July 9, 2025 • 28 mins
Episode 25: Amazon's Dirty Discovery Tactics
Amazon dropped a steaming pile of objections to discovery responses and Karen and Mo are not having it. In this episode of The Velvet Hammer™, they unpack Amazon’s absurd responses to basic discovery requests, like refusing to identify their experts or disclose insurance. Karen compares it to getting “pooped on from the sky,” and Mo brings out his alter ego, Ruthless Mo, to call out the obstruction for what it is: a total waste of time and a deliberate attempt to bury the truth.
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Transcript
Episode Transcript
Available transcripts are automatically generated. Complete accuracy is not guaranteed.
Mo Hamoudi (00:00):
Yeah, so Monday, beautiful day so sunny come to
office and guess what you getpooped on?
Yeah, pooped on by Amazon.
Amazon poop.
Karen Koehler (00:14):
It is like bird poop.
It drops out of the sky, itgoes splat.
It's totally ugly, stinky andamusing all at the same time.
Mo Hamoudi (00:23):
Okay, what I call disclosure.
We do not have ananti-disparagement agreement
with respect to this case thatwe're going to talk about with
Amazon, and why don't you tellus what we're talking about
today, karen?
Karen Koehler (00:40):
Okay, so they sent us poo-poo.
As I already said, we served ina row.
Well, okay, start at thebeginning.
A different lawyer had thiscase and realized that they were
being taken advantage of andbrought it to us to handle.
So we got involved and Amazonwas very unhappy with that.
Mo Hamoudi (01:01):
They were very unhappy with it.
Karen Koehler (01:03):
And we filed a minute complaint, which they
were very, very, very unhappy.
And then we served a discoveryon them.
So, so unhappy Very much, soVery, very, very the case had
been going on for a couple well,for a year at least, before we
got involved.
Yes, we turned everythingaround.
So then they got the discovery.
And then what did they do?
Mo Hamoudi (01:24):
They didn't give us that.
They gave us 11 pages.
Karen Koehler (01:26):
No, they asked for a continuance.
Mo Hamoudi (01:29):
Oh wait, that's right.
They asked for one extensionand we were courteous.
Karen Koehler (01:34):
And then what did they do after the first
extension?
Mo Hamoudi (01:36):
They asked for a second extension.
Karen Koehler (01:38):
A second, because they're working so hard
on this discovery.
I mean, amazon has layers andlayers and layers of
administration.
They have about a thousandlawyers on the case, in-house
and out-house, and what did weget?
Mo Hamoudi (01:54):
Bubkis A poo-poo Bubkis.
We got nothing, man.
Karen Koehler (01:59):
It's so bad and I know you guys don't believe us
, so here we go.
This is just.
Mike Todd (02:06):
We should like start having a star system for who can
do good or who can't I meanthis would be a minus, okay.
Karen Koehler (02:15):
So question number one tell us who your
experts are.
Now there are new court rulesthat say if you have an expert
or any information you can't saywell, we'll give it to you when
the case schedule, when thetime that the judge sets is
right there is no time that thejudge set that's right for
discovery other than timely.
(02:36):
So it says identify each personyou expect to testify at trial
as an expert.
Okay, answer.
Mo Hamoudi (02:43):
Amazon has not yet determined which experts it
expects to testify at trial.
If and when such experts areretained, appropriate disclosure
in accordance with the casemanagement order will be
provided.
Karen Koehler (02:56):
Okay, do they have experts?
Mo Hamoudi (02:59):
I don't think they have experts.
Karen Koehler (03:00):
They could have experts.
They could have experts.
I don't know.
Mo Hamoudi (03:03):
Well the case is so old For them to say they don't
have experts.
They could have experts.
They could have experts, Idon't know.
Well, the case is so old Forthem to say they don't?
Karen Koehler (03:07):
have experts?
This says no, but they don'tsay that.
They say they've not determinedwhich experts will be
testifying at trial.
