Rule 30(b)(6) Document Depositions in Nursing Home Cases
What happens when the documents tell a different story than the witness? Rule 30(b)(6) depositions allow attorneys to question nursing home representatives about records, policies, and corporate knowledge. These depositions can uncover important evidence that might otherwise stay hidden. In this week’s episode, nursing home abuse lawyer Rob Schenk welcomes guest Mark Kosieradski to discuss how to use document depositions effectively in nursing home cases.
Schenk:
Before you hit send on another snarky email, before you pick up the phone for another meet and confer, or file a motion to compel, there’s a smarter way to do discovery. I’m attorney Rob Schenk. This is the Justice for Residents podcast, and this week I am joined by retired trial lawyer Mark Kosieradski, who will break down the Rule 30(b)(6) foundational deposition and how it helps lawyers get ahead of objections and all the malarkey early in lur- nursing home litigation.
Stick around.
Intro
Schenk:
Okay. I definitely thought this was a good jingle. I- that’s baby-making music in terms of podcast jingles, Nursing Home podcast jingles. I dig that. Good job, Jean. Thumbs up. This week, folks, a fantastic episode. I had a wonderful conversation with Mark Kosieradski, tremendous trial lawyer, prolific author, as we’ll get into in a second, about foundational depositions at the beginning of a case in order to better conduct discovery and get the documents that you need.
I have been a fan of Mark Kosieradski for many years. I have all of his books that he has done, and we’ll talk about some of the new additions to old books and new books coming out and the methods contained within them. I actually have them. Usually, they’re over my shoulder. Let me get it for you.
This is the one that’s probably helped me the most. This is his “ 30(b)(6) Deposition” book, which again, as we’ll discuss, there’s a new edition coming out, and I highly recommend everybody check that out. In terms of homework for this episode, other than reading all of his books I would say go back, all the way back almost 10 years to episodes 57 and 58, where I talked to Mark previously.
Related courtroom strategies and litigation considerations are explored in Episode 57: Taking On Nursing Homes in Court.
These are 2018 I think February or March of 2018 is when we had him on. Actually, I wanna say that Mark was one of the first li- one of the first guests that we had on the show. Of course, Richard Mollitt was the first guest. This guy, Richard Mollitt, come on. But other than Richard, I think that Mark was one of the first guests that we ever had on the show.
I emailed him, and he was gung ho about it, and so we’re super happy about that. But at any rate if you want to hear Mark talk about his work fighting abuse in nursing homes, episodes 57 and 58. And he actually has a really cool anecdote, I wanna say in episode 57, where he discusses how in a deposition he had an administrator or maybe someone from the corporate office admit that particular nursing home would spend more…
For a broader discussion of accountability mechanisms, see Episode 58: Lawsuits or Regulations: Holding Nursing Homes Accountable.
Or, it would… They spent as much on food per day in that nursing home as a can of dog food or something. He was able to make a very damaging analogy in that particular case, but that was a really cool episode with him. But not to say this episode is not great. This episode is fantastic. All right, but now it’s time to get to the hamburger and french fries of the episode.
Guest Intro
Schenk:
Mark Kosierowski is a nationally recognized trial lawyer and author known for his work on Rule 30(b)(6) Corporate Depositions and Discovery Strategy. He has taught lawyers across the country how to use corporate testimony to uncover key documents, lock in admissions, and build stronger cases from the very start of litigation.
What Is a “Document” Deposition?
Schenk:
So Mark, I think that the audience understands the concept of taking a 30(b)(6) deposition for the purposes of trying to understand what documents perhaps exist, getting ahead of objections. But tell me why even framing it that way might be outdated. How has your system evolved?
Kosieradski:
If, when we first… This whole process started, Rob, when I came to recognize that written discovery is pretty much worthless. I’m sure you’ve experienced, and our listeners are experiencing, that any time you do a written obstruct- request, be it an interrogatory or request for admissions, a document request, our adversaries seem to feel that it is their role to obstruct that, and they object to everything.
And then you get into this big fight about whether the objection is valid, but we have no evidence to prove that it’s valid or not valid. It’s just our words.
Additional guidance on preparing and conducting Rule 30(b)(6) depositions can be found in AAJ Rule 30(b)(6) Webcast Series.
Schenk:
And oftentimes their word too, ’cause I feel like they’re not bringing affidavits or witnesses themselves to the motion to compel hearings. It’s just Your Honor, we think this.” So it’s yeah.
