1779135211110

0:10

S… Speaker 1 (1779135211110)

Hello, Melissa.

0:10

S… Speaker 1 (1779135211110)

It's Bruce Edwards.

0:11

S… Speaker 1 (1779135211110)

How are you doing?

0:12

S… Speaker 2 (1779135211110)

Hi,

0:13

S… Speaker 1 (1779135211110)

Bruce.

0:13

S… Speaker 2 (1779135211110)

Just great.

0:14

S… Speaker 2 (1779135211110)

Thanks for calling.

0:15

S… Speaker 1 (1779135211110)

Yeah, well,

0:16

S… Speaker 1 (1779135211110)

I really wanted to make sure we had a chance to talk before the upcoming mediation.

0:19

S… Speaker 1 (1779135211110)

I like to do that to make sure that all of us are on the same page and

0:23

S… Speaker 1 (1779135211110)

particularly that we've had a chance to make sure that we're consistent

0:27

S… Speaker 1 (1779135211110)

in our thinking.

0:28

S… Speaker 1 (1779135211110)

I'd just like to avoid any problems that could have been avoided with a little forethought.

0:34

S… Speaker 1 (1779135211110)

Have you had a chance to talk with your clients,

0:37

S… Speaker 1 (1779135211110)

David and Rosanna,

0:38

S… Speaker 1 (1779135211110)

about the mediation?

0:39

S… Speaker 1 (1779135211110)

Do you have any particular concerns or things that I can address?

1:21

S… Speaker 1 (1779135211110)

Well, let me know what I can do to help you.

1:24

S… Speaker 1 (1779135211110)

You and I have done this before,

1:25

S… Speaker 1 (1779135211110)

and neither of us are strangers to emotions within

1:29

S… Speaker 1 (1779135211110)

this process.

1:30

S… Speaker 1 (1779135211110)

So I'll play off your lead.

1:33

S… Speaker 1 (1779135211110)

If you want me to do something directly,

1:35

S… Speaker 1 (1779135211110)

you can tell me in advance.

1:37

S… Speaker 1 (1779135211110)

If you want to just give me some cues as we work through the process,

1:40

S… Speaker 1 (1779135211110)

don't hesitate to take me aside and let me know how we're doing at

1:44

S… Speaker 1 (1779135211110)

the same time.

1:45

S… Speaker 2 (1779135211110)

Okay.

2:06

S… Speaker 1 (1779135211110)

It's not uncommon for that to be party's first reaction.

2:09

S… Speaker 1 (1779135211110)

In fact, I think it's fair to say the other side had a similar kind of concern.

2:13

S… Speaker 1 (1779135211110)

I'll follow your lead ultimately,

2:17

S… Speaker 1 (1779135211110)

but do understand that I have a strong preference for trying to have some

2:21

S… Speaker 1 (1779135211110)

face -to -face communication.

2:23

S… Speaker 1 (1779135211110)

What I typically do is meet with the parties for a few minutes beforehand

2:27

S… Speaker 1 (1779135211110)

on the morning of the mediation to check in and just make

2:31

S… Speaker 1 (1779135211110)

sure everybody slept well at night and doesn't have any last -minute concerns or

2:35

S… Speaker 1 (1779135211110)

issues to deal with.

2:36

S… Speaker 1 (1779135211110)

But then I'll try and bring people together initially because I think there is

2:41

S… Speaker 1 (1779135211110)

something to be said for hearing from each other face -to -face,

2:45

S… Speaker 1 (1779135211110)

perhaps for the first time.

2:46

S… Speaker 1 (1779135211110)

You know me.

2:48

S… Speaker 1 (1779135211110)

I'm going to control that process.

2:51

S… Speaker 1 (1779135211110)

depending on your client's comfort level with his or her participation,

2:55

S… Speaker 1 (1779135211110)

that can range from full participation in that meeting to just sitting

2:59

S… Speaker 1 (1779135211110)

quietly and listening to the other side.

3:01

S… Speaker 1 (1779135211110)

Obviously,

3:02

S… Speaker 1 (1779135211110)

I'll guard against it being any kind of an abusive moment.

3:05

S… Speaker 1 (1779135211110)

But do give that some more thought and talk it through with your clients.

3:08

S… Speaker 1 (1779135211110)

And if you need my help in trying to get them to

3:12

S… Speaker 1 (1779135211110)

start in that fashion,

3:13

S… Speaker 1 (1779135211110)

then we can talk about it on the morning of the mediation.

