I primarily went return to that firm to clerk for them over the summers. - Okay, and what was the thought of that just to kind of, you know, learn from, you know, diverse number of attorneys in different places and firms? - Yep, to work in an area of law that I knew within a high degree of probability I was gonna practice. - Yeah. - And just to have some different mentors. So people who were doing similar things at a similar level, but to have those different teachers 'cause you learned something new from everyone. There might be something that my dad does one way and Rod Smith does another and I can kind of pick and choose to make my own style. How long have you father and Rod been partners in Lance? - I was in middle school and it was around the time that Rod was running for governor. - Oh, that's right. - Yes. - That's so exciting. - It was. - Yeah. - And gosh, I don't know when that would have been. Back in the probably mid to late 2000s. - And your dad and Lance and Rod were partners at the time of Rod, I've never met him before. So hopefully it's not disrespectful just using his first name. But by the time he was running for governor while being a partner at the firm. - I believe so. I think I was in maybe six or seven. - Sure, yeah, you would. - At the point, but yes, I believe that partnership had developed shortly before he was making his run for governor. - Okay. We have to talk about Gatla because you're the current president of that. And I think we're going to Tallahassee next week. If I got the calendar right. What's going on with Gatla? How do you see it moving forward in terms of the plan for helping out injured folks in Gainesville? I know you started on the board of FJ too. Do you talk a little bit about why you spend your time doing those things? And what your goal is in volunteering your time for those bigger scale projects? - I have found it is so important for people in our field to talk and communicate because what one person does really well or a victory that they have and maybe a great order that's issued is a blessing when you're facing the same issue. And you can have that support and that advice and guidance from somebody who has already done it and has done it quite well. So fostering that sense of community and education, I think most importantly, among local lawyers, not only just here in Gainesville, but with a board of justice association around the state is invaluable and contributing to that and being on the receiving end of it. I can't recommend it enough and part of what I would like to see happen with Gatla. And we're working on coordinating some things for this spring for additional educational, CLE is our meetings among the group is for that 'cause there might be little niche areas of personal injury where maybe somebody isn't as well versed as someone else and that can help fill those gaps and build this up as a community generally in the area. - Yeah, speaking of those niche areas, I know that one of the things Gatla's been working on kind of behind the scenes is the changing the admin order or just seeking a change in the admin order in a lot of accounting. You wanna talk a little bit about that, calls and what's going on there? - Yes, so I have had the opportunity to represent multiple minor plaintiffs and whenever you have a minor that has a settlement that meets a certain threshold, there are certain steps that you have to take, getting court approval, potentially setting up a guardianship, depending on does the child have certain, needs either financial or medical, but a way that we have tried to structure some settlement agreements most often is to put the funds for the child in a structured annuity. That way, if it's a three year old injured child, five year old injured child, that money is making them money. So by the time they reach adulthood, they hopefully have a significantly larger return to them from their settlement than they would have if those funds were used or dispersed through just a standard guardianship. Where things have gotten a little tricky and I think it drags the process out and I understand the intent behind it because it is to protect the minor, to make sure their funds can't be used and appropriately by either a guardian, a parent, or anyone else who might have access to the funds. So appreciating that intent, but when you put the funds into a structured annuity and with how the court doesn't move off in the not with specific provisions for this cannot be accessed and if it is to be accessed, it requires coming before this court in an order of being entered. So it alleviates that concern that the funds can be used inappropriately or accessed by someone who shouldn't. But what ends up happening is if the requirement is that the guardianship be opened and more specifically maintained. So it is required for every year for there to be an accounting filed. If a professional guardian ad lightem has to be hired and fortunate that there are attorneys including yourself and in the circuit who are willing to serve on a pro-say or willing to volunteer their time to do it, but if that's not the case, then these funds are being used on a yearly basis for the payment for this filing of the annual accounting and the essentially maintenance of the guardianship. So when all that's happening really is a renewed filing of these funds are still in the annuity and it is the exact same document year after year after year with essentially just the date changing. So the question becomes, is it the best use of the minor's resources to approach it this way in this specific instance when the funds are in an annuity and for all intents and purposes untouchable? - Sure, and this is I think the value behind Gatla you were looking to earlier is, what we just discussed for people who are listening who haven't done per injury work for children where the growth at Mount is over 15K in Florida, which is when it triggers the mechanisms to protect the funds of the child. You're like, what are they talking about? But it really, I think the heart behind that initiative is, look, we've identified this little area that we believe has some waste, which is sort of this annual accounting guardianship being set up that what we believe is not actually necessary to protect the needs of the child and through the organization that you're president of, Gatla, FJA, it's not, FJA as a whole can't focus in on administrative orders and specific jurisdictions. So that's why I believe the work that you guys are doing through Gatla is so important, so we can improve not through ordinances, not through statutes but just through administrative orders, improve the civil rights for children in a lachua county and this judicial circuit. So I am a nerd about that, but we'll move on because we're here to talk about this trial you guys had which was super interesting. I have two questions to kick that off. Before I do actually, I wanna ask this, you tried this case with Jennifer Lester, right? - I did, yes. For those of you who don't know who just. Jennifer Lester is, can you give her a quick shout out and inform our listeners about Jennifer? - Jennifer joined our firm fairly recently and she is an incredible trial attorney. For quite a long time, she worked on the other side of the fence to doing defense work, which I think has really added to what we do here since she has the perspective from the other side, having done that for so long. She has