Kosieradski:
It’s an, “I said, he said.” And one of the things we learn in law school is to say, “I would argue.” I could care less about what the argument is. I want to know what the judges say. I want to know what the law is. So what happened is we developed this system of thinking about what the objections are before they’re made.
And so we use 30(b)(6) as a tool to identify what documents are out there and what those objections might be before we even make the request. So it’s a little bit different than a lot of people think because in the old days, the document depos, say, we’d have them bring the documents and verify that those are all the correct documents.
I don’t know, it was probably around, I don’t know, 2018 maybe it’s the whole concept of discovery about discovery surfaced. Because the courts are pretty clear, you can’t ask someone about how they conducted their response to discovery unless you can prove or show that the stuff is false.
But now, you’re two or three steps down the road and a year into the litigation. So rather than taking a deposition and asking people to bring the documents and authenticate them we’ve come up with the concept of the foundation depo, which goes to my latest book, Litigation Obstruction, chapter 15.
And what the whole concept is you’ve got documents you want because, the truth is in the documents. And what we need to do is get those documents, and so we gotta figure out what the adversary is going to do to try to prevent us from getting the information. So we start with crafting the notice.
The, or I’m sorry, crafting the request for production. And I think we have to really think real carefully about it, about why we are asking for something. Because if we just say Kaj had it on the Listserv,” or, “I got… ChatGPT told me this was a good request,” that’s not gonna cut it.
The federal rules governing depositions and witness examinations are outlined in Federal Rule of Civil Procedure 30.
Yeah, so you gotta think real carefully, what is it that I want and why do I want it? Because relevance is the starting point always. Is it relevant? And relevant really has to be the ability to tell a judge why this helps prove something that’s important in the case. So we start with that, and we work really hard at drafting the document request.
And I’ll just sit and I’ll think, “Okay what is- why do I want this?” And if I say maybe one in a million times or one in a 2,000 times I’ll catch some lying,” probably not that’s not good enough. We gotta say, “This particular document or electronically stored information is going to help prove an element of the case or neutralize a defense in the case.”
So put it up, type it up, put that request for production up on the board, and then call in your friends, colleagues, and say how would you try to weasel out of this?” S- say, is it…” You know what I’m talking about. What are the objections they’re gonna make? And and then with- and then say, “Okay, are those objections valid?”
If I say, “Give me each and every email that you guys have ever written in the last 10 years,” overboard. So we think about all the objections, it- starting with is it relevant? Is it too broad? Is it vague? How precise it is. All of these things. And, and, in the book here, I identify all the objections in the law about it, that you already know what they are.
They say, “Someone says, ‘Kaj I don’t know what their objections are gonna be.'” It’s nonsense. They’re gonna be vague, over broad, immaterial, irrelevant, and violate the rule against perpetuities. Yes. The information is stored in a space capsule on Mars, or, a uni- a unicorn peed on the document and destroyed it.
It’s just junk. But you know what it’s gonna be. Think about this document, what the, why you want ’em and what the objections will be. Then we take the document deposition before we serve it. We don’t serve the request. So this is the important part to remember.
For information on obtaining critical documentation after an injury, see How to Get Medical Records After a Nursing Home Injury.
When Do You Conduct the Document Deposition?
Kosieradski:
What we want to do is to identify what documents are out there, what is the most proportional way to get them, and then neutralize the objections. So then, when you do this document, request this foundation deposition where you take the RFP, the request for production, that you have not served, copy it and embed it, those exact terms into your notice.
And, you’ve got it on your back shelf. I can see it in your book there.
Using a 30(b)(6) Foundation Deposition to Identify Documents
Schenk:
Of course.
Kosieradski:
And so now you can have these matters of examination where you ask them to tell us what documents exist in this category of documents. In this title. And it say, we’re not asking you to give them to us, but if I ask for a personnel file, what’s in that file?
I’ve learned that taking too many of these, that personnel file is not a good term. You want a human resources file. And because there’s all kinds of things that they put into a different file. Like discipline reports. That goes into a discipline report file that is part of the human resource file.
So you gotta know what you’re looking for and say, “Okay, i- if I use the term human resource file, what does that mean to the organization?” And they say, “Blah, blah, blah.” What documents and what categories of documents are in there? Blah, blah, blah, blah. And that you know what you’re looking for, and you’re looking for the performance reviews.