3:24

S… Speaker 1 (1779135211110)

No, it's a good question.

3:26

S… Speaker 1 (1779135211110)

My understanding is,

3:27

S… Speaker 1 (1779135211110)

in talking with Bob,

3:28

S… Speaker 1 (1779135211110)

the people that are going to be on his side of the table include Ivy

3:33

S… Speaker 1 (1779135211110)

Fine, who's the CEO of the company.

3:35

S… Speaker 1 (1779135211110)

And while I'm just sort of starting to get into some of the specifics about

3:39

S… Speaker 1 (1779135211110)

their insurance picture,

3:41

S… Speaker 1 (1779135211110)

it looks like most,

3:43

S… Speaker 1 (1779135211110)

if not all, of the dollars and therefore the decisions will be hers to make.

3:47

S… Speaker 1 (1779135211110)

They have a nursing supervisor who I think is known

3:51

S… Speaker 1 (1779135211110)

to the Garcia family.

3:53

S… Speaker 1 (1779135211110)

who will be there in attendance as well to help me at least and perhaps

3:57

S… Speaker 1 (1779135211110)

the group understand some of the sort of more technical issues,

4:00

S… Speaker 1 (1779135211110)

if not factual background,

4:02

S… Speaker 1 (1779135211110)

to what led to these events.

4:04

S… Speaker 2 (1779135211110)

Nolani

4:08

S… Speaker 1 (1779135211110)

is her name.

4:09

S… Speaker 1 (1779135211110)

I'd have to look up her last name.

4:12

S… Speaker 1 (1779135211110)

I had just taken a note in my discussion with Bob.

4:15

S… Speaker 1 (1779135211110)

So Nolani,

4:17

S… Speaker 1 (1779135211110)

I think that's it.

4:18

S… Speaker 1 (1779135211110)

I think that is it.

4:19

S… Speaker 2 (1779135211110)

Okay.

4:20

S… Speaker 1 (1779135211110)

And while we're on that topic,

4:22

S… Speaker 1 (1779135211110)

my understanding is that Mrs.

4:24

S… Speaker 1 (1779135211110)

Garcia, Olivia Garcia,

4:25

S… Speaker 1 (1779135211110)

is not going to be...

4:26

S… Speaker 1 (1779135211110)

in a condition to participate in this,

4:28

S… Speaker 1 (1779135211110)

that really this is about her children,

4:30

S… Speaker 1 (1779135211110)

David and Rosanna,

4:32

S… Speaker 1 (1779135211110)

and those are going to be the ones in attendance.

4:34

S… Speaker 1 (1779135211110)

There's a couple more thoughts,

4:36

S… Speaker 1 (1779135211110)

so I wanted to take advantage of your time.

4:38

S… Speaker 1 (1779135211110)

I usually prepare a list of things that I like to go over

4:42

S… Speaker 1 (1779135211110)

with...

4:43

S… Speaker 1 (1779135211110)

the parties just from my experience over the years of what I call getting

4:47

S… Speaker 1 (1779135211110)

my nose bloodied by forgetting to raise an issue and then finding out on the morning of

4:51

S… Speaker 1 (1779135211110)

mediation that it's important to somebody or we've neglected it entirely.

4:55

S… Speaker 1 (1779135211110)

So give me a moment just to kind of look at my list.

4:57

S… Speaker 1 (1779135211110)

My understanding from

5:00

S… Speaker 1 (1779135211110)

talking with Bob is that you guys have done a bit of discovery in this case already

5:04

S… Speaker 1 (1779135211110)

and that there's at least enough has taken place so that you feel comfortable

5:08

S… Speaker 1 (1779135211110)

sitting down and working with the facts that you have at your disposal.

5:11

S… Speaker 2 (1779135211110)

Yeah,

5:12

S… Speaker 2 (1779135211110)

I think we're at a good safe discovery.

5:14

S… Speaker 2 (1779135211110)

We haven't done any experts.

5:15

S… Speaker 2 (1779135211110)

And

5:25

S… Speaker 1 (1779135211110)

then I'd like to see you guys exchange some mediation briefs if that works

5:30

S… Speaker 1 (1779135211110)

for you.