done countless things here in our circuit for the benefit of our circuit and then the state at large. She is one of the teachers, almost I believe every year, at least every year since that she's been here that I'm aware of, teaching the trial college at UF every year, which affords attorneys who attend a full trial credit. Which has extremely beneficial. And it has been, I will say, very, I consider myself very fortunate to have the opportunity to be mentored by her, not to say, not to say my dad and uncle and Rod who are all wonderful mentors, but to have the opportunity to have a female mentor, a female trial attorney has been really, really wonderful. And I can't express my appreciation enough for the opportunity that we have with this most recent trial, going through the steps with her and working with her and her showing me how to do certain things, the way that she would like them done, or maybe how to do them a little bit better tweaking what I had essentially already known or intended to present, which I think if you don't think you can learn something, you're wrong. There's always something to learn. So she's a wonderful trial attorney and I'm quite lucky, and we are quite lucky to have her here practicing with us. Absolutely. She's got a great reputation in the Gainesville area and beyond. I've handled several cases with her, even on opposite sides, and she's very talented. So that was a good trial partner that you had in this case. So two questions. Who is Amy Osteen and can you take us on premises with Amy Osteen on September 11th, 2020, when she's walking up the stairs at the Oak Small Plaza? Miss Osteen was a truly wonderful client. She was in her, I believe her late 40s, at the time this happened back in September of 2020, which having to shift back to remember what September of 2020 looked like, 'cause we were in the midst of COVID. And she was a nurse, specifically VA. She was part of the state's COVID rapid response teams or she would bop around the hospitals, around the state to try to fill nursing vacancies because there just weren't enough nurses. And on the state in question, she was going to patronize a scrub store that was located on the second floor of the plaza. And she tried to take the elevator, but it was out of commission, it wasn't working. So she went to the next staircase and made it up the first flight of stairs fine. Turn the landing and it's, these stairs are kind of outside, but the landing itself is covered in its brick, so it's quite dark within the staircase. Turn to go up the second flight of stairs and almost made it to the top when the last five to six steps at the top coming down. They had started to have pretty significant concrete deterioration where the stair tread, which is what you actually step on and put your foot on, separating from the riser, which is the vertical bit of concrete that goes up in between the tread and you have to clear your foot over that to step on the next tread. Where the lip of that, where those meat were separating and creating a gap. So looking at it, as she was from the base of the landing, we do have a photo and you cannot see these cracks in the staircase. You really can't see them until you were right on top of them. And if you are looking up, which in this instance would be looking up towards the light, so you have a glare coming in. This is something we kind of touch on at trial as well, but if you're a female traveling up a staircase, you're usually not, especially if it's enclosed, you're paying attention to what is around you, either behind or in front of you, rather than looking down. So she didn't see this, her shoe got wedged in the crack of that stair and it pitched her forward. So she fell forward, but the stair essentially held on to her foot back there. So she was almost immediately, well, not almost immediately felt a tear or a pop in her hip. - Oh, as a nurse too, you're on your feet so much. - And that really became a problem for her. And something that we dealt with at trial is she did not immediately seek treatment. So essentially it was, listen, I was scraped up because she fell on her essentially braced with her hands, elbows, her hands, elbows, forearms were scraped up and bleeding, she had some bruises, but she essentially said, "Listen, I'm a nurse and I knew I was gonna be sore, I patched myself up and expected to be sore for a while after this, but it is when it started to progress and to shift back really quick, the defense took, made this big issue of, well, if you were so badly hurt, you know, why didn't you call an ambulance and why didn't you immediately go to the emergency room? - Yeah. - With the response being, I'm a nurse, so I knew this wasn't, I could take care of this at least initially. Medical personnel are already stretched very thin, so I wasn't gonna call an ambulance when that might be needed much more somewhere else. And the emergency departments in these hospitals are overwhelmed under staffed and COVID is rampant. - Right. - So I wasn't trying to walk into that environment immediately. - Sure. - But it was when she, you know, two, three weeks passed and instead of getting better, she's getting worse. And as you mentioned, being a nurse, being on your feet all the time, it was starting to affect her mobility at work. - Oh yeah. - That she sought treatment and things progressed from there. - Wow, so you've got this nurse in her mid-40s around there during COVID, September, so it's probably hot. Walking up this second flight of these concrete stairs, towards the top of those stairs. - Correct. - Correct. - Okay. - There was a crack in the concrete of the stair tread or a riser where those meet, where the nose cone would typically be, if they had nose cones on the treads. - That's exactly it. - It's so big, it grabs her like a claw and you know, her flip flop gets stuck in it and then rather than being able to move that foot upward to climb the stair, she then falls forward on her hands and wrists and hits her hip on the stair. - That's a great summary, yes. - Okay. And then does she, so she was going to get scrubs. And for those of you who don't, you haven't seen the pictures and stuff, this is like a dilapidated, sorry for the offense to the defense of the listeners, but this is dilapidated, strip mall, essentially next to the oak mall and off of university and Gainesville, right? - Off of Newbury Road here in Gainesville. - That's right, off of Newbury Road. And it's kind of like behind the Starbucks over there, it's not oak small, it's oak small plaza next to oak small. - Yes. - Got it. And she's going to get scrubs, does she continue and go buy the scrubs and go about her day? - She doesn't, she goes into the store and say, hey, let's him know that she just fell, asked to use the restroom to wash up, wash her hands and they basically told her we're not letting anyone use the bathrooms right now, other than employees because COVID. - Oh gosh. - But here's some hand sanitizer and she's like, well, I didn't really want to use that 'cause I have open wounds on my hands and forearms, so she left and went home at that point. - And the elevator's broken, so she wasn't able to take the elevator up. - No, she had to take the stairs back down, which she said she did very carefully and that it was at that point extremely painful and she still shaken up from the fall itself, so it took her quite some time to make it back down to her car. - What