Moving from Arbitration to Mediation in Business Disputes

Hi, welcome to MediatorPodcast.com, a podcast and video series about mediation, negotiation and collaboration. My name is Melissa Gragg, and I'm a valuation expert and divorce financial mediator in St. Louis Missouri – specializing in divorce and partner disputes. 

Today we are talking about moving from arbitration to mediation in business disputes with Margeaux Thomas. Margeaux has worked for entrepreneurs and small business owners,  specializing in commercial landlord/tenant disputes, business partnership disputes, and contract disputes, including franchise, partner, shareholder, non-compete, and non-solicitation. She is located in the D.C area. Welcome, Margeaux.  

Episode Transcript

Speaker 1 (00:00):
Hi, welcome to mediator podcast.com, a podcast
and video series aboutmediation, negotiation, and
collaboration. My name isMelissa Greg , and I'm a
valuation expert and divorcefinancial mediator in St.
Louis, Missouri. I specializein divorce and partner
disputes, and today we're gonnabe talking about business
disputes. And Margot Thomas hasworked with entrepreneurs and

(00:20):
small business ownersspecializing in commercial
landlord tenant disputes,business partnership disputes,
contract disputes, franchises ,um, partner issues,
non-competes, non-solicitation.
She's actually located in theDC area. And today we're gonna
talk about moving fromarbitration to mediation and

(00:44):
business disputes. Welcome,Margot. How are you?

Speaker 2 (00:48):
I'm doing good.
Thank you for having me,Melissa.

Speaker 1 (00:50):
Awesome. Okay. So I specialize mostly in divorces
and business disputes wherethere is a valuation involved.
And what we're gonna talk abouttoday is really the fact that
there's a ton of areas that arereally ripe for maybe mediation

(01:13):
in a business issue thatbusiness owners are just
defaulting to arbitration orhave contractual language
around some of these issues.
And I think that what we wanthere is a perspective to walk
away after today with aperspective of how a business
owner could use mediation orthese alternatives to get

(01:38):
through , um, some of theirdaily issues with suppliers,
vendors, and really in somesituations where you may not
want to like sue somebody thatyou're working with, but you
have to come to an agreement.
Um, and quite frankly, when wefirst started talking about
this with Margot, I reallydidn't know like what types of

(02:01):
business issues she is seeing ,you know, being on the east
coast, kind of having yourwhole practice around this.
Like what types of issues areyou seeing come through
mediation that involvebusinesses?

Speaker 2 (02:16):
So we have seen just about every kind of issue go
through mediation, but I thinkthat the, the issue that is
best suited for mediation iswhat we call business divorces.
Um, business partners who aregoing their separate ways for
one reason or another. And thereason that I think that those
are so well suited formediation is because there is a
money aspect, there is avaluation aspect in every

(02:38):
single one of those, butthere's also , um, underlying
issues that also need to beresolved in most of those
cases. It is not like having adispute with a supplier or a
third party who you can justend the contract and go get
another supplier. You neverhave to see this person again
when you're dealing with abusiness partnership dispute.
Most of the people that we dealwith are siblings, their family

(03:00):
members, their husband andwife, their cousins, you know,
they have some, they've knowneach other for 20 years. That's
why they went into businesstogether. A lot of them do not
have a lot of , um, they didn'thire a lawyer at the beginning
to get an operating agreementor some type of foundational
document because they know loveor trust the other person that
they're in partnership with,which makes the mediation a

(03:23):
good avenue to try to workthrough a resolution because
there are a lot of emotionalfactors at play. There's other
family members who may not bein the room who may have an
influence on that outcome.
There may be things other thanmoney who is gonna continue to
run the business. Um, you know,what is the person who is gonna
walk away from the businessgoing to do , um, what are they
gonna focus their efforts on?

(03:44):
There's a lot of intangiblethings that need to be
addressed in resolving thebusiness partnership dispute.
And a lot of those things canbe addressed in mediation much
better than they can in acourtroom, because in a
courtroom they're gonna say,you know, let's sell the
business. Let's break it up.
Let's sell it to somebody.
Let's split the proceeds. And,and you go in your separate

(04:04):
ways. And that, that doesn'taddress all of those
intangibles.

Speaker 1 (04:09):
Well, and I think that, oops, one of the things
that, you know, when, when wewere first talking, whenever I
first came on, even thepodcast, you know, I typically
deal with divorces, anddivorces are gonna be two
people kind of separating. Nowyou said a term which we
actually use very regularly,right. In business and this

(04:30):
business divorce. And let'sjust, and I think you've kind
of talked about it in general,but there is, you know, like
this is normally gonna be whatwe think as a regular partner
dispute, where you either havemultiple partners and you're
buying one in or out, you'regoing apart, but you could also

(04:51):
be coming together, like youcould be pulling things
together as well. So in abusiness divorce, which is kind
of a term that you know, isloosely used, right , um, we're
really talking about allaspects . Like if they own
property, right, if they haveland together, if that business
contracts together, like thisis also like your firm also

(05:12):
deals with a lot of the legalaspects. Like it's not just a
financial aspect, but it's theunwinding as well and
negotiating because not alwaysdo they have money ,
like, and then somebody'swanting to be left. Well, well
, I want the website, well Iwant the logos, the name, and

(05:33):
things like that. So talk to usa little bit more about, you
know, how you're seeing peoplekind of in this space.

Speaker 2 (05:41):
Yeah, I think it's a very difficult situation to
deal with because like I saidbefore, it's someone that
you've known for a long timeand now you're at an impasse.
And that impasse usuallyresults from some type of
communication issue. You havedifferences on how the business
should go forward. You havedifferences on how much you put
in versus the other party. Youdon't value their contributions

(06:03):
as much as your own. Um, wehave theft issues. We, I mean,
there anything under the sun wehave seen when it comes to a
business divorce, there are alltypes of reasons , um, why
people are at this impasse. ButI can say that a lot of the
times it, it comes down toexpectations and communication
and there's some , um, missmal-alignment there with those.