5:30

S… Speaker 2 (1779135211110)

If

5:37

S… Speaker 1 (1779135211110)

there's anything you'd like to send to me in confidence,

5:39

S… Speaker 1 (1779135211110)

Melissa, you're welcome to do so.

5:40

S… Speaker 1 (1779135211110)

Just make it separate from the brief itself.

5:43

S… Speaker 1 (1779135211110)

That way you can...

5:44

S… Speaker 1 (1779135211110)

share your brief and some of your arguments with Bob and just keep

5:49

S… Speaker 1 (1779135211110)

for confidential information whatever you want to send me separately.

5:52

S… Speaker 2 (1779135211110)

My

5:57

S… Speaker 1 (1779135211110)

guess is this case is the kind of case

6:01

S… Speaker 1 (1779135211110)

that could take the better part of the day.

6:03

S… Speaker 1 (1779135211110)

You think your clients are prepared for that sort of commitment?

6:42

S… Speaker 1 (1779135211110)

there's always a delicate balance to be struck between moving too

6:46

S… Speaker 1 (1779135211110)

quickly in these things versus allowing it to flow at its own pace

6:51

S… Speaker 1 (1779135211110)

and addressing all the important and necessary issues.

6:53

S… Speaker 1 (1779135211110)

So I will try and be attentive to your client's fatigue

6:58

S… Speaker 1 (1779135211110)

level.

6:59

S… Speaker 1 (1779135211110)

As I go through what I would normally feel we need to go through in this,

7:03

S… Speaker 1 (1779135211110)

and if at any point you want to take me aside and

7:07

S… Speaker 1 (1779135211110)

let me know that you feel your folks are running out of gas,

7:10

S… Speaker 1 (1779135211110)

particularly as we get close to final decisions,

7:13

S… Speaker 1 (1779135211110)

the last thing I want to do is get this thing to a settlement

7:17

S… Speaker 1 (1779135211110)

agreement that is the result of people just feeling tired.

7:21

S… Speaker 1 (1779135211110)

So I'll listen to you on that.

7:25

S… Speaker 1 (1779135211110)

We had another case before,

7:27

S… Speaker 1 (1779135211110)

Melissa,

7:27

S… Speaker 1 (1779135211110)

where you actually brought a form settlement agreement with you.

7:31

S… Speaker 1 (1779135211110)

And I don't want to get the cart before the horse,

7:33

S… Speaker 1 (1779135211110)

but I certainly found that to be helpful.

7:36

S… Speaker 1 (1779135211110)

And I can see us,

7:39

S… Speaker 1 (1779135211110)

if we get to the end of the day and people are tired,

7:41

S… Speaker 1 (1779135211110)

if we already have an agreement that's underway,

7:45

S… Speaker 1 (1779135211110)

even if you have it in your briefcase for a period of time,

7:48

S… Speaker 1 (1779135211110)

that may help expedite our efforts at the end of the day.

7:52

S… Speaker 2 (1779135211110)

I can do that again.

8:02

S… Speaker 1 (1779135211110)

I have a question.

8:03

S… Speaker 1 (1779135211110)

It just occurred to me.

8:04

S… Speaker 1 (1779135211110)

In a lot of these cases that I work on,

8:06

S… Speaker 1 (1779135211110)

not all of them,

8:07

S… Speaker 1 (1779135211110)

but in a lot of cases,

8:08

S… Speaker 1 (1779135211110)

it's helpful if I actually see the

8:12

S… Speaker 1 (1779135211110)

location that has sort of given rise to the events,

8:15

S… Speaker 1 (1779135211110)

whether it's a construction case or it's an area where some

8:20

S… Speaker 1 (1779135211110)

personal injury occurred.

8:21

S… Speaker 1 (1779135211110)

And I don't bill people for that,

8:24

S… Speaker 1 (1779135211110)

but since this is a local facility residence,

8:29

S… Speaker 1 (1779135211110)

Would you have any objection if I drove by on Saturday and just poked my head in the

8:33

S… Speaker 1 (1779135211110)

door and kind of looked around?

8:34

S… Speaker 1 (1779135211110)

Sometimes it gives me a little credibility with the parties

8:38

S… Speaker 1 (1779135211110)

when I can actually make comment or observe that I've seen some

8:43

S… Speaker 1 (1779135211110)

of the conditions.

8:43

S… Speaker 2 (1779135211110)

No,

9:00

S… Speaker 1 (1779135211110)

just that's my effort.