Say, are there performance reviews in there?” No, they’re in a diff- different file.” “Okay, what’s that file ca- called?” What you’re doing is identifying, what are the things that are supposed to be in that request before you’ve made it so that’s the starting point. And then the next thing is what is the purpose of having these documents?
And the reason the purpose is important is it’ll go to show relevance because it’s how it’s used in d- to day-to-day activities. And there’s a couple of other steps in there. For example, how are these documents disseminated to other people? Does anyone get to see them? And then and through that you say are there things, to make sure that they’re not shared with anybody?”
The investigative process behind nursing home abuse and neglect claims is discussed in Who Investigates a Nursing Home Abuse Case?.
Locating Emails, Archives, and ESI
Kosieradski:
Because that helps neutralize confidentiality. But then we get into the important part. It says, where are these documents stored? Are they stored in different places? And what is the easiest, or what are all the different ways to retrieve those documents, and what are the easiest ways? And I think the classic example of that is the emails, because you’re always gonna say, “Oh we have a system that destroys the emails, purges them every 30 days,” because the server can’t hold them all.
Okay. Do they go anywhere? Yeah, they go into an archive file. What’s an archive file? A full server. The archive server s- stores all the emails that have been deleted. How long are they held? Seven years or 10 years or indefinitely. How do you search for that? We have a software that searches for it.
See, you’re identifying all these things and when you’re back at the beginning talking about, what are these documents, you say, what does that term mean to the organization? Is there anything vague about that term? How is it used in the ordinary course of business? You’re getting rid of vague, you’re getting rid of overburdensome, you’re getting rid of where it’s, they’re stored.
And what you’ve done is you’ve identified all the responses to every objection, and you’ve identified every document that you can get. So let me be old for a second. Okay. Okay. Okay? So let’s say that it’s 2021. I … why would it, why would you now not wanna do this way? I go ahead and send the request to produce, okay?
Schenk:
Only before I take this deposition. But only so that I know what objections are being made. Now, I know that you said we already know. So- sometimes they surprise me, okay? Sometimes there are objections, like, how are you gonna object that this is privileged but also publicly available, right?
At least that is a way where I can reduce the amount of time I actually spend at the 306 deposition, because if I’ve gotta go through the vague questioning for all maybe 50 or 60 categories, that might be two hours when I might only need to do it on five of them because that’s, those are the ones they actually made the objection on.
Now, tell me, like why do you think that might not be a good way to do it anymore?
Kosieradski:
Because then now you have to go into discovery about discovery, if they said it’s overburdensome, now, they said they’ve already said it’s overburdensome and we have to take their word for it.
If we start, if we… Because now we’re taking discovery about what their responses are, and we can’t conduct responses about, or discovery about what their responses are because of the discovery on discovery.
For insight into how long nursing home litigation typically takes to reach trial, refer to How Long Does a Nursing Home Lawsuit Take to Go to Trial?.
Question of the Week
Schenk:
We interrupt this interview for the Nursing Home Regulation Question of the Week. This week, folks, I think that the difficulty level is hard.
This is not necessarily an easy one like they normally are. So if you get this right, instead of going to McDonald’s, you get to go to Five Guys
Under 42 CFR 483.80, the infection preventionist is required to, A, provide consulting on a regular basis, B, work at least part-time at the facility, or C, work full-time at the facility
And that answer is B, the nursing home’s infection preventionist needs to work at least part-time at the facility. So enjoy your Five Guys and your $65 bill.
Schenk:
I guess then that means that I’m ignorant of the objection regarding discovery. Yeah. Because I feel like I’m, like at least to the Georgia Bar, I’m still like, if they’ve, if they have objected to something being, let’s say, privileged- Yeah … even though I, like I’m not doing a foundational like you are, I find out, okay, they’ve made the objection on incident reports as being QAPI privileged, okay?
I’m still gonna go in on the cause line of questioning of “Okay, how are these created? Who has access to them? Are they used from shifts to keep providing care?” Yeah. And I really haven’t had a pushback on Rob, these, th- because we’ve already told you that it’s QAPI privileged, now you’re conducting discovery on discovery.” I guess that hasn’t been a problem for me right now.
Kosieradski:
I’ve had multiple cases in Georgia, and I did face that Oh,
Schenk:
No.