(06:26):
So, and I think you hit on akey point. I mean, it's not
just about the business beingseparated, but a lot of those
businesses own real estate andthat needs to be there , there
are loans associated that withthat, there are guarantees
associated with that , um,people's credit or is tied into
that. So there's a lot ofunwinding that needs to be

(06:48):
done. And there's cases thatinvolve ip, there's products,
there's trademarks, there's, Imean, it, it touches on a lot
of different areas of lawdepending on the type of
business. And the issues tendto be the same, but they can
relate to whatever type ofbusiness people are in. I mean,
we've done hyperbaric chambersto dental offices, to doctors,

(07:10):
to lawyers, to law firms. Imean, there's a lot of , um,
intricacies to being in asituation where one or more
people need to go theirseparate ways and, and the
businesses have beensuccessful. So there's
something to break up. And alot of people feel very close
to, it's almost like havinganother child to the business

(07:30):
that they built from nothing.
And it's now turned out to bevery successful. So they have ,
um, an attachment to, to thebusiness that makes it very
difficult to get past this or,or overcome the impasse and ,
and walk away or take oversomething that they haven't
never run in this capacitybefore.

Speaker 1 (07:51):
Well, and one of the things that I think we'll talk
about are some of the benefitsthat we see in mediation, but
one of the benefits I wonder,and, and you would know more
than I would, is when you'regetting into these mediations
and you have two partnerscoming in, and now they're
actually communicating. Nowthey're actually talking about

(08:12):
at least what they're gonna doto separate. Do you ever see
them come back together? Likeit's like the mediation kind of
jumpstarted them to go backtogether? Or for the most part,
are they ending thatrelationship?

Speaker 2 (08:27):
People do not come to our firm until it's the last
straw in 99% of thesituation. If they could work
it out and we're going to like, uh, get past this and move
forward, they would not beknocking on our door. Okay. Um
, and mediation does not meanthat they're not in litigation.
We have, most of our casesthere has been litigation filed

(08:47):
, and they're at a point in thelawsuit where they wanna pursue
what we call alternativedispute resolution, a way to
resolve the litigation whileit's going on. So there may be
motions being filed, the caseis going forward, but the
parties have voluntarily agreedto, to engage in the mediation
process and go , um, meet witha third party to try to resolve
it. So , um, there's usually alot at stake. And , um, yeah,

(09:13):
it is , I mean, it, it'ssomewhat sad when you think
about it because a lot of thesepeople we've had , um, one case
in particular was a grandmotherand her grandson, and they were
in a very , um, contentiousdispute that ended up going to
trial and getting appealed andwent along for many years and
they never spoke again. Andthey were family members . I

(09:33):
mean, she, she had raised thischild as her own child and they
never spoke again. So there area lot of people who, this is
not something that is going to,you know, be unicorns and
rainbows. They're gonna workthrough it. I mean, that's not
where they're at in thisprocess. The business is gonna
be separated one way oranother. The parties want
freedom from each other. Um,it's not that type of

(09:55):
situation, unfortunately.
That's, that's not really whatwe see.

Speaker 1 (09:58):
Yeah. And, and I think that what we have seen is
that , 'cause I would say forthe most part, most people
start in litigation and thenthey kind of are like, there's
gotta be some other options. Sowe move towards mediation even
as a professional. Right. Butalso in general, like when
you're running a process, Ifeel like you can run both of

(10:19):
them. Like you can have yourlitigation process kind of
working in the background tokeep your deadlines and keep
everybody moving forward. Butthe reality is that most
states, most jurisdictions ,um, you know, are starting more
in the family law arena, but Ithink are going into a lot of ,
uh, other issues that they'rerequiring mediation at the

(10:41):
beginning of a , uh, of asituation, like at least due
two to four hours with somebody, um, in order to see if you
can figure this out because youhave more control. And control
is one of the benefits ofmediation. But talk more about
that because I think thatpeople say, oh, you have more
control over the situation.
That's not really true. You,you have more control over the

(11:03):
input into a solution. But, youknow, where does some of the
benefits, like your favoritebenefits of, of, you know,
minor control and privacy andconfidentiality I think are big
issues that I see benefits formediation. What are some of
yours?

Speaker 2 (11:22):
I think the biggest benefit is time. I think that
people undervalue the emotionalinvestment that goes into being
involved in litigation. I mean,they're up at night thinking
about it, you know, there'sanxiety involved in that and
most of these people are stillrunning a business. So the

(11:42):
emotional energy that you'retaking out of your business and
devoting to this dispute can'tbe replaced. So I think that
that means a lot. And beingable to put this behind you and
move forward without thishanging over your head, I think
makes you a more productivebusiness owner. And, you know,
I see people who are tied up inlitigation for years and you

(12:05):
can't get that time back. Andthere, there are a lot of, what
is the word? Um, I would justsay that they're giving a lot
to the process. And I thinkthat people just don't see how
much, you know, time and energyand thought and, you know, that
they're dedicating to meetingwith their attorneys and coming

(12:25):
up with the next motion andstrategy and discovery.
, just the word discovery. Whenyou need to produce documents,
years of documents of financesand what every dollar that has
come in or go gone out of thebusiness and how this was a
business expense and you know,how the taxes were. I mean,
the, the scope of discovery andcourt these days is very

(12:49):
expensive . And the amount oftime that clients spend
compiling that information andbeing involved in discovery
disputes about pieces of paperthat are lost or weren't given
or redacted or whatever thecase may be, I mean, just takes
a lot out of people. And, youknow, I think that that is one
of the biggest benefits ofmediation. If we can meet over

(13:11):
a couple of days with a thirdparty and reach a resolution
that will put this entirematter behind you forever. I
mean, that is a , a hugeadvantage. Um, but I , I think
there's also a lot to be saidabout the types of resolutions.
There's flexibility inmediation that, you know, the
court and , and most of thecases that go to court, there's

(13:32):
what's called a receiver thatis appointed. It's basically
kind of like a judge, butusually an attorney. And they
get involved in how thebusiness is gonna be split up.
Um, they can bring inevaluator, they can bring in a
forensic accountant, they canlook at the finances, they can,
you know, depose parties. Theycan go to the facilities to see
how the business is run, butthey're basically gonna figure

(13:53):
out how do we sell thisbusiness for pieces and
separate the money between thepeople. Um, it's a very
expensive process. It's a timeconsuming process and um, most
of the time the business ownershave a very good awareness of,
you know, what they need to getout of this to walk away and,
you know, what the bottom lineis or what the best and final,

(14:13):
you know, proposal they wouldtake. And they can do that
without having a third partyimpose that solu resolution on
them . Um, a lot of theresolutions that are reached
between the parties and a thirdin a mediation are more
favorable in my opinion,because there is some buy-in by
the business owners themselves.