9:03

S… Speaker 1 (1779135211110)

to really start to come up to speed on this and delighted to sort

9:07

S… Speaker 1 (1779135211110)

of donate that time for a variety of reasons.

9:09

S… Speaker 1 (1779135211110)

And otherwise,

9:10

S… Speaker 1 (1779135211110)

I'll take a look around.

9:12

S… Speaker 1 (1779135211110)

I'll let Bob know,

9:13

S… Speaker 1 (1779135211110)

obviously, that we've had this discussion and that's my intention as well.

9:16

S… Speaker 2 (1779135211110)

What

9:22

S… Speaker 1 (1779135211110)

haven't we talked about today that might come up at the mediation

9:26

S… Speaker 1 (1779135211110)

that you'd like us to think about in advance or otherwise

9:30

S… Speaker 1 (1779135211110)

preview so that we don't find ourselves stumbling on

9:34

S… Speaker 1 (1779135211110)

something out of the starting gate?

9:43

S… Speaker 1 (1779135211110)

Well, I'm very interested in helping out in this case.

9:46

S… Speaker 1 (1779135211110)

It obviously presents a real important question,

9:49

S… Speaker 1 (1779135211110)

not just in the lives of these family members,

9:51

S… Speaker 1 (1779135211110)

but for sort of all of us as we think about aging parents and health

9:55

S… Speaker 1 (1779135211110)

care issues and the like.

9:56

S… Speaker 1 (1779135211110)

So I appreciate it.

10:00

S… Speaker 1 (1779135211110)

And I always appreciate your confidence in me and the process.

10:03

S… Speaker 1 (1779135211110)

So I look forward to seeing you in a couple weeks.

10:06

S… Speaker 1 (1779135211110)

And I know you'll enjoy working with Bob.

10:10

S… Speaker 1 (1779135211110)

And let's just give it our best efforts.

10:13

S… Speaker 1 (1779135211110)

And let me know between now and then if any questions come up with you or your clients.

10:17

S… Speaker 1 (1779135211110)

And we'll address them before the mediation itself.

10:19

S… Speaker 1 (1779135211110)

Otherwise, I'll see you that morning.

10:20

S… Speaker 2 (1779135211110)

Thank you,

10:21

S… Speaker 1 (1779135211110)

Bruce. Thanks,

10:27

S… Speaker 1 (1779135211110)

Melissa.

10:27

S… Speaker 1 (1779135211110)

You have a good evening.

10:28

S… Speaker 2 (1779135211110)

Thank you.

10:29

S… Speaker 1 (1779135211110)

Bye -bye.

10:29

S… Speaker 1 (1779135211110)

Bob,

10:31

S… Speaker 1 (1779135211110)

are you there?

10:32

S… Speaker 2 (1779135211110)

Bruce,

10:33

S… Speaker 2 (1779135211110)

how are you?

10:34

S… Speaker 1 (1779135211110)

Good.

10:35

S… Speaker 1 (1779135211110)

How are you doing today?

10:43

S… Speaker 1 (1779135211110)

That's a complaint I hear a lot,

10:44

S… Speaker 1 (1779135211110)

I have to admit.

10:45

S… Speaker 1 (1779135211110)

But hopefully at the end of this mediation,

10:49

S… Speaker 1 (1779135211110)

you will think it's all worthwhile.

10:50

S… Speaker 2 (1779135211110)

Yeah,

11:01

S… Speaker 1 (1779135211110)

and it's about two weeks out,

11:04

S… Speaker 1 (1779135211110)

so I wanted to take a couple minutes and just talk to you about the event and make sure we're

11:08

S… Speaker 1 (1779135211110)

on the same page in terms of who's attending and issues that are

11:13

S… Speaker 1 (1779135211110)

of concern to me,

11:13

S… Speaker 1 (1779135211110)

certainly any issues that are of concern to you and your clients.

11:16

S… Speaker 1 (1779135211110)

I've spoken with Melissa a couple times,

11:19

S… Speaker 1 (1779135211110)

so...

11:20

S… Speaker 1 (1779135211110)

had the opportunity to vet some of these conversation points with her.

11:24

S… Speaker 1 (1779135211110)

So anyway,

11:25

S… Speaker 1 (1779135211110)

it's all about really trying to make sure we hit the ground running on the day of the mediation and

11:30

S… Speaker 1 (1779135211110)

don't have any missteps.