Kosieradski:
But depends what lawyer-
Schenk:
Your fame precedes you apparently.
Kosieradski:
But the long and the short of it is, you say it’s gonna take you longer, it’s not gonna take you longer.
It’s gonna be much shorter because you’re gonna have to do all the meets and conferring and everything, and build the record anywhere. And there really aren’t that many objections they’re gonna surprise you with… you’re gonna deal with privilege, you’re gonna deal with vague, you’re g- gonna deal with overburdensome, you’re gonna deal with work product.
You’re gonna deal with all of that stuff on the process basis or in the dis- the foundation depo. And because then we go on to the next step because we have this spreadsheet method. You’ve taken the deposition. You haven’t asked for anything, so they can’t object. This, they will, but it’s really, they can’t object ’cause you’re not asking them for anything.
An overview of case evaluation and litigation strategy can be found in How Schenk Smith Approaches Nursing Home Cases.
What Is Your Typical Strategy (RPD → NOD → DEPO → MTC)?
Kosieradski:
And your response is “I just don’t wanna ask for anything that doesn’t exist.” I wouldn’t do that. And I wanna find the most proportional way to get it. Now, granted, if I recall correctly, Georgia doesn’t have proportionality in state court, but they do in federal court, but you have overburdensome in Georgia.
Which judges look for the same stuff, okay? But when you’re coming, if you’re doing it from the beginning here, they haven’t had the time to really prepare for all of this stuff because they, a lot of the def- defense lawyers, just respond to whatever you’re doing, and they learn the case through you.
It’s crazy. So if you take this deposition right at the beginning and you really take the time to craft the notice, now you set up the spreadsheet, okay? And th- that’s in, in the book, there’s actually a software if you want also to make it even easier for you. And the way it works is the first column of the spreadsheet is your individual request, which means it’s gotta be tight.
It’s n- it’s not like four paragraphs long. I want this document. The next column is relevant. Why do you want it? And I recommend creating this spreadsheet before you even make the request, okay? Because when you get down to why you want it, if you can’t say it in one, two sentences maximum, eh, there may be some problems with it.
And so you set this up so you got whatever it is, the 10 requests, the 20 requests. I’m finding that as I got into my career, I started asking for fewer documents because I didn’t need them all, and there was a lot of fighting and pushback about it, so it was really focusing on what I needed and why it’s relevant, okay?
So you set that up well in advance. If you’re a young guy like you, you can even export that right into your document request, and you build it in the spreadsheet. So now you’ve got that, okay? The next column is each objection they’re gonna make for each request, and it’ll be a separate line for each objection, and there’s always gonna be seven to 12 objections.
And like the spreadsheet system I have set up, And by the way, I developed this in Georgia.
Further discussion of evidence gathering and case investigation is available in Who Investigates a Nursing Home Abuse Case?.
Schenk:
Oh, great.
Kosieradski:
All right. And it was because I was getting so many stupid objections.
Schenk:
That’s how we do in the Peach State.
Kosieradski:
Yeah but, and so then what happens is for each request, you’ve got one, two, three, four, 12 objections.
Request two, 12 objections. And you’ll see that they’re the same objections over and over and over again. The next column is just one sentence about what’s wrong with the objection procedurally. Like vague if they object, they’re supposed to contact you before the 30 days are out to clarify it.
And if they don’t, there’s a problem with that. Or overburdensome. They can’t just say it’s overburdensome, they have to say why it’s overburdensome. And so when I wrote Litigation Obstructions, I literally dug into all the jurisprudence for all the law for everything. Or they say confidential, but they don’t say why it’s confidential.
Or they say privilege, and they say th- but they don’t give you a privilege log, which they do all the time, even though the law is uniform that you have to do a privilege log when you assert, assert privilege. So now you’ve got the request, the relevance, the objections, and the procedural problem with each objection.
Next column is what’s factually wrong with the objections, and that’s what your 30(b)(6) depo is for, the foundation depo. Because y- you ask the… When you read the request right into the r- records is, “What does that term mean to this organization?” Blah, blah, blah, blah. “Is there anything vague about that?” “No.”
Okay, copy and paste, drop that into this spreadsheet. And this is sounding like a lot of work, but it’s probably an three, four hours work versus 40 hours of meet and confer emails that go on endlessly, and you can’t keep track of them. So now you’ve got what’s wrong with the objection, what’s wrong with it, and factually, and y- boilerplate objections are de facto improper.