were her injuries? - So she had an injury to her lower back. She had some discreneations, but the principal injury and the one that she received the most aggressive and substantial treatment for was to her right hip. So that issue was really a, laparimitar, that progressively became worse over time. So typically with that, they don't jump right into getting an MRI for imaging. They usually try some physical therapy at first. And if that is an effective, they proceed with getting that imaging. There's a tear. Well, what now? Some options for conservative management, for surgical treatment. She's so young and her job was physical. So she worked at the VA on their essentially like surgical rehab for solving veterans who had either undergone, she cared for some stroke patients, patients who had received amputations. So it was a physical job on her part. So once you have that tear, it really, it doesn't heal itself. It's not going to get better. So the election was made for surgical management. That helped for a time. But as can happen, it's a known risk of the procedure. The tear, the repair can fail, which is what happened, unfortunately. So a second procedure followed. Oh, man. Yes. And then eventually it reached the point where because of all of these procedures, the department she had received to her lab room. Upwards of like 50% of it ended up being removed. So fast forward a little bit. We are, you know, set for trial. The first time we were set for trial in August of 2024 and turning the corner of that year in January. She had been undergoing treatment for all of this time. Her hip had deteriorated so much. The arthritis had set in an impregnest to wear her orthopedic surgeon who had been managing her since 2022 had the conversation with her of listen. I think it's time the only option, essentially available now, besides conservative management, which she failed. She tried physical therapy. She tried steroid injections would be a total hip replacement. And she's a nurse. So she understands the importance of that home exercise and she does a total hip replacement and being told that in your early 50s is a shock to say the least. I mean, you hear about hip replacements and wore off in the nod. You associate that generally with the elderly, either because of fall or you've just, you've lived so long and your joints are worn. You expect to hear that more maybe 60, 70s or around, you know, that age. But just having turned into her 50s because she was in her 40s when this happened. Sure. Is definitely not something that was on her radar when she started to climb those stairs back in September of 2020. So we filed a motion to have the trial continued because this was going to change our whole expert lineup, expert testimony. It was going to change the dynamic of the case, the seditional treatment. Because as far as we have come in medicine, there is an extent to what it can do. Sure. And with implants, they typically last 20, 25 years. Yeah. Which would put her and her young to mid 70s needing another hip replacement. So that had to be taken into account. We had to get a life care planner to be able to discuss that and forecast what that would mean, you know, 20, 25 years down the road. Because it's not just that it's going to be probably end home nursing because she's going to be elderly at that point. Right. Physical therapy to rehab it, follow up appointments appointments between now, because she has an implant at her 70s. I mean, just the treatment that she was going to need compounded so quickly as it progressed. And when we initially took this case on and infiled the case, we had no idea what it was going to evolve into. Yeah. People think it's a litigious society. You know, you fall out of place of business and you just, it's America. So you sue, you want a quick buck. But I mean, this, the amount of just inconvenience, just alone, just inconvenience that missed Osteen has gone through from this, you know, needless negligence. I mean, I took, I looked at a picture of the stairs and they are outrageous. I mean, they're literally crumbling. It's like in the, the mummy movies or so. It's like it's like they're crumbling before your eyes. No. Yeah. And part of that was we took the property manager's deposition before we added them in formally as a party defendant. And the testimony we got from that was repeated frequently, both in motions and at trial because the property manager essentially was like this place was in really poor condition. The stairs, you know, were essentially following a part. This was a problem. This was a problem. This was a problem. And my attempts at communicating that just went on answered. Which at trial, they tried to kind of back out of that position where the deposition transcript came really handy. The impeachment. I think it was well received by the jury to say the least the truth is so inconvenience sometimes. It really is. So let's talk about the litigation. I mean, this is like the quintessential premises case because you're looking at the docket. I mean, you went through so many of the common issues that everyone who's a practitioner or works at a firm goes through in premises cases like, you know, no one who to sue, amending the complaint when you find out that there's a different entity like when you have a commercial property, there's so many hands in that and everyone is passing the buck to everyone else. So you file suit March 9, 2023. And then you serve a PFS. I'm interested in this. You serve a PFS on September 19, 2023. And then again, November 1, 2023. I've talked to you before about PFS and how your firm handles those. What's your strategy behind, you know, doing that? You know, do you do that after some negotiations? Like you file it, you know, two of them. So did you change the number? Just tell us how you think about the PFS is in these cases. Yeah. We, we changed the number and how we did it because we did have some before we filed on this, we did attempt some pre-suit negotiations, you know, demand back and forth with the adjuster. Needless to say, we evaluated the case quite differently than they did. Considering we ended up going to trial on it several years later. But yes, especially, well, really in all cases, on the 91st day after that complaint has been served. I want to file a proposal for settlement. Wow. It's aggressive. Yeah. Question is for the amount. And in this case, the first one we did policy limits, giving them another chance. Sure. That we had offered pre-suit as well. And then when that 30 days ran and it was just that they never responded. So deemed projected. We file the second one for lesser amount that the client's sold have been happy with. If they had paid. So setting it up or not setting it up. I don't want to phrase it that way, but making it to where if we were to go to trial, but not be able to beat the policy limit plus the 25% that we would need. We had that secondary proposal for settlement for the lesser amount as the backup, because they're both still effective. Hmm. Filing of multiple doesn't cancel out the previously filed. Okay. Interest. So even if you don't get an offer or counteroffered to your PFS, your first BFS, you still then file a second BFS for a drop dead amount to lock them in. Not always, but in this situation, we did. Okay. So let's back up real quick so it went to filing suit. Who did you sue and what were their roles? So this actually ended up there. I