11:31

S… Speaker 1 (1779135211110)

Why don't we start

11:35

S… Speaker 1 (1779135211110)

with what's on your mind first?

11:36

S… Speaker 1 (1779135211110)

It's obviously you've got clients that have some

11:40

S… Speaker 1 (1779135211110)

interest in this,

11:41

S… Speaker 1 (1779135211110)

I'm sure.

11:42

S… Speaker 1 (1779135211110)

And I don't recall if Ivy,

11:44

S… Speaker 1 (1779135211110)

your client,

11:45

S… Speaker 1 (1779135211110)

has been through mediation before,

11:46

S… Speaker 1 (1779135211110)

but what can you tell me?

11:48

S… Speaker 2 (1779135211110)

No,

12:36

S… Speaker 1 (1779135211110)

I appreciate that perspective.

12:40

S… Speaker 1 (1779135211110)

You and I can talk more about it on the morning of the mediation,

12:43

S… Speaker 1 (1779135211110)

how to strike the right balance between having IV appropriately

12:48

S… Speaker 1 (1779135211110)

involved and communicating that continued message of care

12:52

S… Speaker 1 (1779135211110)

and concern versus setting herself up as

12:56

S… Speaker 1 (1779135211110)

the piñata,

12:57

S… Speaker 1 (1779135211110)

if you will,

12:57

S… Speaker 1 (1779135211110)

for the other side's emotion.

13:00

S… Speaker 1 (1779135211110)

That said,

13:01

S… Speaker 1 (1779135211110)

I'm a real believer that it is important for people to sit across the table from each

13:05

S… Speaker 1 (1779135211110)

other. Oftentimes I find it's the first time they've had the opportunity to do that

13:09

S… Speaker 1 (1779135211110)

and really listen as best they can.

13:12

S… Speaker 1 (1779135211110)

So that's going to be my bias.

13:15

S… Speaker 1 (1779135211110)

That's going to be my push,

13:16

S… Speaker 1 (1779135211110)

but I certainly will do it in a thoughtful,

13:18

S… Speaker 1 (1779135211110)

respectful way as you and Ivy kind of give me direction.

13:34

S… Speaker 1 (1779135211110)

Okay, good to know.

13:36

S… Speaker 1 (1779135211110)

One of the thoughts I had is maybe it would make sense for me to just

13:40

S… Speaker 1 (1779135211110)

swing by Golden Acres some evening on my way home from work.

13:43

S… Speaker 1 (1779135211110)

It's not too far out of the way,

13:44

S… Speaker 1 (1779135211110)

and I told Melissa I had the same thought,

13:46

S… Speaker 1 (1779135211110)

and I certainly am not going to bill anybody for the exercise,

13:50

S… Speaker 1 (1779135211110)

but it might help me in my conversations

13:54

S… Speaker 1 (1779135211110)

with Ivy if I have...

13:56

S… Speaker 1 (1779135211110)

been out there and can actually comment on sort of a first -person

14:00

S… Speaker 1 (1779135211110)

perspective on what I see,

14:02

S… Speaker 1 (1779135211110)

particularly if it demonstrates the kind of quality and concern

14:06

S… Speaker 1 (1779135211110)

that you suggest it does.

14:07

S… Speaker 1 (1779135211110)

That can only help as I try and sort of build a relationship

14:12

S… Speaker 1 (1779135211110)

with her moving forward.

14:13

S… Speaker 2 (1779135211110)

Okay.

14:28

S… Speaker 1 (1779135211110)

Can I talk for a minute about mediation briefs?

14:32

S… Speaker 1 (1779135211110)

I want to make sure that you and Melissa are on the same page.

14:34

S… Speaker 2 (1779135211110)

Sure.

14:35

S… Speaker 1 (1779135211110)

And what I suggested to her and what you and I have done in the past,

14:38

S… Speaker 1 (1779135211110)

you've shared

14:39

S… Speaker 1 (1779135211110)

mediation statements with the other side.

14:42

S… Speaker 1 (1779135211110)

Obviously,

14:43

S… Speaker 1 (1779135211110)

again,

14:44

S… Speaker 1 (1779135211110)

I believe there's value in the other side getting from you some kind of statement

14:48

S… Speaker 1 (1779135211110)

of position that they have an opportunity to read and reflect

14:52

S… Speaker 1 (1779135211110)

on before the day of mediation.