And Georgia, unfortunately, doesn’t have 26G, unless it’s happened recently, but the federal courts do, where the attorney has to certify, like Rule 11, that the objections are valid. But most judges take that same approach that they’ll say what, you’re making objections without a valid basis for it.
So then the final columns are withdrawn, sustained, and overruled. And now y- you’ve, once you’ve embedded this, and you’re gonna get these objections, because what happens is you’ve taken the depo, then you serve the request. Okay? 30 days later, you get the response with all the objections. Your spreadsheet is set up, you just fill it out, and if you use the software, all you do is click the buttons, and it’ll fill in the objection and the procedural problem with it, and then you finish it off.
How Can a Spreadsheet Simplify Meet-and-Confers and Motions to Compel?
Kosieradski:
So then the idea is now you give… Send the spreadsheet to the defense lawyer and say, “This is a template for our meeting and confer on everything.” And of course, it’s well-recognized that boilerplate objections are improper, and in some courts, de facto sanctionable, and respectfully, some of these look like boilerplates.
So before we even spend time on the meet and confer, take a look and see which ones you want to stand by. Now you’ve already got the facts in there saying, what’s wrong with them. And so you’ve now spent, an afternoon on a 30(b)(6) depo and an afternoon on the spreadsheet, and you don’t have 40 emails, and you say, “Let’s get get together.”
And Randall Freeman down there in Georgia taught me that. He said, “Let’s get together for coffee.” That looks great in the motion, and you just say, “Check these things off. What objections are you standing by, and factually, what is the basis for them?” All of a sudden, you’ve neutralized all of those objections before they’ve even happened.
And, I had one woman in North Carolina use this. She went from 308 objections to four Because it just- Yeah … it all jumped off the page. And the m- the meet and confirm was a one-hour coffee, and the filling out the form was maybe three hours, and it was done. But- And the beauty of it is you can show the judge that there were 300 objections, and you resolve 301 of them, and the judge says, “Wow, you guys are professionals.
It’s an honor to work with you.”
Schenk:
I was gonna say what’s really cool is that with the spreadsheet basically the judge has it in front of him or her, and it’s just- Yeah … all the judge has to do is go boomph, and you’ve got your order, right?
Kosieradski:
And here’s the beauty, because in the book we also have the template brief.
You gotta tweak it, but instead of having a 40-page brief, you have an eight-page brief. Then, you just have each type of objection, two paragraphs on the law. They don’t want a tome. Say, “Objection, overburdensome. Here’s the law on overburdensome. Council or defendant has asserted overburdensome to interrogatory one, two, three, four, five, six, seven, eight, nine, and ten,” every one of them.
Schenk:
Yeah.
Kosieradski:
See the spreadsheet. Yeah. So they got the spreadsheet with all the factual and legal, and then you got a short brief that just shows what the law is so the judge can copy and paste that into the order.
Schenk:
I’ve been using I, I call it your method. I don’t… I don’t know, but I’ve been doing what you have described not this newest one but the previous iteration, for so long now, and I can’t tell you how many orders that I’ve got for documents that, in my favor, that I wouldn’t have gotten otherwise because I’ve built the record.
Yeah. And it’s j- I… And it’s funny ’cause it’s like you say this, and it sounds like common sense, like what… but, for a long time I didn’t do that. I didn’t… I’m just, I’m gonna go, “And Your Honor, personnel files I should get because of X, Y, and Z.” I don’t. I’m rolling the dice, but when I have a f- a record of the administrator saying, “This is exactly what’s in them.
We have resignation letters. Sometimes when they’re pissed off, we put that stuff in there,” and blah, blah, blah, the judge has no other option than to go, “Yeah, it is relevant,” and et cetera, et cetera. So- Yeah, he… yeah. It is an excellent system for nursing home cases because nursing home cases are document-intensive.
What’s New in the Third Edition of the 30(b)(6) Book?
Schenk:
Tell me tell me in the last few minutes that we have here, what are some of the things that we can look forward to in the new edition of the, of your 30(b)(6) book?
Kosieradski:
The 30(b)(6) book is very similar to the second edition. And the only reason I wrote the third edition is second edition was in response to the attempted rule changes, and that didn’t happen.