Mo Hamoudi (03:12):
That means they have them.
Karen Koehler (03:14):
Thank you.
Mo Hamoudi (03:15):
And they just don't want to tell us.
Karen Koehler (03:17):
They're not going to tell us until the case
management schedule says butthat's against the rule.
Mo Hamoudi (03:22):
That's not the rule .
Okay, rule breakers.
Karen Koehler (03:24):
Okay, so when they're bad and they do stuff
like this, who follows up?
Mo Hamoudi (03:30):
Kristen does, and then I do.
Karen Koehler (03:32):
Wait, you got to do the Ruthless Mo thing.
Mo Hamoudi (03:34):
Oh it's.
Karen Koehler (03:35):
Okay, when we follow up with this, who will be
following up?
Ruthless Mo?
Ruthless Mo will be followingup.
Mo Hamoudi (03:44):
Ruthless Mo.
Ruthless Mo will be followingup.
Karen Koehler (03:48):
And what will Ruthless Mo be doing?
Mo Hamoudi (03:49):
Be ruthless.
Karen Koehler (03:51):
Okay, but you've got to show how ruthless you
are.
Mo Hamoudi (03:54):
I'm going to tell him give me my discovery, give
me my documents.
I want it and I want it now.
That's what I'm going to do.
He is too.
Karen Koehler (04:05):
All right, I'm going to do he is too.
All right, it's going to beworse than that, though.
Mo Hamoudi (04:08):
It is going to be worse than that.
I'm in a good mood, it's sunnyoutside and you're asking
Ruthless Mo to come out.
It's going to take a little bit, but I've got to read more of
these and I'll get angry.
Karen Koehler (04:18):
All right.
Number two identify anddescribe all the facts upon
which your denial of liabilityis based.
Okay, let's stop here Now.
Liability means cause of theincident.
Mo Hamoudi (04:31):
Okay, yeah.
Karen Koehler (04:33):
I think that the Amazon driver was going the
wrong way down the highway.
Mo Hamoudi (04:36):
Yes, yes.
Karen Koehler (04:38):
Okay, yes, right , yes, there shouldn't be too
much dispute in that.
Going down the wrong way of thehighway yes, all right, there's
a little bit more, becausethere's also vicarious liability
.
We just asked for liability,okay, so remember their driver
was going which way down thehighway Wrong way.
(05:01):
The wrong way down the highway,and so it should be pretty
simple, right?
Yes, okay.
Mo Hamoudi (05:08):
But it's not simple .
There is a complete paragraphof.
Karen Koehler (05:14):
No, you've got to read it because it's so bad.
Okay, as fast as you can.
Mo Hamoudi (05:18):
Amazon objects to this interrogatory as it is
overbroad, unduly burdensome andnot reasonably calculatedly the
discovery of admissibleevidence.
This interrogatory impersonallyseeks to obtain impressions,
conclusions and opinions ofcounsel.
As it seeks informationprotected by the attorney,
client privilege and work,product doctrine, discovery
exemptions afforded consultingexperts, trial preparation
materials and our informationafforded any other applicable
(05:40):
protection or privilege,plaintiffs refer to the general
denials and Amazon's answer toplaintiffs' amended complaint
and to the affirmativeallegations and our affirmative
defense and so forth.
Therein Amazon further objectsto the extent this
interrogatory's prematurediscovery is ongoing and calls
for investigation up to andincluding in the time of trial,
subject to and without waiving.
Karen Koehler (06:00):
First, of all, you did that really good.
Okay now.
So they make this hugeobjection and now they're.
This huge objection, yes, andnow they're going to answer, are
they?
Mo Hamoudi (06:11):
Kind of this is so silly.
Amazon responds that it did notemploy the defendant.
The defendant was anindependent contractor under the
terms of his agreement withAmazon.
Amazon did not employ orcontrol any person involved in
the accident, nor was Amazonpresent at the scene, nor does
Amazon have any personalknowledge of the accident.