Speaker 1 (14:35):
Well, and that , I think that all of those points,
you know, like I could belaborall of them because I think
that those are all important.
Um, the emotional attachment, Ithink it's a big deal. I think
it also is some of thecomponents of what would
prevent a mediation from beinghyper successful. If you have
just people that are so lockedin and can't see any other

(14:57):
options. But you're right atthe, at that point that they're
coming to you, they're, they'vetried all of the other options,
you know, they've, they'velooked at other options and a
lot of times people are lookingor, you know, a lot of
contracts that we, you know, Ihave the benefit of looking at
a million contracts a day withbusiness owners, operating

(15:20):
agreements, you know,shareholder agreements and most
of them, and you know, anysort, anytime you sign anything
to purchase something or youknow, it's always got a clause
of you, even my contracts like,you can't take me to court, but
you can take me to arbitrationin the state of Missouri. And
things like that are , uh, youknow, arbitration and mediation

(15:42):
kind of originated as legalconcepts if you will. They kind
of like fell from the legalsystem. So tell us more kind of
from that framework, like haveyou seen people shift from
arbitration to mediation or isthat still the first place?
Like if you have a multimilliondollar business divorce, you

(16:06):
know, like a $50 million, evena $1 million, like, are you
seeing people still go thatroute of arbitration and what
does that look like? Or are youseeing them shift just straight
to mediation? 'cause there'smaybe less barricades involved
in it ? .

Speaker 2 (16:24):
So I think that for a long time arbitration was
just the go-to businessattorneys would put an
arbitration clause in justabout every ar operating
agreement or other contract.
And it said that the partiesagree a binding arbitration,
and it was either with AAA orJams and there would be maybe a
panel of a couple arbitrators,and that's how this dispute was

(16:45):
going to be resolved. I thinkthere has been a shift , um, to
take arbitration clauses out ofcontracts because it is an
extremely expensive process andit , I'm not sure a lot of
people appreciate the nuancesor differences between
arbitration and mediation, butbasically arbitration is

(17:06):
binding. It's like going tocourt. There's going to be a
person who says, you know,you're right or you're wrong,
or you owe this much money, orthis is how we're gonna resolve
this, and you are bound by it.
And there's usually very littleappeal opportunities after they
come up with an outcome, whichmeans that if they come up with
the wrong outcome or theydon't, you know, review the
facts, there's not much you cando about it. Which is, I guess,

(17:28):
good to the , to some people, Imean, if you're winning, but
you know, there are people whowake , you know, judges have
bad days and they makemistakes. And arbitration can
be a difficult process becausethere aren't a lot of options
if you are on the short end ofthat stick and do not get the
outcome that you want. Um, butit's also very expensive
because when people go tocourt, your tax dollars are

(17:48):
usually paying the judge'ssalary. But in arbitration
you're paying an hourly ratefor the judge, and the judge is
usually very expensive. So ,um, and that judge is going to
be involved in every aspect ofthe case. So , um, every
motion, every discoverydispute, the scheduling order,
and then there's also thisadministrative body that helps

(18:11):
facilitate arbitrations thatyou have to pay for as well.
And there's like a arbitrationcoordinator on every case that
just makes sure that thingsflow smoothly and everybody
gets the information you need.
You pay for them too. So itbecomes very, very expensive.
Um, there's a sliding scalebased upon how much is that is
in dispute of how much you evenhave to pay to initiate an

(18:33):
arbitration. So you could haveto pay $5,000 to even get into
arbitration, whereas the filingfee for a federal court
complaint in Virginia is like$400. So it is a huge
difference in the amount ofmoney that is spent in
arbitration. So I think thatthere has been some shift in
understanding of thedisadvantages of arbitration.

(18:54):
So people are , are leaningaway from that and mediation is
a voluntary process. There'snobody is gonna come in and
say, you have to do this,you're not gonna be bound by
it. You have to reach anagreement that you are okay
with. Both sides have to signon the dotted line. The, the
mediator has no ability toforce an outcome on any of the
parties. Um, and that's why theparties need to be involved in

(19:16):
that. In good faith, they wantto have to be there. I mean,
they, they need to be therewanting to reach a resolution
and put this behind them. Ifone of the parties is not and
has some ill motive, then it isnot gonna be successful. But ,
um, so a lot of the agreementswe see now, especially
operating agreements, say thatbefore you can go to court and
file your lawsuit havinganything to do with the

(19:37):
business or your businesspartner or whatever your
dispute is, you need to try tomediate the issue. And I think
that that is it . It's called ,uh, a precondition before you
can file your lawsuit. So youhave to check this box. And ,
um, you know, some people wouldsay forcing people into a
voluntary process is not agreat idea because if they're

(19:58):
not really doing it becausethey wanna be there, how
successful is it gonna be? Butin my experience, it has been
very successful because a lotof people don't want to be
engaged in litigation. No mamatter how much they hate their
business partner or, or want tobe away from them. Um, they
usually do go into mediationwith , um, good intentions and

(20:18):
good faith and, and we have hadexperiences with a lot of very
good mediators who can get tothe brass tacks of the
situation and figure out, youknow, what are the real
motivating factors here andsave the parties a lot of time
and expense before me before ,um, a lawsuit is filed. So I
would say that compared to 10or 15 years ago, the number of

(20:40):
mediation clauses that I see inoperating agreements has
increased tenfold.

Speaker 1 (20:47):
Well, I think that mediation clause that you just
said, or even anything is waymore brilliant than just
forcing to arbitration because,and I can only say from a
perspective of understanding ,you know , like I do a lot of
business divorces, but I do alot more independent, you know,
individual divorces and we alsohave collaborative divorce
where you're signing anagreement and you're gonna be a

(21:10):
part of it. And witharbitration you're signing an
agreement and you're gonnaagree that, that you're bound
by those decisions. The problemis in some capacity is that we
as humans want control overwhat we're gonna have to be
part of. And like you said, it,you, I think you said it
earlier, is the , the buy-in.
If you, if you don't have bothsides saying, Hey, we're

(21:32):
probably gonna have to come toan agreement that's not the
best for either one of us,right? But we're going to have
to get out of it. I think thatfor the most part, people don't
wanna be bound to a system, beit court, be it arbitration, be
it any system that requiresthem to take spoonfed what a
third party is going to sayabout that dispute. And that's