had to do quite a bit of legwork and fieldwork trying to figure out who owned this place because it traded hands so many times. And if you would go there, there'd be one, you know, sign up. But what I would find online would be different. So essentially went on property appraisers to try to track down who owned it and when. And we initially filed because we weren't sure even with that because of the documents on the property and how it was still showing listed in other places. Sure. sued the J.R. defendants because there's J.R. Lawrenceville and J.R. investments who owned it. One was a majority owner. The other was a minority owner and we also sued a property management company that ended up having nothing to do with it. They let us know pretty quick. And we moved on. But then the question became, well, if not you, then who? Because there's someone and one of the really big problems we had in this case and why it took so long to pinpoint who is it? Who is. responsible for this property other than the owner, who's your management company, is everything that we sent went unanswered. So we sent our typical request for insurance disclosure letters by certified mail, and this is, we also sent a preservation letter. Very early on before we filed suit, like as soon as, essentially, the case crossed the desk for the stairs to be preserved, so we could have the opportunity if they were going to have them fixed to have an expert go out and do all the work that would normally be done in a permissive liability case. But I want to answer it. So every month for three months, we sent a letter saying, we know that they were getting them because we were getting the signed return receipts back. Right. Throughout this process, I found a property management company that might have been the property manager. So we kind of just, I did a Hail Mary and just started sending, you know, them insurance request disclosures and preservation letters and the whole thing. And again, it goes on answer to the last letter that we send. It's, we are going to unilaterally schedule an inspection. If we do not hear from you within 15 days, and this kind of kicks off what I think was like the overarching theme of the case, which was the spillation of evidence. When they got that letter, then they had the stairs fixed. They didn't tell us. But when we went out there to do our inspection with our expert who, you know, came in from out of town and the whole thing, the stairs had been repaired. Yeah. So that was an unpleasant surprise. Sure. But we knew that they had gotten our preservation letters and essentially just decided to completely disregard them and then make the decision of, oh no, they're going to send someone out here to look at these. We can't really ignore this anymore. So let's get it fixed really quick before this becomes a problem, which then became quite a significant problem for them. Once we got into litigation and started doing additional discovery and motions to compel and motions for sanctions and spillation, it really snowballed. Yeah. It certainly did. And to your client's advantage. I'm looking at, so you filed on those backups. So the two defendants are JR Lawrenceville and then essentially a shell company for JR, the same dude or woman, whoever kind of played some games and has it owned by two entities and did they live in Gainesville? This is the owner living Gainesville? No, they are based in California. Unfortunately, that's common in Gainesville and other places where these people, private equity, money, treats these properties as banks essentially and doesn't care what they look like, doesn't care who gets hurt on them just wants the return on their investment, no matter if the check for that return is written in blood or not. And so, and then they don't respond as you and I both see and you and I both have judgments against defendants who just don't participate. So on June, in June, 2024, you filed a motion for expolliation. June, 26, 2024, you felt a expolliation motion to strike the pleadings, get a default on judgment on liability. You go through the timeline in that motion, you know, 227, they received a preservation letter. You put a screenshot from the Google Street view of, hey, this is where it happened. I wanted to make sure there was going to be no question, no wiggle room that we were talking about anywhere else, other than that staircase and that did come in handy later on. Yeah. And then so you filed that and you filed that the same day if I'm remembering from a docket correctly that you guys got an order or you filed a motion to continue because of the surgery issues you mentioned earlier, because you want to make sure that Miss Osteen doesn't get a smaller judgment and then have bigger damages after her one chance has passed. And I liked how sorry, I'm popcorn around a little bit. I liked how on your original expert witness disclosure on March 6, that you filed, you filed a disclosure, you know, you had a lever, you had your liability expert. And then the same day you also the same time filed a motion for extension at time to disclose. And then you laid out your case for why you need an extension of time. And I just like that because I just felt that, you know, you maybe could have just filed motion for extension or whatever, but I liked that you showed the defense that, you know, we're going to spend money, we've hired these people, you know, we're buttoned up even if the court doesn't allow us to continue once we're ready to go. So I liked that. And then you filed a motion on the June motion for spuliation. And then it was set for hearing in October of 2024. I hate to see that. Yeah, that's just I think especially post COVID with the courts trying to catch up on their dockets. It was just an unfortunate reality that we struggled to get hearing time. Yeah, they have good. I deal with it all the time myself. So they wait until so you filed yours in June, they wait till September to file their opposition of this main issue of the case to explain why they shouldn't get a judgment against them on the issue of liability. And I was trying to, I thought I saw this somewhere in here. Do they say in here when the stairs were actually so we did not find that out until I want to say it wasn't at this hearing. It was potentially following a second motion to compel because when they responded to this, they ultimately ended up responding under the court's order. Who fixed the stairs and when answer unknown? I mean, you're going to have to know you own the property. So somebody came out there at your request to do this work and presumably they're not doing it for free. They're going to be paid. So there's a paper trail somewhere for all of that. So we came back before the judge. And then that order was entered finding out that they had them fixed in the early part. I believe in June. We sent preservation letters and follow ups, February, March, April, end of April. I think it was like April 30th or something. We sent this last letter of, hey, we don't hear from you. Then 15 days we're sending somebody out working on scheduling that. And as much as I wish we could get an expert as soon as you know, out tomorrow at the end of that 15 days, they were a little backed up. So it took them a little bit to get out there. But pretty much at the cusp of then they had already taken steps, contacted somebody to have the stairs repaired and did it without saying anything about