Any damages sustained byplaintiff as a result of
(06:37):
plaintiff's own contributorynegligence and or the unforeseen
superseding intervening acts ofdefendant over whom Amazon had
no control, additionalaffirmative defense is pled in
the case other than supersedingnegligence, or apportionment
were pled to preserve them onthe basis that facts would come
in light as an investigation anda discovery process gives rise
to the basis.
Such affirmative defenses arefrom allegations.
In the absence of completion,pretrial discovery and
additional information thatshould be revealed by discovery
(06:58):
proceedings, includingdepositions, amazon does not
possess sufficient informationto fully respond to this
interrogatory at this time.
Mike Todd (07:08):
Amazon reserves the right to supplement its response
to this interrogatory.
Mo Hamoudi (07:12):
I think you're ready to do a side job as an
auctioneer?
I think so.
Sold, sold for $5.
Mike Todd (07:17):
Sold for $5.
Karen Koehler (07:17):
There was nothing said in this whole
answer.
Mike Todd (07:20):
No.
Mo Hamoudi (07:21):
What?
No, there wasn't.
Karen Koehler (07:23):
Wait, wait, Mike .
What happened in this accident?
Mike Todd (07:27):
I don't know I just told you, we told you oh, the
guy was driving the wrong waydown the freeway.
Yes, okay, say that right.
Karen Koehler (07:35):
I mean, uh, yeah , yeah, I, that's an easy one I
I'm confused as well.
Mike Todd (07:41):
I I feel like if you're driving the wrong way
down the freeway, we're not justtalking about like a one-way
alley or something like that,we're talking about the freeway.
Karen Koehler (07:52):
Okay, we go to interrogatory number three and
now what they're going to do.
See, remember that answer wejust read.
Mo Hamoudi (07:59):
Yeah.
Karen Koehler (07:59):
They're going to invoke it, so Are they wizards?
Like the next series ofquestions, will just say hey,
see our answer to that one thatwe just did.
Mike Todd (08:10):
Yeah, exactly.
They're just going to keepsaying go back to that long
answer.
That meant nothing.
Karen Koehler (08:14):
So we ask number three, we ask if someone else
is involved, and they say hey,go back, we invoke it.
They say specify all facts uponwhich your affirmative defenses
are based.
They invoke it.
Okay, oh my God, okay.
Mo Hamoudi (08:33):
You know, okay, I'm going to have a discovery
conference with these guys andI'm going to tell these lawyers
why are you wasting my time?
Now I'm getting angry.
I am reading this.
This is an entire waste of mytime, entire waste of my time.
Why did they do this?
Why?
Karen Koehler (08:52):
did they do this ?
This is why Amazon lawyers saythat Mo is not cordial, of
course.
Mo Hamoudi (08:58):
This is an entire waste of my time.
Karen Koehler (09:00):
Why are?
Mo Hamoudi (09:01):
you making me read these words.
Karen Koehler (09:04):
After two requests for continuances.
Who does this?
Mo Hamoudi (09:09):
What kind of professional drafts responses
like this?
This is an entire waste of mytime.
This is an entire waste ofresources.
This is worse.
The denials here, the denialshere.
These people are untetheredfrom truth, from reality.
They're irrational.
(09:29):
He's going off.
No, I am.
This is pissing me off because,okay, all right, stop, all
right.
Karen Koehler (09:37):
All right, ruthus Moe, I backed you off.
Mo Hamoudi (09:40):
Okay.
Karen Koehler (09:40):
Okay, interrogatory number five this
is one that the courts havedrawn up.
This language, by the way, isall kind of form language.
The questions, and this one isa form question.
It's basically regardless ofwhether you agree that you're
faulted or not, tell us all,each, identify, each and every
(10:03):
policy of insurance maintainedby you that may apply to the
claims or may be liable tosatisfy, or any part of the
judgment, and that includes thename of who's insured, the
entity who issues a policy, thepolicy limits, the policy
periods, any exclusions, anydecisions affecting coverage,
(10:25):
and go on and on and on.