(21:55):
how mediation is also differentfrom some of those is that yes,
nothing's gonna bind you to doit, but also the fact that, you
know, it's like even workingwith kids, like if both of them
, uh, come up with thesolution, the odds are they're
gonna champion that solution tothe end. And there are steps

(22:16):
you're gonna have to likechange the, you know, like all
of these things that takeadditional time that aren't
solved in like in , in the,even in the arbitration, they
would just say, okay, great,split this and you keep this
and you keep that, then youhave to go for months and
unwind those things legally.
Whereas if you go to the right,and, and this is one of the

(22:37):
things that maybe we could talkabout a little bit, but you
know, it really does mean thatyou need to go to the right
mediator. And I think thateverybody in business or in the
world thinks that mediation islike the same thing. You know,
like it's just like, and it'sin a black box. So I really
don't know what it is, but Iknow it's all the same. The

(22:57):
reality is it's very differentfor all of these purposes. I
mean, you even have like peoplewho are just doing labor
disputes, people who are justdoing landlord tenant disputes,
you know, like you really haveto find the right connection.
But as a business owner, youknow , like if, if we are not
getting along, and maybe itdoesn't have to be to the point

(23:19):
of like, I hate you and I don'twanna be partners with you, but
like, we just need to go ourseparate ways. We have two
great ideas for the future. Wedon't totally don't get along,
but that conversation'suncomfortable 'cause we're
friends, our families hang outtogether. We don't wanna ruin
this relationship. A lot oftimes this is to prevent the
ruining of that relationshipbecause you have the mediator

(23:42):
that's asking those hardquestions. Right. But in
general, what do you think abusiness owner would need to do
to even consider? 'cause Iwanna step back like, hey, you
and I are, we're just notjiving like we were and we've
been partners for a long time,we have some stuff to separate.
We think we could do it, but wedon't know if it's fair. We

(24:03):
don't know if it's reasonable.
Um, then what would they firstdo? Do they need to first
contact you? One of them orboth of them? Like how do they
even get ready for this processand have it be very
transparent?

Speaker 2 (24:20):
So I think the process is the most productive
when there is sufficientpreparation. And I have a
athletic background, so it'ssimilar to just, you know, you
wouldn't go join a basketballteam and show up for the first
game without learning therules, you know, talking to the
coach, going to a practice andsome people just feel like, I'm

(24:42):
just gonna show up and whateverhappens, happens. And I do not
agree that that is going to bea very productive way to, I
mean, there's a lot ofpreparation that goes in and
there's a lot , um, kinda liketherapy. I mean, you really
need to think about what it isthat you need to get out of
this. Like what, so the legalor negotiation terms for this
are bota and wna , right? Whatis your no deal option? If I do

(25:05):
not reach a resolution at thismediation, what's the worst
thing that's gonna happen? Orwhat is the best thing that's
gonna happen? Because you needto have some parameters walking
into it about, you know, thisis a good deal because this
could happen if I don't takethis deal. And if you do not
think through those scenariosand try to figure that out
before you step in the room,how do you know that the deal
that you agree to is a goodone? And it also leads to

(25:29):
buyer's remorse because youwake up the next day and say,
why did I agree to that? Youknow, I mean there's a lot of ,
um, pressure to an extent. Imean, you may be in a
unfamiliar environment, I mean,so there's a lot more virtual
mediations now, but um, thereare also a lot of in-person
mediations where you're in aroom that you've never been in
for a very long amount of time, um, you know, whether you

(25:52):
have dinner on time, whetheryou've been there 12 hours, you
know, you're getting tired.
There's all kind of like , uh,environmental elements that are
at play. And to the extent thatyou are very clear on what it
is you need to walk away withfor this to be a good deal. I
mean, that means to be set instone before you walk into the
room. And I've just seen toomany people just , or lawyers

(26:14):
just, you know, we'll justfigure it out. That's, this is
not the situation where you getthere and try to figure it out.
Just like any sport, like thisis not where you just, you
know, jump in the pool and say, I'm gonna swim a 500 meter
race. This is not that. There'sa lot of preparation that goes
into just thinking about thosescenarios and calculating and
that that may be a mathcalculation. You know, what is

(26:35):
the business worth? Let's lookat the numbers, you know, how
much do I need to walk awaywith , um, to feel like, you
know, I got, you know, what Ideserve in this situation. Um,
a lot goes into picking themediator. I say a lot, just
because it's a good attorneydoes not make them a good
mediator. Just because they'rea good judge does not make them
a good mediator. A mediator hasa specific set of

(26:58):
qualifications that I thinkmake them really good. Um,
there are two things that theyhave to be able to do, and
there's two hats I should saythat they have to be able to
wear. One is a facilitator ofinformation and other is an
evaluator of information. Andthey have to switch between
these two things at the righttime during the mediation. So
there are points in themediation where they need to
say, look, you have a bad, youknow, your , your case is not

(27:21):
that good. like that isnot gonna be that persuasive.
Or, you know, your credibilityon that issue is not the best
because of these other thingsthat you've done that kind of
conflict with what you'resaying right now. And they need
to be able to do that in a waywithout making the person feel
bad, right? They cannot beat upon the person and then expect
them to, you know, engage inthis voluntary process and ,

(27:44):
and really get the outcome thatthey want. So I think that
really good mediators have away of delicately saying that,
but allowing the person in theroom to, to understand what
they're saying, right? Andthere are people who just wanna
force information down theirthroat or say, look, if you go
to court, you're gonna lose.
Like, that's, that's not theway to get people to buy into

(28:08):
the solution that they need.
And I think that good mediatorsrecognize that, and they're
very good at , um, allowingpeople to feel heard, but also
evaluating the merits of whattheir position is in a neutral
way. Um, so the person doesn'tfeel like they're taking sides
or against them. Um, but, butmoving the parties to, to a

(28:29):
solution. I mean, the, themediator is going to have to go
into one side or the other andsay , look, your portion is not
worth what you think it's like that , that's an
inevitable conclusion becausein every business of worse , we
handle, I call it, it's calledthe Ikea effect. If you build
something from ikea, you feellike it's worth more than what
you bought it for because youput your hard earned , you

(28:53):
know, work and effort intodoing it, you just feel like
it's worth more. Now you have astory to tell about it. I was
like, putting this together allnight, like now it's worth
more. It's the same thing withthe business. Like you put your
sweat and tears and time intothis business, even if you are
50 50 partners, inevitably onepartner is going to believe
that their portion is worthmore. And, and that's just