it. And then withheld that evidence from us for gosh, I think it ended up taking if not close to a year a little bit more than that to find out who did it and when. Yeah. It blew, blue color maintenance. Like I love the way that this was put in. Look, there's no ill will towards any defense lawyers at all. That's a hard job. But it says based on information and documents, it has recently been, it has been recently learned that the stairs were repaired in June of 2021 by blue color maintenance. It's like, like you said, four preservation letters, no response. You've been litigating at this point. And what is this September, 2024? You've been litigating since March, 2023. If I'm not mistaken. Yes, that's correct. Yeah. So, I mean, what is that like a year and a half? And it's been recently learned that they were repaired. Like it's so such a passive framing. It's like, go have the owner not know. And it's information that because this was back before the rule change with initial disclosures, so we could serve discovery with the complaint. Yeah. One of the first questions we asked, when were the stairs fixed? Who did it? And it took the better part until, like as you read it, and two different hearings before the court for them to finally give us that tidbit of information. So I'm looking back to, I mean, the reason why you got the result you did, I think, is because of the work you put in so early with those preservation letters. And just making sure that they were put on notice, not to repair it. I was looking at the RFAs. I really like the RFAs you guys sent. And this was interesting to me. In RFA2, they admitted that they had noticed in September, 2020 that the stairs were in need of repair, but were without knowledge as to quote the type of pairs we needed that were needed. How did they have this notice? Did they ever explain that? Like what the, the notice was? That the stairs needed to be repaired. Yeah, they admitted that. early in the litigation. So that came from the property manager and her deposition testimony. So we found out that this corporate entity had acquired the property. I believe it was in June or July of 2020. So a couple of months before this incident occurred. And the property manager had been the manager of the property prior to their purchasing of it. So they had a longer history with it and made them aware of, hey, these are the problems. And we later learned did a walkthrough of the property with the owner. So we got in deposition testimony that they walked these stairs. I knew it was a problem. She sent him a list of things that needed to be fixed, which was like one of the bullet points was concrete repairs to the stairs, fix the lighting and the stairwell. Yeah, so that is how we argued, like he knew that this was a problem well before this incident happened. And here we are. This was something that was known, nothing done about it, and unfortunately our client paid the price of that. She did the form of three surgeries to the hip and a future surgery. In an RFA 9, I thought this was interesting. They said that they were without knowledge to admit or deny if they authorized repair to the stairs. Yeah, so later on, we ended up filing a motion for sanctions for failure to admit the truth of the matter based off of some other responses to this request for admissions. Yeah, you got I love that because really, I mean, there's two ways to do discovery, like as a plane, if like you just send the RFPs, they give bogus objections and you move on and you try the case not in the evidence, but you guys really, you're like, no, this was not a good response. You didn't provide the evidence. These contradict each other. We're going to file a motion and we're going to hold your feet in the fire. That is pretty much it. And it just kind of progressively became more and more frustrating as we continue to file things and get these responses back because you knew, you have to know there's this exists somewhere. Why isn't it being produced? I will say I think this was more a client issue than defense council issues. I know that can be something that has run into from time to time. I think there was just cooperation issues on that they had on their end with their client producing things that he had or knew of. Sure, this is what I gather is a very wealthy individual who lives in California. I think that would be correct. So it's kind of interesting, the chess game of this because in their response to your spoliation motion and we're kind of teeing this up, it's like dramatic, long litigation, hard fought up to the day of trial. I want to get into and go with you and Jennifer there. I mean, it's got to be so exciting after having all this big pressure, keg of these evidentiary issues and you walk in the courthouse. But they have to kind of argue, okay, we did destroy the evidence. We did mess up the evidence. But the plaintiff has the pictures. Their expert has said the pictures show code violations. They basically have to say that the plaintiff can prove negligence. But at the same time, we're going to argue they can't prove negligence. That became really interesting. And so they filed our client had taken a handful of photos of the stairs. They were not very good. They were blurry because she's hurt and we had to know. And we had photos, some limited photos taken in like the days that followed her fall from a visit back out to the scene just to try to figure out where this happened and did some better quality ones, but not photos taken for the purpose of this being the exclusive evidence that could be used at trial and review for an expert. So when our expert disclosure has came around, they filed a motion to strike our engineering expert because he did not go out to the scene and take any measurements, review the evidence as it was and just relied on photographs. That's crazy. When I say I had a field day writing the response to that motion, it's been a while since I've had so much fun doing over apply because of just how absurd it was. We've been before the court now, twice, on motions to compel for this issue. This is the sole evidence. The court withheld ruling on the sphulliation issue saying, "If your expert can review these photos and come to some kind of an opinion that is going to determine essentially how I view this and what remedy I might grant." So when we got back before the judge on this, it was like, are you serious? Because you can't have your cake and eat it too. I mean, you were the reason that their expert can't go out there and review the stairs, which was fun because when we took their engineering expert step as aion, he went out there and inspected the stairs and did all this and generated this massive invoice to say, you know, we went out there and we did it, but they had already fixed it. So there wasn't really any point to this didn't tell me anything. Yeah. So, full of one more issue into it all. Yeah, it gives like a picture of worth a thousand words, you know, but the real thing is what your entitlement to and what you asked for and what they were responsible for. So. Right. And it's a picture of worth a thousand words, but it's not worth a whole bunch of numbers, which is what you need for these code violations. Yeah. You need math here, which was the important part that we were missing because a lot of it could not be determined from incredibly blurry and dark photographs. Absolutely. Yeah. So I'm sufficiently, you