Now, again, this is basically acourt-based request.
Mo Hamoudi (10:34):
Like do you have insurance?
Do you have insurance?
Do you have insurance?
Not a trick question and justto clarify for me.
Mike Todd (10:42):
This is the insurance that amazon has, not their
third party.
Yeah, this is this.
Karen Koehler (10:47):
These are responses to amazon just amazon.
Mike Todd (10:50):
This is only there's a whole separate set of
attorneys that are dealing withthe other side.
Mo Hamoudi (10:55):
Okay all right okay amazon objection is in their
octagon grounds it is overlybought and duly burdensome,
seeks irrelevant information andis not reasonably calculated to
lead to the discovery ofadmissible evidence.
You under breath and scope ofAmazon's insurance program and
the circumstances of thisaccident render this
interrogation excessive, giventhe facts and claims in this
litigation, amazon furtherobjects to this interrogation on
(11:17):
the basis that it seekssensitive and confidential
proprietary business informationyeah, sensitive and proprietary
business information as to itsinsurance.
Karen Koehler (11:26):
Sensitive like emotional, they might cry.
Mike Todd (11:30):
I think they are crying.
Mo Hamoudi (11:31):
Additionally, Amazon objects to this
interrogatory misleading,assumes facts not in evidence,
as Amazon did not employ orcontrol any person involved in
the accident, nor was Amazonpresent at the scene, nor does
Amazon have any personalknowledge of the accident.
Further, Amazon objects to thisinterrogatory to the extent it
requires Amazon to make adetermination as to available
insurance coverage.
Karen Koehler (11:50):
Subject to Okay so.
Mike Todd (11:52):
Wait, they just said that they don't have any
awareness of the accident.
Karen Koehler (11:57):
Yeah, Because, they weren't present at the
scene.
Mo Hamoudi (12:00):
Well, they were present at the scene.
You know how they were.
They're tracking those thingsDigitally present.
Mike Todd (12:06):
The scene.
Might they track all those?
I mean because it's an Amazonbranded van that they were
driving right.
Karen Koehler (12:12):
No, no, this is different, not this one.
This is the Flex program.
Mo Hamoudi (12:14):
This is the Flex program.
Karen Koehler (12:26):
Yeah, but they still have their little phone to
carry around, so they knowwhere they are, they know what
they're doing.
All right, okay, or I assume?
All right, we're not going tolike we don't have to say who
their insurance companies are?
No, I won't say okay.
However, it says after layingout a certain amount of coverage
.
It says a certain amount ofcoverage.
Mo Hamoudi (12:43):
It says Well, it says that After laying out a lot
of how much their limits are,it says the part where it says
any policy beyond this scope,beyond this yeah, any policy
beyond this is beyond areasonable scope of the present
case and therefore not relevanthere, given the nature of the
facts and claims that issue inthis litigation.
If plaintiff's counsel believesdisclosure of higher levels of
(13:04):
the insurance tower is necessaryin this case, counsel can
schedule a CR26I conference.
Karen Koehler (13:11):
If we think that we're going to get a lot of
money, then they might have togive us more information.
Mo Hamoudi (13:17):
More insurance.
So they're basically tellingyou how much the claim is worth.
Okay.
Karen Koehler (13:20):
They think it's worth, then they have to sign a
certification.
Mo Hamoudi (13:25):
Why do they do that ?
Why do they have to sign thatone and not the other ones?
Karen Koehler (13:28):
Well, they're supposed to sign all their
objections.
You know, supposedly that wasthe old school.
Mo Hamoudi (13:34):
Yeah.
Karen Koehler (13:34):
But in this one they're supposed to write down
the name and sign it of who ismaking the special certification
, Because, shocker, we've had somany cases where they've lied
about how much insurance isavailable.