(29:14):
human nature because you feellike the other person isn't
doing half as much as you are,right? Right. But the mediator
has to be able to come in andsay, look, but this is a
mathematical, you know, youknow, we can look at time, we
can look at, you know, how muchthe business is worth. We can
look at, you know, what yourroles are. I mean, there is a
way to, to logically , um,figure out exactly what your

(29:39):
portion is worth. And somepeople do not want to hear what
that is. So I think that a goodmediator is able to communicate
that information in a way thatthe person does not feel
defensive or attacked or, youknow, like , uh, I think that
that's the key. So I think thatthat is more important than the
mediator having a wealth ofknowledge in the area. Um, it

(30:02):
could, you know, you could havesome very complicated IP
dispute and yes, the mediatorcould have like 20 years of
education and, you know,mediated all types of disputes
or been a judge that justspecifically did trademarks
for, you know, decades. Butthat is not the skill that I
think is the most importantwhen choosing a mediator. So in
preparation for a mediation, Ilike to reach out to other

(30:24):
people who have used thatmediator , um, or preferably
use the mediator that wealready have used that
we know that is gonna be verygood. Um, and, and ask that
question, you know, and it's,it's not about what the
mediator's resume is, it'sabout what are their statistics
on resolution. And, and I thinkthat that goes a long way.

(30:47):
There are mediators, 95% of thetime they reach a resolution,
and that's not because theyknow the ins and outs of every
practice area and issue thatcomes before them . So , um, so
I would say the big things insome are, are the mediator
preparing, selecting a mediatorthat that is gonna be good,
that has some knowledge aboutthe practice area, but really

(31:07):
is, is a persuasive , um,individual that is able to, to
wear those hats at the righttimes. Um, thinking about the,
the best case and the worstcase , um, I think environment
is important. If there's a waythat we can do it, I say home
court advantage, let's do that.
So I offer my office to theextent we can, let's have it

(31:27):
here so the client can, youknow, they've seen it, they've
been there, that , that plays alot into, you know, success in
people's comfort levels. So ,um, virtual , um, can be
preferred where people can beat home and in their own
element. So that's important.
Um, you know, I think thoseare, are are the big ones.
There's a lot goes intopreparation though, so

Speaker 1 (31:48):
Well, and I think that

Speaker 2 (31:49):
All of those things kind of go to preparation

Speaker 1 (31:50):
When I ask somebody, you know, like I'll say, oh,
did you prepare for thatmediation? And they'll be like,
no. And I'm like, okay, wellthen in , in those cases where
I know the other side has notprepared, like, I will always
win, I will always get over insome capacity because you don't
know the numbers. And so, andyou're making decisions in real

(32:12):
time , which is hard for somepeople, you know? So if it's
hard for you to make a decisionin real time , you practice the
decisions beforehand, you say,okay, what would I say? You
know? 'cause it's really like,would I say yes to that or
would I say no to that? And youhave to be clear. Like
sometimes you don't know whatyou'd say yes to, but you know,
what you would say no to. Andeven having that understanding.

(32:34):
But one thing that I think thatpeople , um, get a little
confused that you can maybe fixa little bit is that I think
one of the reasons why theydon't prepare for mediation is
because they think they'regoing into the mediation and
the mediator is going to savethe day, come up with the
perfect solution and tell themwhat to do. Like it is a judge.

(32:57):
And so they're kind of like,well, I mean, they know what to
do. I don't, I'm just there forthe ride. You know, like, I
think that that is a hugemisconception and that if
you're not planning ahead, ifyou're not preparing, if
you're, and , and quitefrankly, there might be other
people, like you could go intomediation and you could have

(33:18):
your own valuation person, youcould have your own ip, you
know, expert. You could havesome of, or these people might
already be in your company, youknow, like you might be just
talking about these things andgetting feedback from the
mediator, but the mediator kindof gives you a view of what

(33:39):
somebody is gonna look at fromthe outside of the situation
and give you an honest opinion.
But don't you think that a lotof people come into mediation
planning, like, okay, wellwhat's your solution kind of
situation?

Speaker 2 (33:54):
I think so, and as an attorney from my vantage
point, there should be nothingthat the mediator says during
this mediation that you haven'theard, right? But there are
situations where I know thatthe opposing counsel has not
told their client a huge issuewith their case or has not

(34:16):
conveyed it to them in the waythat they need it to be
conveyed, right? And so my jobis to come in and convince the
mediator of how big a weaknessthis is to their case, and to
get the mediator to go into theother room and say something to
the other person's client thatthey have not heard or haven't
heard in that way, right? So Ithink a lot of people also

(34:38):
think, well, it's just neutraland they're just moving
information back and forth andthey're just shuttling stuff.
And no, we want most of themediator's time to be in the
other room, , you know,trying to get them to come to
the number or whatever thesolution is that, that, you
know, there's gonna be somecompromise for sure. But we

(34:58):
wanna know what that realm ofcompromise is, and we want to
be prepared. You know, I willgo into a mediation and say,
look, we know this is ourweakness. I will say that to
the mediator. You do not needto tell my client the weakness.
We know what the weakness is,but you know, this is what we
need them to focus on. And Ithink that mediators appreciate
that because they're not gonnaspend 25 minutes telling my

(35:19):
client that, you know, this isa weakness that we know we
know, but we need to focus onthese things to get to this
number. And I think that , um,people, I , I don't know why.
We'll just, you know, just,we'll, we'll see what happens,
attitude. And I, I think thatthat is a losing proposition
. So , um, if you havea media , uh, lawyer who just

(35:39):
says, all right , well, we'rejust gonna show up and see what
happens. If it doesn't settle,we'll just go to trial and, you
know, we'll just keep itmoving, then I don't think that
they're really, you know,giving mediation the, the time
and energy that would make iteffective.

Speaker 1 (35:52):
Well, and I think you've already even talked
about one strategy of how touse , um, you know, mediation
to your advantage. I think thepreparation is a piece of it.
It it gets you very clear. Um,I typically tell people that
the mediator is not yourtherapist. You should not tell

(36:12):
them everything. That youshould really be telling them
your best version of this storyin order for them to take that
to the other side and be like,okay, well here's where they're
coming from. Right? I also,like, one of my little fun
things is I create kind of a ,a , uh, cheat sheet that I'm
more than willing to be. Youknow, like sometimes mediators

(36:35):
will request information. Maybeyou can talk a little bit about
that, that a lot of timesmediators will want some
information upfront , so youwould need to be prepared for
this. Um, but, but also havingyour own cheat sheet so that
you stay focused, you stay, youknow, concerned about the big
points in mediation , um, andyou're not getting all

(36:56):
distracted by all the minutiae,right? Which could take time ,
you know, like if you have todescribe an event that happened
five years ago, and it takes ahalf an hour to tell the story,
you're losing some time whereyou could talk about the really
big issues . So what are someother strategies that you think
you know, and can you gain anadvantage? Like should you be
manipulating the system andthings like that? So, so what

(37:19):
are you , some of your , uh,super tricks?