14:54

S… Speaker 1 (1779135211110)

I also hold out to both sides the opportunity to send

14:58

S… Speaker 1 (1779135211110)

me something in confidence.

15:00

S… Speaker 1 (1779135211110)

if you want to augment the brief itself.

15:04

S… Speaker 1 (1779135211110)

So if there's something that you feel kind of fits that need,

15:08

S… Speaker 1 (1779135211110)

you're always welcome to send me a separate confidential statement.

15:11

S… Speaker 1 (1779135211110)

But do take advantage of the opportunity to send something

15:15

S… Speaker 1 (1779135211110)

to Melissa and her clients,

15:17

S… Speaker 1 (1779135211110)

if you would.

15:17

S… Speaker 2 (1779135211110)

Well,

16:20

S… Speaker 1 (1779135211110)

as you know, mediation timing is an imperfect science.

16:23

S… Speaker 1 (1779135211110)

And on the continuum between way too early and way too late,

16:27

S… Speaker 1 (1779135211110)

there's a lot of data points.

16:30

S… Speaker 1 (1779135211110)

And my hope is that we are hitting it somewhere,

16:32

S… Speaker 1 (1779135211110)

if not in the sweet spot,

16:34

S… Speaker 1 (1779135211110)

at least close enough that we can make real progress.

16:37

S… Speaker 1 (1779135211110)

And as you know,

16:38

S… Speaker 1 (1779135211110)

if we end up needing to come back because there was something that we

16:43

S… Speaker 1 (1779135211110)

just hadn't yet developed or people need a little bit of additional time to ripen

16:47

S… Speaker 1 (1779135211110)

to the moment, those are always options.

16:49

S… Speaker 1 (1779135211110)

But more often than not,

16:51

S… Speaker 1 (1779135211110)

I find when people think we're maybe a little bit too soon,

16:54

S… Speaker 1 (1779135211110)

a little premature.

16:56

S… Speaker 1 (1779135211110)

We still have a meaningful chance of success.

16:58

S… Speaker 1 (1779135211110)

So I hear you.

17:00

S… Speaker 1 (1779135211110)

I'm attentive to those timing issues and just keep an open mind.

17:03

S… Speaker 2 (1779135211110)

Thank

17:56

S… Speaker 1 (1779135211110)

you. I mean,

17:57

S… Speaker 1 (1779135211110)

the optimist in me looks at that and says,

17:59

S… Speaker 1 (1779135211110)

depending on the size of the self -insured retention,

18:02

S… Speaker 1 (1779135211110)

it may mean that we have the entirety of decision -making capability

18:06

S… Speaker 1 (1779135211110)

there in Ms.

18:08

S… Speaker 1 (1779135211110)

Fine, and we don't have to deal with some of the more typical

18:12

S… Speaker 1 (1779135211110)

insurance issues that we would in the absence of an SIR.

18:15

S… Speaker 1 (1779135211110)

I know that...

18:17

S… Speaker 1 (1779135211110)

It doesn't necessarily make you happy because your client's still paying a tidy

18:21

S… Speaker 1 (1779135211110)

sum out of pocket potentially,

18:22

S… Speaker 1 (1779135211110)

but at least it sounds like we'll have the decision maker there.

18:26

S… Speaker 2 (1779135211110)

I

18:43

S… Speaker 1 (1779135211110)

would never make that assumption,

18:44

S… Speaker 1 (1779135211110)

Bob.

18:44

S… Speaker 1 (1779135211110)

I would suspect you would have something to that effect on your tombstone.

18:48

S… Speaker 1 (1779135211110)

So for now,

18:50

S… Speaker 1 (1779135211110)

we'll...

18:51

S… Speaker 1 (1779135211110)

All right.

18:56

S… Speaker 1 (1779135211110)

While we're on the topic of decision makers,

18:58

S… Speaker 1 (1779135211110)

I did talk with Melissa,

19:00

S… Speaker 1 (1779135211110)

and apparently...

19:03

S… Speaker 1 (1779135211110)

Olivia Garcia's adult children,

19:05

S… Speaker 1 (1779135211110)

David and Rosanna,

19:06

S… Speaker 1 (1779135211110)

will both be there.

19:07

S… Speaker 1 (1779135211110)

They have been appointed guardian ad litem,

19:09

S… Speaker 1 (1779135211110)

so they will have legal and perhaps moral authority

19:14

S… Speaker 1 (1779135211110)

to sort of make family decisions.