Mike Todd (13:49):
Not they, not just.
Karen Koehler (13:49):
Amazon.
Mo Hamoudi (13:50):
Yeah, not Amazon.
Karen Koehler (13:51):
Other, other people.
So for all of these defendants,we always put the special
certification.
This is not a special Amazonprovision.
Okay, all right, so I want to.
We've got two, and we alreadytalked about the sanctions
certification.
This is not a special Amazonprovision.
Mo Hamoudi (14:01):
Okay, all right, so I want to.
We've got two and we alreadytalked about the sanctions
orders.
We did.
Karen Koehler (14:07):
From the case where they signed certification
and lo and behold, there was waymore insurance.
Mo Hamoudi (14:12):
Okay.
So now I want to talk to youabout and get some insight.
We have these two particularinterrogatories that they have
not really responded to,interrogatories that they have
not really responded to.
What's the process of goingthrough and scheduling a 26I
conference and talking to them,and how would you approach that
conference with answers likethat.
Karen Koehler (14:37):
Oh, I still want to go through all of them.
Oh, you want to go through allof them.
Okay, wait, okay wait, we'llpick another one because you
know because.
They're very similar.
Mo Hamoudi (14:45):
They're all very similar.
All of them tell us tobasically go pound sand.
Karen Koehler (14:48):
But in addition to the interrogatories, of which
, again, none of them.
Mo Hamoudi (14:57):
And an interrogatory is A question Okay
, a question, that's all Okay.
Karen Koehler (15:02):
But they include the discovery request, includes
request for production, meaning.
So we're asking for documents,yes, so let's see which one do I
really like here?
I think well, they don't likeany of them.
Mike Todd (15:23):
None of them.
Karen Koehler (15:24):
None of them.
They're all the same objections.
So pick whatever your favoritequestion is and read it to us.
Mo Hamoudi (15:32):
Tell me which number I would say Okay.
Karen Koehler (15:40):
Which one?
Mo Hamoudi (15:42):
I'm looking, I'm looking, I'm looking.
Uh, I would say request forproduction number 14 oh my gosh,
you really went down yeah,because I think that's an
important one okay.
Karen Koehler (15:54):
Quest for production number 14 all
documents related to the amazonflex program, including policies
, procedures and guidelinesapplicable to drivers.
Okay, that's the shortestsubject of all of them.
Yeah, okay, go ahead Well justfor our sake.
Mo Hamoudi (16:10):
The Flex program is a program where you can take
your personal car and then youcan enter into an agreement with
Amazon and use your personalcar to deliver Amazon packages.
Mike Todd (16:21):
It's like being an Uber and are you an independent
contractor when you're doingthat?
Mo Hamoudi (16:25):
By contract, you are.
Mike Todd (16:27):
Who then?
So you individually are, you'renot under the umbrella of a
third-party company.
Mo Hamoudi (16:35):
No, you're not.
You're an individualcontracting with Amazon.
Now, Karen can educate youright now about vicarious
liability very quickly.
Karen Koehler (16:45):
If Amazon controls you while you're doing
the job, enough, then you are ina relationship with.
Mike Todd (16:52):
Amazon.
That was my question.
Is you're actually working forAmazon?
Karen Koehler (16:57):
Happens all the time in our Uber cases and our
Lyft cases.
Mike Todd (17:01):
It's the same with Uber and Lyft.
They try to play that same gameand they've lost that several
times now, right.
Mo Hamoudi (17:08):
So what we're asking for is documents related
to that program and policies andprocedures and guidelines that
Amazon imposes on their drivers.
Mike Todd (17:17):
And they're objecting to that.
Mo Hamoudi (17:18):
Well, yeah, they're objecting to it.
Well, yeah, they're objectingto it.
No-transcript.
(17:50):
In this litigation, amazon alsoobjects to the extent this
request seeks information and ordocuments protected from
disclosure by theattorney-client privilege to
work, product doctrine or anyother applicable protection
protection.