Speaker 2 (37:23):
So before the mediation starts, there's
usually a meeting with theattorneys and the mediator to
discuss the framework of themediation. And at that meeting,
the mediator sets a deadlinefor the parties to submit a
statement. And that statementis very important. I mean,
that's, that's the opportunityfor you to basically give your

(37:46):
opening statement to, tooutline the strengths and
weaknesses, to give a analysisof what settlement discussions
have occurred and why theyhaven't been productive to lay
out, you know, the issues thatyou need the mediator to step
in on and evaluate or helpfacilitate a resolution of. And
I think that that is apersuasive piece. And I think

(38:09):
that some people would viewthat as just some type of
informational document. It isnot, in my opinion, this is
your first opportunity toconvince them that, you know,
your client is entitled to Xand it needs to be written in
that way. Our client isentitled to X because they did
these things, you know, and,you know, these are the
documents that support that.

(38:29):
Um, I see a lot of attorneyswrite a book, like a , a novel
on, you know, no mediator wantsto read your novel. You need
to, you know, this is short,sweet, to the point. Like,
let's summarize. Like, this isnot the time to attach the
entire gear long litigation ofpleadings. Like, there are some
key points. We are about toargue this motion and our

(38:50):
likelihood of success is Xbecause of these two key things
that are either gonna go ourway or they're not. Like that's
the summary that needs to be inhere. And I think that the , an
advantage, a huge advantagegoing into a mediation is , um,
putting a lot of time andeffort into making that very
persuasive. We use a lot ofcharts, a lot of times. I was
just in a mediation not toolong ago, and there were a lot

(39:13):
of parties involved, and all ofthe business names were very
similar. It was like A, B, C ,A, B, C, D, A, B, C, D, E .
Like for whatever reason, theydecided to name all these
entities very confusing. And,and I , I don't know, it was
just a mess. And I was like,for purposes of this statement,
we are gonna change the namesof all the parties to things

(39:34):
that relate to, you know,memorable things. So all of
these entities were tied todifferent properties, which
were on specific streets. SoI'm like, we're gonna call this
one green 'cause this relatesto this green property, you
know, we're gonna call this onered, you know, so that, and the
mediator was like, this makesso much sense, right? So in the
mediation, the mediator startsthen using the terms that we

(39:57):
put in our document. And theother side, obviously this is a
confidential document, so theother side is not seeing the
document and they're like, youknow, what, what are you
referring to? And themediator's like, well, it was
so confusing with the names.
And then, you know, this sidedecided to, you know, tie them
to these specific things thatmake them very easy to
understand. And they startedusing the language that we put

(40:19):
into the statement. That's whatyou want. You don't want them
to come in confused . Andthere's all , you know , like
you want them to adopt thelanguage. And those words mean
a lot. I had another case, I'lljust for an example where , um,
they kept calling a , a thirdparty who was involved like the
fraudster or some kind ofnegative connotation to this

(40:41):
person, and they put it in alltheir pleadings and they kept,
oh no, it wasn't the, it wasthe whistleblower. That's what
they kept calling this person,right? And I was like, this, we
have to change the terminologythat we are gonna use to refer
this person because that's nothelping us, right? So we need
to put into this statement,this person is not the
whistleblower. We don't knowwhy they keep calling them that

(41:04):
they're a third party witness.
They have this information.
We're not gonna call them thatin this mediation because
that's not, I mean, that'sframing the issue in a way that
benefits them. And I want tomake that apparent that that is
what they're doing. We don'twant this to just, you know,
people will start using wordsand not even understand the
association that they have withthose words . So we want to
make this statement persuasivein a way that benefits us. And

(41:26):
that I think helps the mediatorwalk into the mediation , um,
in a more favorable position toour client. And I think that
that is an undervalued , um,tactic. I I think a lot of
people spend 10 minutes on thisstatement and then just say,
we'll see, you know , we'lljust talk about it when we get
there. I , I don't think thatthat helps anybody gain an

(41:46):
advantage to the media issue .
I think that's a key indicator.

Speaker 1 (41:50):
And one of the things that I'll kind of go
through as we prep the clientfor a mediation, especially
when we're talking aboutnumbers, is I want them to know
the numbers, right? But I alsowant everybody to understand
the cadence of the mediationand the cadence and who's
speaking and who's, you know,especially if you have clients
and everything involved, youwant them to understand like

(42:12):
when they should speak and whenthey shouldn't. But I try to
get them to focus on like threeto five central points and that
we will always like a mantrakind of go back to like, we're
here for this and this and thisand, and, and then lump all of
these other extra issues intoone of those three categories.
Because I think the client getsvery distracted by the minutiae

(42:33):
of the issue and the attorney,you know, like, 'cause there's
a lot of different ways to domediation, but if you know the
parties are there and you havea mediator in the middle , um,
you know, you're, you're reallytrying to containerize and
summarize in a big picture tothe mediator what those three
points are. So if you can getthose three points across, then

(42:53):
when you pull in an ancillaryissue, you're like, well, that
does fall under, you know, thesecondary point that we've
always been talking about. Andthen you have kind of these
things that you can continuetote, say, in a very consistent
manner. Like I do that fortestimony as well, but I think
it's very helpful in amediation because then
everybody in the room is kindalike, oh, okay, yeah, these

(43:16):
three points. These threepoints, right? And if the other
side is all distracted by ahundred points, then again,
you're getting the focus , uh,the attention of the mediator
on your issues and maybe not onsome of theirs. 'cause it's
like, you know, you're , you'retrying to collect rainwater
here. Like, I don't know whereyou're going with this, but

(43:37):
it's not very clear. But Ithink being understanding what
the mediator requests andrequires at the beginning is
important. And understandingthat if you have a lawyer
involved, that sometimes theywill put together too much.
Like you might have to helpthem, even if you're the
business owner, understand thethree main business points, and

(43:57):
then you combine them with thelegal points, right? Because
you could have financial issuesand legal issues and all of
that, but what are your centralkind of concerns? Right?