So I showed how all the things that they had been arguing were rejected by the rules committee, which pretty much neutralized a lot of those objections and obstructionist moves that we still need to use the sp- spreadsheet method to identify, but it neutralized it. But what happened was then, okay, if we can’t do that, then we’re gonna try to prevent the evidence from coming into evidence at trial.
And all kinds of nonsense occurred about trying to block 30(b)(6) testimony at trial, and a whole area of jurisprudence evolved on it between the second and third edition. So the last chapter of the book is completely new. The rules about what you can and cannot do for introducing 30(6) testimony.
Can they do it? Can you call the witness live? Non-party versus party. And so that’s all new. So it’s, if you’re going to trial and you plan on using 30(6), it’s a must.
Schenk:
And what’s interesting to me about this edition is that it can be super confusing sometimes to conceptualize these things.
Okay, like we have this corporate depo transcript that we wanna read, but that person’s here, or it’s a different design now. Like- … w- who… You know what I mean? There’s just so many different ways that it can be approached that it’s good that we’ve got this jurisprudence in one location.
Kosieradski:
It’s all there. I’m gonna tell you, the chapter’s only 20 pages long, but it took six months to write it, to just, to parse out all these nuances. And I worked pretty hard to try to make the books accessible to people because these are abstract concepts. The other part of the book that’s new is I updated all of the appendices to make sure we had the most recent state jurisprudence about the 30(6), which is almost nonexistent.
It’s, so it’s making sure that w- we know what laws the state has the language, and how the state Supreme Court looks to federal authority. A couple states have cases on them, but not many.
Schenk:
How does it feel and I wanted to ask you this. How does it feel reading, in the past five or six years, all these district opinions, all the appellate opinions about 30(6) that exist only because of attorneys that have read your book?
You know what I mean? You’re, one of your legacies, and I’m sure you have kids and grandkids and all that, one of your legacies is all these o- opinions based on the work that you did in 30(6).
Kosieradski:
It’s fun because oftentimes I- I’m pretty honored to see the exact language from my book in this case.
That doesn’t cite me, but the language is there. But the legacy is actually a big part of what this is. My daughter just said, “Dad, you’ve spent 45 years just fighting and you’ve got all of this knowledge and these techniques and things that you developed, and you should share them with people.”
And so the most important thing for me is empowering lawyers to stand up to bullies, ’cause I hate bullies. I was bullied as a child. I was bullied as a young lawyer. And people tried to con- to bully to the end, but eventually it got to the point where they couldn’t do it because I knew the law.
And if you know the law, you don’t have to sit and go home at night worrying did I screwed up or not?” You know that you did it right. And so if you know the law, and I’ve captured it for you as a legacy to empower new lawyers, older lawyers to stand up to bullies and in some cases even teach the bullies how to not get in trouble by not bullying.
And I have defense lawyers contact me and say, “Cos I’d like you to just go over this and tell me, am I doing this right? Because I don’t wanna get sanctioned.”
Schenk:
Very well said. I am definitely one of those who have been empowered if I may say so. I really appreciate the work that you’ve done. And Mark, again, I really appreciate you coming on the show and sharing your knowledge with us.
Kosieradski:
It’s been a privilege and an honor. But as I always say this, no matter what it is in life you’re encountering, you can count on one thing: it always goes back to the bluefish. There we are.
Schenk:
That was amazing. Thank you so much, Mark. Folks, I cannot recommend Mark’s books enough to get… I have all of them. You’ve got The 30(b)(6), that’s the, to me, that’s the OG. I recommend that. Deposition Obs- Obstruction is an o- is also an excellent book. I don’t think we discussed that in his interview, but Deposition Obstruction is really great.
He goes through basically whether or not objections and depositions are valid or not, and this was very helpful for me, particularly as a younger lawyer. And then of course, as we just talked about, Litigation Obstruction. I’m not getting any money. I’m not an affiliate. I’m not anything. I’m just a huge fan, so don’t…
I’m not selling anything, but these books are fantastic. The Litigation Obstruction is the one that we discussed most today. That’s the one where it has a spreadsheet and stuff in it. Folks, if you enjoyed the content of this episode, please be sure to like and subscribe wherever you get your podcasts from.
If you have an idea for a topic that you would like for me to talk about, let me know. If you have an idea for a guest that you would like for me to talk to, let me know that as well. New episodes of the Justice for Residents podcast come out every single Monday. And with that, folks, we’ll see you next time.