Mike Todd (18:02):
Yeah, that's a lot of words and I'm just going to say
no, because all of that to thatI heard is them trying to say
our policies don't affect us atall.
But how can they not whenthey're saying that that
person's not an employee?
Karen Koehler (18:20):
they do.
They're just being beingobstructionists.
Mike Todd (18:22):
Yeah, they're just trying to stand in the way and
slow everything down, so ittakes longer and longer.
Mo Hamoudi (18:27):
This is why I got angry earlier.
Mike Todd (18:29):
Oh yeah, I honked the horn Okay.
Mo Hamoudi (18:31):
Okay, so I want to.
Karen Koehler (18:32):
No, self-education, I'm going to
read this.
Mo Hamoudi (18:35):
Okay, all right.
Karen Koehler (18:36):
It was my idea, dang it, okay, sorry.
Mo Hamoudi (18:44):
okay, I thought I was trying to back off.
Karen Koehler (18:45):
Okay, I'll back off okay, um, we are now going
to role play.
Oh, we are.
Yes, I love it.
Yes, we are.
I sent a letter this morning toamazon that said dear amazon,
did you see my letter?
No, let me see the letter Isaid dear, okay, you can read my
letter I want to read theletter and then we'll go from
there okay, okay, and you senthim an Amazon response to this.
I sent a note, an email.
Okay, okay okay To Mr, I can'tremember.
Mo Hamoudi (19:09):
Oh, dear counsel, our team just took a vote and
agreed that these are some ofthe worst incomplete,
over-objectedto, non-responsiveanswers to discovery we've seen.
Please sign the verificationpage specifically regarding
(19:29):
insurance PS.
Disclosure of all insurancemeans all Mohammoudi will be
taking the lead in shepherdingyou properly through the
discovery process.
Oh, you've tasked me already,karen.
Okay, all right.
Mike Todd (19:48):
I imagine you in an Indiana Jones outfit, with the
whip.
Karen Koehler (19:51):
Yes, so they already know what's coming If
they've done their due diligence.
Well, they have know what'scoming If they'd done their due
diligence?
Mike Todd (20:03):
Well, they have to because you just got done
working with them.
What, oh yeah.
Mo Hamoudi (20:09):
Well, okay, here's the fun part.
They don't know what's comingon Friday and this is not going
to be published until after,After they file the motion for a
protective order and theobjection I'm gonna file for the
judge to enter the protectiveorder.
It's going to be a doozy.
I've been working on it.
It's going to be a big one.
Karen Koehler (20:29):
Okay.
Mo Hamoudi (20:29):
That's going to be fun.
Karen Koehler (20:30):
Stay back on track.
Mo Hamoudi (20:31):
Okay, I'm back on track.
Role playing I'm role playing.
Yes, okay, all right, back ontrack.
Karen Koehler (20:37):
So we're going to have our first discovery
conference, in this case, yeah.
It's going to be Mr Amazon.
Yeah, is it?
Mike Todd (20:46):
going to be in person .
Karen Koehler (20:49):
No, they never wanted to be in person.
Yeah, oh.
First of all, what are yougoing to ask them?
Mo Hamoudi (20:54):
What do you mean?
Karen Koehler (20:55):
Before we set up the call what do we want to do?
Mo Hamoudi (20:59):
We want to record this.
Hey, do you mind if we record a26I conference?
Yeah, no that's not going tohappen, okay, well, we're going
to move to ask the judge torecord it.
Karen Koehler (21:10):
On what basis?
Mo Hamoudi (21:12):
Judicial efficiency , transparency and the fact that
you have obstructed discoveryin another case.
I'm going to attach the orderswith the judge.
Karen Koehler (21:20):
Well, we disagree.
Mo Hamoudi (21:21):
Okay, great, fine, we'll go with that.
Okay, fine, I went to.
Karen Koehler (21:24):
Harvard.