Speaker 2 (44:08):
That's a really good point . Um, I think that being
a business owner and beinginvolved with another person in
a business or another couplepeople for years, there are a
lot of issues. It's usuallynot, you know, this one big
thing. I mean, there'sdifferent personalities,
there's lots of decisions thatneed to be made. There's lots
of feelings that you stillharbor about decisions that
have been made five years ago.

(44:29):
So I think that your pointabout, you know, having those
key points, like a theme helpskeep things focused. Because I
think that if you go off ontotoo many of those tangential
issues, it can distract fromreaching a resolution on the
big, big ticket items thatyou're there to resolve.

Speaker 1 (44:48):
Well, because even like conceptually, you know,
I've talked to mediators thatwould say, I only do two hour
mediations at a time, or youknow, like if I'm gonna be
talking about the valuation, Ia two hour window for people to
ask questions to go through it,it, it, it is still drinking
from the fire hose . Like theyare still taking in so much

(45:10):
information that they're justoverloaded at that point,
right? But in mediations wherewe're dealing with that is one
piece of it, and we have allthese other pieces, it could be
an entire day mediation. Youknow? So even preparing for
that level of attention, youknow, do you need fuel? Do you

(45:34):
need food? Do you need liquids?
Do you have the capability tosit in that capacity for that
amount of time? You know?
'cause that puts stresses onthe negotiations , right? So
understanding what is involved,which kind of, I mean, I guess
goes into a little bit of like,when you're looking for a

(45:55):
mediator , um, and you have avery complex financial matter .
You know , I I think a lot ofit comes down to your
specifics. Some people wentin-person, some people went
online. Some people wantdifferent types of situations.
I don't think people understandthat these mediation firms that
are really coming about. And,and even if you are a mediator

(46:18):
in space, you have other kindof people that are
professionals in this mediationspace, right? You have the
accountants that understand it.
You have evaluated , you havereal estate appraisers, you
have, you know, I , you haveother attorneys that talk about
like the IP and things likethat. So it's not just looking
for a mediator, it's also maybelooking for what their

(46:42):
resources are or you know, likedon't assume that just because
they're one person that it'sreally one person. You know,
like a lot of times themediators will have staff and
they'll have other people thatthey might pull in depending
upon the issue. But what, whatare you kind of telling people
to look for and , and how areyou guys kind of unique in that

(47:03):
capacity?

Speaker 2 (47:04):
Yeah, I think that is a really good point. I mean,
a lot of times there are anumber of experts that are
required to speak to differentissues, and there has to be a
decision made about whetherthey need to be there on the
day of the mediation, whetherthey can prepare something in
advance that can be submittedto the mediator. Um, and, you
know, those logistics can bespecific to, you know, the

(47:26):
situation that you're in. But ,um, you know, know it is good.
We, we use a mediation grouphere that has a lot of
resources. Um, they have, it isa group of retired judges from,
you know, federal courts, statecourts, different states in our
area. So, you know, they havepeople who have decided just
about every case under the sunand, you know, have a lot of

(47:49):
good statistics on theirmediation success rates, which
is something that we look for.
So, you know, I, I think it'sjust important to have that
conversation. Um, I see a lotof people just choose randomly
mediators and not put anyeffort into who is gonna be, I
think they think that theprocess is not gonna be that
effective, so they don't wantto invest too much time into

(48:10):
it. But I think it's one ofthose things that the more time
you invest into it, the morelikely it is to be successful.
So , um, I , I certainly don'tlook at it that way. And we
have a very, we have had somevery favorable resolutions for
our clients in mediation. So Ithink it's just, you know,
putting the effort in and , andthe preparation in , you know,
looking into the mediator'scredentials and success rates

(48:32):
and the resources and, youknow, experts that may be
needed and anything else. Ithink it's just all of that
goes to preparation.

Speaker 1 (48:40):
Yeah. And, and I think there's something to be
said about, you know, werecently , um, hired a mediator
in a case, and it was a veryspecific mediator that we knew
from prior experience couldeffectively communicate what we
needed, right? And it, itwasn't because like we would

(49:02):
control them, it was that theyhad a way of kind of calming
this chaos, right? That otherpeople would all be very
defensive, but their way isjust beautiful. And I think
that in some capacity, youknow, the mediator is just a
conduit, like the preparationthat goes into, and, and

(49:24):
realistically, if you wannacontainerize any of the costs
in this kind of process,especially because, you know,
partner disputes, like, who'sgonna pay for it? Is the
company paid for it? Or are youindividually paying for it?
Right? When you get involved inthe process and you're vetting
the people and you're preppingsome of the information and you

(49:45):
are doing this, what is, whatis your hourly rate zero? You
know, like, yes, it's a costbenefit of pulling yourself
from your business, but themore you know , like this is an
opportunity for you to put yourtime and effort into finding
something that you know, likeeven fits with you and your
partner, right? Uh , uh, in ,in the conversa. And , and then

(50:07):
you talk around and say, okay,are they good at business? Have
they done this? Have you seensuccess? What have they done?
It's the same type ofsituation. It's not foolproof,
but you can have a little bitmore insight into it and
understand, you know, from thatcapacity. So, and I, I think

(50:27):
for the most part, if you'regonna go about mediation as a
business owner, you have toknow that you're gonna be part
of that process. Like, not froma controlling standpoint, like
you're gonna dictate it, butyou are gonna be part of the
creativity if there is to beany of how something, you know,
like, oh, well, we can't justsplit this all up. It has to

(50:48):
be, you know, protect this andprotect that and do that, and
don't worry about that. Andwhat about the employees? You
have that capability to protectall of those interests, but you
are gonna have to put your timeand effort into it as well. And
that, and if you just wanted tobe solved by lawyers and the
court, then you go to trial andyou let them deal with it. But
the mediation is more like,Hey, I think if I am a part of

(51:10):
this, I think we can get itresolved, right? Because I am
the business owner, I am thecreative person that, that
thinks that they can come upwith something. Um, but maybe
you should tell us a little bitmore about you, your firm, how
you handle people, how you dealwith people, and how you maybe

(51:31):
came about to do , uh,mediation, because we all have
a fun story about mediation,but maybe, maybe you have a fun
one to tell .