19:15

S… Speaker 1 (1779135211110)

So I think we're going to have all the decision makers we need at the table.

19:19

S… Speaker 1 (1779135211110)

I did want to alert you that the family is bringing an expert to

19:23

S… Speaker 1 (1779135211110)

the mediation.

19:24

S… Speaker 1 (1779135211110)

A nurse,

19:25

S… Speaker 1 (1779135211110)

Julie Brandt,

19:27

S… Speaker 1 (1779135211110)

I think her last name,

19:28

S… Speaker 1 (1779135211110)

I'll have to look it up,

19:28

S… Speaker 1 (1779135211110)

but she's somebody who's had a lot of experience both working.

19:32

S… Speaker 1 (1779135211110)

in the area of elder care,

19:34

S… Speaker 1 (1779135211110)

assisted living,

19:35

S… Speaker 1 (1779135211110)

and has also served as an expert witness for the last 10 years or so.

19:39

S… Speaker 1 (1779135211110)

My thought would be that we involve her in the mediation

19:43

S… Speaker 1 (1779135211110)

process as well.

19:44

S… Speaker 1 (1779135211110)

You'll get a preview of what she has to say and how she's going

19:48

S… Speaker 1 (1779135211110)

to say it, and I'll try and manage her from the standpoint of

19:52

S… Speaker 1 (1779135211110)

not making it too antagonistic.

19:55

S… Speaker 2 (1779135211110)

And

20:09

S… Speaker 1 (1779135211110)

my understanding is,

20:10

S… Speaker 1 (1779135211110)

in addition to Ms.

20:11

S… Speaker 1 (1779135211110)

Fine, you're going to bring the nursing supervisor with you as well.

20:56

S… Speaker 3 (1779135211110)

Rosanna.

20:56

S… Speaker 3 (1779135211110)

Yeah,

20:57

S… Speaker 1 (1779135211110)

Rosanna.

20:58

S… Speaker 2 (1779135211110)

You'll

21:43

S… Speaker 1 (1779135211110)

be happy to know that both lawyers in this case have taken full advantage

21:47

S… Speaker 1 (1779135211110)

of the opportunity to begin working in the mediator before we're starting the mediation.

21:51

S… Speaker 1 (1779135211110)

But I do appreciate the

21:59

S… Speaker 1 (1779135211110)

liability arguments,

22:01

S… Speaker 1 (1779135211110)

and I will, in all seriousness,

22:02

S… Speaker 1 (1779135211110)

look forward to hearing them from both you and your client on the

22:06

S… Speaker 1 (1779135211110)

day of mediation.

22:07

S… Speaker 1 (1779135211110)

We'll address them sort of as seriously as they're intended.

22:13

S… Speaker 1 (1779135211110)

Anything else that I should be thinking about?

22:15

S… Speaker 1 (1779135211110)

Anything else that I can do to help make you or your clients comfortable coming

22:20

S… Speaker 1 (1779135211110)

into the mediation process?

22:21

S… Speaker 2 (1779135211110)

Okay.

22:37

S… Speaker 1 (1779135211110)

And should anything come up in the next couple of weeks that creates

22:41

S… Speaker 1 (1779135211110)

a concern for you?

22:42

S… Speaker 1 (1779135211110)

Or even if you're...

22:44

S… Speaker 1 (1779135211110)

client wanted to have a private conversation in preparation for the mediation,

22:48

S… Speaker 1 (1779135211110)

you know, those things are all possible.

22:50

S… Speaker 1 (1779135211110)

Just give me a heads up.

22:52

S… Speaker 1 (1779135211110)

I'll alert the other side that that's happening and then we'll

22:56

S… Speaker 1 (1779135211110)

work through it.

22:56

S… Speaker 1 (1779135211110)

But otherwise, I will look forward to working with you in two weeks.

23:00

S… Speaker 1 (1779135211110)

And I think these are important issues.

23:02

S… Speaker 1 (1779135211110)

So I appreciate the opportunity to be invited into this discussion and

23:06

S… Speaker 1 (1779135211110)

really looking forward to helping your clients work through them.

23:09

S… Speaker 2 (1779135211110)

All right,

23:11

S… Speaker 1 (1779135211110)

Bob, you have a good evening.

Sommarju

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