know, on the edge of my seat, I'm viewing the defendant as, you know, someone who's not been participating, you've been holding their feet to the fire, slugging it out, the clients got more surgery. It's continued. Now I'm ready to go with you in Jennifer. I wish I was there. Did you guys? So when was this trial? Sorry. I don't have that in front of me. It was in July of 25. Okay. So it's hot beginning or end of July beginning. Oh, you know, always have it around July four. This the weirdest thing. They do. They do it. I thought the July holiday was like the Saturday or Sunday before we started trial on Monday. Yeah. So you and Jennifer, like bosses are rolling up behind. Do you go in the back entrance of the courthouse? Yes. Okay. And do you bring a trial team with you to help? We do. Yeah. So our our paralegals, we have somebody helping us with the tech. Just to make sure all the exhibits that we want go smoothly. So there were definitely more than just me and Jennifer working and helping behind the scenes. Oh, and hold on. I think we missed so but the Friday before that, you'd got some additional documents, right? Yes. So I think it was the Thursday before trial set to start on Monday late at night, around like eight o'clock, get an email from their lead trial counsel saying, you know, essentially, hey, I just got this information and here it is. So at the 11th hour before trial, where we're going into a holiday weekend, where we essentially have a limited number of hours to create a response and file it before the court closes 5 p.m. on a Friday. Sure. Off for a holiday weekend. Right. So at that point, I think it was this issue had been revisited so many times, but it was a emergency amended, updated, and renewed motion to strike pleadings and affirmative defenses on the issue of liability and request in the alternative, a adjure instruction for either a burden shifting presumption or an adverse inference. Because if you're like it like me, there was no possibility you were going to allow a continuance for this. No, no. They asked for it. They asked for it at the pretrial hearing. And that was not well received. Okay. So you've got this. You've printed those out. You're walking in and for those of listening who haven't tried a case in Latvia County, kind of just take us with you kind of in the court house. What court room were you in? What was the vibe like? What was jury selection? Just kind of take us let us live that through through you and Jennifer. So we're in courtroom for a, which is the larger courtroom in the civil courthouse. Jennifer principally handled jury selection, which we kind of view in some ways as jury deselection. And a lot of strong opinions. We almost didn't get a panel. Yes, it became very close by like a hair that we weren't going to have enough jurors to be able to see the jury. Why? There were just so many people with such strong opinions about tripping fall cases that these people are money grabbers. They're essentially before we even started. They heard any evidence. We were starting well behind the starting line from the defense. You guys did a really good job then in jury selection finding those folks. Yes, Jennifer did a really wonderful job of it was I mean cause, cause, cause, cause. People are just being excused left and right. To where eventually we have a jury. Unfortunately in a lot of county it's I think a bit interesting because we have a lot of healthcare workers who make up the population with UF Health Shans and HCA in North Florida. To where we had some medical professionals on our jury. Good. So you get the seven. You sound like you have a really successful sort of jury selection process there. Get all the tour formers off and who you guys do openings after lunch? No, I think we ended up doing them the next day because it took so there was the issues and it was taking so long and people were just constantly being stricken for cause that the judge couldn't I think correctly limit our time to do that because it was such a reoccurrent issue when we weren't waiting into topics in the questioning of the jury that weren't relevant. I mean they were directly to the heart of the issue and people just had really strong opinions. And it's one of those times where you learn if you have nothing nice to say don't say it at all. I want to hear that put that aside because I want to hear everything nasty or anything that you might have not nasty but controversial or that you disagree with me in relation to the topics. That's the only way we can see a jury who's hopefully unbiased. So for anyone listening who's not an attorney it's not that their panel was in my opinion was more biased than other panels. They just did a good job of drawing out like you said, like hurt my feelings, drawing that out so you don't have those spokes on your jury and not know that they hate your clients case. And I kind of like that good on judge kind of judge kind. Yes, she was our trial judge. I really like her and good on her for allowing you guys that time to get a fair jury for both sides. And I kind of like that you got to do openings fresh the next morning when the jurors had you know kind of kind of locked in had some sleep like did you do opening? Yes, yeah, I handled opening Jennifer would have handled closing and we had a split between the witnesses. Okay, so you do opening how long was your opening? It's about 45 minutes. Do you do PowerPoint? We do. So we had some evidence that we agreed on beforehand with the defense so we had combined exhibits that we could pull from some of which included the photographs that the new ones. No, not the new ones. The ones taken by the client. So we had an agreed set of exhibits wasn't terribly many. Some photos like her medical records medical bills, but there were some things I wanted them to see as part of the opening and we admitted those at the outset of the case, not in the presence of the jury. So those could be used by both sides and opening if they so chose. What did Judge Kine say? Because you got to show up before jury selection kind of like just meet with a judge and that you know, whatever and did you hear like, Hey, we just got these photos and what did she do with them? She didn't immediately rule on it because she wanted to take it under advisement. She wanted us to provide the proposed jury instructions and something that became an issue was she's like, guys, the jury's waiting for us. Motion should have been filed. You know, there's a in the pre-trail order, a deadline to file motions and have them heard. Our response to that is your honor. Yes, but we just got this Wednesday evening or Thursday evening to where this is something that we really need to have heard because of how recently this was filed and this is a major issue in the case. So we carved out some hearing time, I think during a lunch break, maybe where we sent the jurors to lunch, not Tuesday, but Wednesday, which is around the time where we were going to rest our case and the defense was going to pick up theirs. That's a short case. I like that. Sounds efficient. And did you mention those late disclosures in your opening at all? We didn't because we really wanted to because she hadn't ruled on it. We wanted to avoid any potential of there being any kind of a pellet issue. And to, I don't know about you, but I like to prepare, like really prepare for an opening and, you know, like write it out. I don't read it. I'm sure