Speaker 2 (51:41):
Yeah, so I , um, we have a law firm in Northern
Virginia, and I practice inMaryland, DC and Virginia. We
help people , uh, build,protect, and resolve disputes
concerning their business. Um,99% of my practice is business
divorces. So we handle lots ofdifferent situations that

(52:02):
business owners face. And Ithink that what makes us
uniquely qualified is, youknow, I, I'm a business owner,
so, you know, I I getthe struggles and the late
nights and the, the commitmentand energy that is required to,
to build a business. And, youknow, a lot of those things are
at stake. And I think the, thebiggest shift that, that we

(52:25):
have to discuss with our clientis, you know, they're
successful business owners. Andwhat makes this process hard is
that there's an emotionalaspect to it. If this was just
a business decision, it wouldprobably be very easy for them
to do. But we appreciate thefact that this is not just
about money. It's not just abusiness decision. There's a
relationship that existedbefore the business that is
influencing a lot of what'sgoing on. So, you know, we have

(52:48):
to, we have to be aware ofthat. We have to, to take that
into consideration in ourconversations. Um, even if
that, that relationship isbeyond repair, it is going to
have an effect on our clients.
And I think that, that peoplelike working with us because we
have empathy towards, towardsthat situation and , and

(53:08):
understanding of, you know,that aspect of it. Um, there
are certainly lots of lawyerswho have experience in business
and can value things and , you know, give you an
analysis of what it's worth.
But, you know, there's in , inmy opinion, more to it than
that there's a, there's anotheraspect that that needs to be
weighed. And I started withthat, you know, there's,

(53:28):
there's an emotional toll thatthese type of situations take.
And, you know, you have to becognizant of that if you gotta
survive this and , uh, behealthy for yourself and your
family. So, you know, we, we,it's our job to help you
through that process. So I havebeen doing this for over 15
years and , um, you know, Ireally love it. I like working

(53:49):
with , um, business owners whoare brilliant individuals and,
you know, help them, you know,tackle this problem and move on
to other successful businessventures. So , um, or, or just
running their business on theirown. That's also a , a very big
difficult step that some peoplehave to take if you start
something with other people andare now in a position where

(54:09):
you're gonna have to do ityourself. I mean, that is a
mindset shift as well. So, youknow , um, we work with people
in all stages of that processand walking them through that
and helping them in thattransition is really something
that's very close to my heart.
So that's what we enjoyed .

Speaker 1 (54:23):
Well , I think that that is really impressive
because that is, you know, ifyou go into mediation or
litigation, or even I went intomath , um, because I thought
that numbers were more fun thanemotions , um, then you have to
be mindful that you can doeverything right from a

(54:43):
financial aspect and a legalaspect and a mediation aspect,
but the emotions could stillprevent the settlement. And so
I think that you bring up avery valid point that, you
know, it's about beingunbiased, but it's not about
being unemotional orunempathetic, it's about

(55:03):
recognizing it. It doesn't meanthat we have to go into it, but
we can recognize it as acontainer, as a safe space in
order to do some of this. But Ialso see people that are
helping in mediation, lawyers,financial people, that we are
that consultant, like we arehelping you kind of efficiently
go through this mediationprocess in a way that hopefully

(55:26):
both parties, you know, come toa favorable decision. But in
the long run, you're hiringkind of a consultant to help
you in this process. And forthe most part, it's a better
process than litigation is. Um,it's a little bit more
controllable, right? Butthere's room for all of them.
What we've seen is to do aparallel as well. And so you

(55:48):
would be doing a litigationstrategy and a mediation
strategy if you believe thatthat is what's necessary. So it
is getting the right people inthe right room to give you your
options to allow you to havethose decisions to be made ,
um, and to have a say at it.
But we appreciate your time.
Um, is there anything else youwanna kind of say about

(56:09):
mediation that you think, youknow, is really amazing? I
mean, I talk about a lot.
People kind of get tired of mesaying it's the wave of the
future. Like, you need to be apart of it. Like, it's so
great, but, you know. Yeah . Doyou have anything more to add?
Yeah,

Speaker 2 (56:26):
No, you know, I think we've covered it. I, I ,
I , I do think it is a greatprocess. I think it's very
beneficial and, you know, itdoesn't solve every problem.
Every case is not resolved inmediation. It's certainly not a
slam dunk for all cases. But,you know , there are some very
favorable outcomes that comefrom mediation and I'm
certainly a huge proponent of,of trying it, giving it a try.

(56:47):
I think it is worth the effort, um, and time involved in
going through the process. So,you know, if you were to ask
me, I would say yes, ,you should try mediation no
matter what point you're in.
Um, in your case it can bebefore a lawsuit is filed, it
can be after a trial, whilesomething is on appeal. We
have, you know, mediationthat's at all stages of cases
and, and have been, I I am ahuge proponent of it.

Speaker 1 (57:11):
Yeah. And I think that the, the only thing that
I'll say about finding somebodyto work with, because again,
since it's so new , um, newerfrom acceptance standpoint,
from acceptance, you know, frombusiness owners and courts and
all of that , um, work withsomebody who has a process.

(57:32):
'cause if they have a process,the odds are they've done this
for more than just a year ortwo. You know, they've really
cultivated how they can do itwell. So , um, I appreciate all
your knowledge and hopefullywe'll have you back on to talk
more about business divorcesand, and how we do valuations.
But we appreciate your time,Margo, and they can reach you
if they have questions, right?

(57:53):
Because you work around thecountry, it's not just in the
east coast, right?

Speaker 2 (57:59):
Yes. We consult on a lot of cases , um, around the
country that involve businessdis business disputes and
business divorces. Yeah . Sofeel free to reach out. Um, I
would love, you know, this is,this is my passion and I'd love
to speak with anyone that wecan help through this process.

Speaker 1 (58:16):
Yeah. And I'd love to say that there are a lot of
people out there like you, butthere aren't . And so,
you know, I really think thatthis is a space that is gonna
blossom and there will be moreproviders around the country.
But for right now, you know,seek out some people that
really know what they're doing.
And Margot, I feel is one ofthem . So we appreciate you and

(58:36):
we'll see you soon.

Speaker 3 (58:44):
A huge thank you for tuning in to another episode of
mediator podcast.com. Allepisodes are produced and
edited by Ellie Marketing . Ifyou're interested in starting
your own podcast, head over toour website, ellie
marketing.com. Thank you again,and stay tuned for more
episodes.