you don't either, but that's something that you kind of really put a lot of time into getting read, right? And so I don't know about you, but I don't want any possibility of the opposing council standing up and objecting or the judge heavens forbid, getting in some kind of trouble during the opening, you know, I don't know if you feel the same way or not. No, and we just wanted to keep it as clean as we could and remove any possibility of this popping up and being a sticking point for an appeal because that if it does get bumped up to the first TCA, it could be, you know, 18 months would be, I think, a realistic expectation maybe before you hear something back or get a decision to where we didn't think we really needed it because the testimony from the property manager that we laid into quite happily in my opening of she said this, this is what they knew as early as, you know, three months before this happened to where we knew the jury was going to learn about it eventually because the judge, we felt pretty confident at that point was going to give some kind of instruction. It's just what kind to where they would know about it without me having to say it and potentially cause an issue. Yeah, you don't have to tell tale. It's going to come out. I mean, it's, you have a strong enough case, just alone. What was the property manager a defendant at trial? Yes, but there was some kind of shifting where we came to an agreement with the defense where they would essentially subsume responsibility for the property manager and so she wasn't an individual defendant at that point at trial. Yeah, so you guys stick to that. Yes. And dismiss their wait off her shoulders. Yes. Sure. So before trial, you told me before the podcast, you got like some nominal, like low, low offers that just wouldn't compensate Mrs. Teen for her, her hip. Correct. Okay. So you were there. I mean, I love trial. I love trial. I'm like really enjoying enjoying this. So you're like, yeah, this is the long trial jury selection. You've got this new evidence. Such a crime is like, you know, should have filed this for, but we just got the documents. On Wednesday, Thursday, you're in for a, you know, you give your opening. They give their opening is the man is a male or female who owns a building. Is it a male? Okay. So is he there in the court? He is there. Yes. Okay. So he's there. And how many lawyers do they have at their table? Two. Two lawyers. Then you and Jennifer at your table, Judge Cime and then the jury's over here. You picture openings and then who do you call first? If I recall correctly, we called the property manager and our case in chief. That's awesome. And as well as the property owner, we intended to call him, but we kind of, we played with that idea a little bit because I think we ended up calling him because they were not going to. They had said that they would, but we're kind of playing with the idea of not calling him. We very much wanted his testimony. Yeah. So then, you know, in addition to that, we had our treating physician who we played by video. We had recorded or zoom. That was recorded. Then we had an expert economist and we had a life care planner and our engineering expert who appeared in person. Our economist appeared by zoom and our life care planner also appeared in person. Then we had two before and after witnesses and then the client herself. Did she go last? She went second to last. We had to kind of do it. Usually that would be the preference, but just trying to accommodate schedules because we expected to do openings on Monday. Everything had to be shifted a little bit and to make sure we could accommodate our experts, we had to go a bit out of order. Okay. Cool. So did you finish up your case and chief on Tuesday? I think we finished it Wednesday morning if I recall correctly. I love that feeling. So then the defense put on there, obviously, they started their case and chief, how that go. They did. And they had some interesting experts, which there was one that we were really pumped up about the cross. Jennifer was going to do a cross of him and it would have been spectacular. I mean, one of those that you just want to sit there with a bucket of popcorn, I didn't yield. Right. Because of the amount of information that she found on him that he relied on, specifically literature. She went and bought the book. and read the book and was ready to just roast this man over some of the assumptions he made. But we get an email that I think it was Thursday morning at this point they weren't going to call them. I think they knew that we knew certain things about him. So they bring on their orthopedic surgeon expert who we had done a CME before and we'd recorded it and can't stress the importance enough of recording the CME because there's things he said and the CME that Chakr didn't make it into the report where he basically said yeah you're a candidate or a replacement basically agreeing with us in our whole position of the case. So his cross we think went really well. We were feeling like good about the case then they called the property owner. That was just I'll say dumpster fire because he starts throwing around the word insurance and now you know the the jury's clued in now that you know there's some policies in play here so around I think Tuesday the adjuster for the excess carrier or the attorney for the excess carrier started attending the trial. So saw was that rumberg or Kirk or what was that? You know and I don't remember they really didn't they didn't do anything in the case. Yeah you know we had them requested they attend mediation but outside of that they left everything to the underlying policy and in those lawyers but they started attending I don't know the afternoon of our case presentation and then we made it to two experts or one witness and an expert into their case and Jennifer and I are sitting at the table and we're in a brief recess and we get a tap on our shoulder from the excess attorney saying can we can we have a chat please and one thing like do another and the case resolved before it went back to the jury. Wow I love that that's a great tap to get. It was yes. So did you guys go out in the in the hallway obviously the confidential settlement communications but I just love this process I mean I'm just admiring it you like it makes me want to do a trial so bad because it's just you're just fighting and fighting and Jennifer reads the book and then they don't call them and like you're ready to go and you know they're order their cases and going well and the excess care is like okay that's enough let's pull the -- -- Stop the hitchhiking put the shovel down. -- Yeah exactly so so you guys went out and was the and if you can't discuss any of this let me know but the trial lawyer for the the defendant was he kind of involved in that or was it just kind of the excess carrier sort of cleaning up and yeah he was you know part of the conversations because there had been you know conversations and you know the week before trial and then things changed so substantially and then we have this pending motion on you know entering a default that's to liability so there was you know conversations were had but we were had really never changed our position of the case and what we felt it would be fairly valued at and then it was the the excess when they came in or just like listen this is what's gonna this is what's gonna happen I feel like that was a conversation they had between their side of things before we were approached and you know then the the details were hammered out. -- Was Miss Nostini pretty thrilled that day it means kind of be a big rush of different emotions for her. -- She was I think it was just a relief that because it had been going on for so long that there was some resolution because anytime you go to trial we have the conversation with the client of you know there could be an appeal and if there is an appeal this is what that process looks like so they know you know a lot of times people think you get the jury verdict back and then that said and there's you know a check in case closed where kind of the unfortunate reality is is a lot of times something can come up a trial you try to keep it as clean as it can but an appellate issue for the defense to hang their hat on where they can draw out the payment being made or the verdict being satisfied. -- If only we could do that with our bills right just a appeal them and damn for four years so in your opinion how has this case and this this result made gains bill safer? -- Well I think it has at least to the extent of that one specific location I mean and I'm sure you know this land and there's people who get hurt at residential commercial properties every day all the time so I'm not sure you know I wish I could say that it has this like greater impact but I think it's probably really just localized to that one specific plaza because the owner is out of state and it was like a locally owned or even a Florida you know company to own or manage it that maybe would be different but I think that's just the unfortunate reality with a lot of these large commercial property owners of do they care do they care enough to fix it and I think a lot of times the unfortunate reality is they look at they do a cost analysis is it worth it to fix it within the time frame to fix it in because what's the likelihood something's going to happen and they roll the dice. -- Until they get this you know giant traffic ticket for speeding right I do look at similar as speeding it's like you you know you fly too close to the sun and sometimes the wax melts like in I think that that's what I love about what we do and why I can't believe this is a real job is we're we're kind of like law enforcement I know your dad was a law enforcement before being a lawyer and it kind of feels like that we're like enforcing the codes. This is not meet the codes the for the you know a safe stairwell and so we are going to enforce those codes. --And I think it's to just enforcing accountability because if this whole process was just left between an injured person and an insurance company I think we both know how that would go. You know insurance companies are in the business of I would argue fairly paying claims they try to pay claims but to as less a degree as minimal of a degree as they possibly can that's how they stay in business and and make the kind of profits that they do to where I think we step in and fill that gap of no this is not going to work and here's why and here is what's fair here's an opportunity for you to do the right thing the balls in your court and if they you know choose otherwise we're the ones who step in and and hopefully make it to where the person who is hurt has you know some modicum or a redress or a recourse for what happened to them. Yeah and I know that to end on a positive note another positive note you know you've become an apparent recently I'm a parent myself I have two two children two sons and from I know you represent a lot of injured children too and children who've been in terrible situations that I know that you that you've helped to a great degree. For me when I when we first had kids like it changed the way I looked at cases both for my child clients and my adult clients because I'm like okay you were a baby once like I can kind of like I kind of just understood and appreciated human life a little more of that makes sense how has I know you know you're still crushing as a child lawyer and I'm wondering like having your daughter like has that as that change your viewpoint at all as it made it different better like what you know do you have any put on that. Yeah it definitely has both you know from the perspective of things that happen to children because I think anyone can agree you know viewing that not having a child can agree this is awful and never should have happened but then it becomes I always try to the degree that I can to try to put myself in that person's shoes of what they're experiencing what they're going through and talking them to them about it because if you don't hear it from them you know you don't know and there's I know there's a degree that I just I can't comprehend or understand what someone's going through just because I'm not the one living it but to the degree that I can I think now that I'm a parent it's more personal it hits a little closer to home which I think will be beneficial in communicating to a jury it gives that different perspective that I wasn't capable of having before I became a parent and kind of conversely we'd have a case coming up for trial it's up in the first tca right now on a sovereign immunity issue but it involves a wrongful death of a mother who left behind a two-year-old and an eight-month-old. And it really will, it has put for me, that case, an entirely different perspective, when it comes back, which we are fairly confident it will to go to the trial court to do those openings and closings of, you know, imagining, you know, my daughter, she's not that much younger, she's three months now, then, you know, the eight-month-old baby was at the time that he lost his mom and all the things that he will, you know, miss, not having his mom in his life and as much as I love my daughter, I know she loved her son, and that's something that she'll hear about from others, but he'll never get to experience himself from her directly. So yeah. And that's why I love from sister's liability and what you and I do is because those stairs are fixed now and, you know, Lord willing, no one will be injured on them again, and I think it's because of this case and because of those priesthood letters and like, oh man, we've got to fix these now, and we don't have to worry about people in Gainesville walking up to scrub and dub and falling and breaking their hip God forbid, and that's why one case at a time, I think that the work you're doing is making an impact, and if people want to contact you and partner on a case or bring you and your, you know, powerhouse team and to help that trial, how can they get in contact with you? So the best way to reach us is our office phone numbers, which is 352-372-999-999, alternatively, my email, which is [email protected]. So either way, we're always, you know, more than happy to speak with anybody who is concerned or think that they might have a case, we're here and waiting to be of assistance however we can. Great, well thank you so much, I really enjoyed you coming on the show and we'd love to have you back again and just appreciate you coming on. Thank you, London. Thank you all so much for listening. If you have any questions or concerns, you can send me a text at 850-777-9504. If you like the podcast, please leave us a review, share it with your friends and colleagues, and remember don't just read about it in the news or on the pleadings or online, come with us on premises.