Mo Hamoudi (21:25):
Oh Harvard, yes, Harvard you Harvard.
Oh Harvard, yes, harvard youwent to Harvard.
Go ahead, keep going.
Okay, how about them apples?
You went to Harvard.
When are we going to get ourdiscovery?
Karen Koehler (21:39):
Did I tell you I went to Harvard?
Mo Hamoudi (21:41):
No, you did tell me you went to.
Karen Koehler (21:43):
Harvard.
Yeah, I just want to make sureyou knew that.
Mo Hamoudi (21:46):
Okay, well, since you went to Harvard and you took
probably civil procedure, youprobably understood in civil
procedure do you have anobligation to give me discovery,
so why haven't you given mediscovery?
Karen Koehler (21:57):
We did give you discovery.
Mo Hamoudi (21:59):
Okay, let me ask you another question.
Do you know what happened to myclient?
Do you know how much injuriesthey sustained?
Are you aware of that?
Karen Koehler (22:06):
You know I'm really sorry that the defendant
driver hit them, but we havenothing to do with them.
Okay, by the way did you knowthat I went to Harvard?
Mo Hamoudi (22:15):
All right, you say that one more time.
All right.
Karen Koehler (22:19):
Are you threatening me, Mr Hummity?
Mo Hamoudi (22:21):
If you say that one more time.
Karen Koehler (22:23):
You are being uncollegial.
Mo Hamoudi (22:24):
If you say that one more time I'm going to talk to
you about where I went tocollege I If you say that one
more time.
Karen Koehler (22:28):
I'm going to talk to you about where I went
to college.
I don't care about where youwent to college.
You are nothing.
You are a peon.
I represent Amazon and I wentto Harvard.
Stop breaking character.
Mike Todd (22:43):
It's hard because you just keep saying you went to
Harvard over and over.
You keep saying Harvard.
Mo Hamoudi (22:51):
But I just have a simple question Are you going to
give me the documents that Ineed to prove that your client
is liable for this collision?
Are you going to do that?
Karen Koehler (23:03):
We've already given you 11 pages of documents
and if you want the rest, weneed a protective order because
everything we do is top secret.
You don't understand.
The whole balance of the worldrelies upon Amazon.
We are so essential to everysingle thing in the whole wide
world.
And did I tell you that I wentto Harvard?
Mo Hamoudi (23:22):
Yeah, you told me you went to Harvard.
Karen Koehler (23:24):
Anyway, we need a protective order and we'd like
you to agree to that, and allthat it'll say is that we're
going to show you some documentsand then we're going to take
them away and you've got topretend they never existed and
never tell anybody about them,and we're going to hide them
back where they came from.
We might destroy them, but wemight also hide them, and they
(23:44):
should never see the light ofday.
But we really don't want togive them to you, because did
you go to Harvard?
I didn't think so.
I mean, I don't know if we cando the pinky swear code.
Mo Hamoudi (23:53):
No, but I went to a non-ABA accredited school.
That's where I went.
Oh my God, I can tell you thatI bartended at nights when I
went to school.
Mike Todd (24:01):
Hold on just a second yeah.
Hold just a second yeah.
Karen Koehler (24:07):
Rebecca, this guy did not go to Harvard.
Can you believe it?
I mean, what the heck?
I don't even know how tocommunicate with them.
Maybe didn't they say to dothat on like a fifth grade level
.
Mr Hamoudi, let me repeat, weare very important.
Mo Hamoudi (24:32):
Yeah.
Karen Koehler (24:33):
These documents are very, very top secret, top
secret.
You know like I spy with mylittle eye, yeah, yeah, yeah.
You cannot get them because youdid not go to Harvard.
Mo Hamoudi (24:50):
I'm going to destroy your client.
That's it.
Karen Koehler (24:53):
Mr Hamoudi, that's not very polite.
Mo Hamoudi (24:56):
I know it's not Because I'm done being polite.
Karen Koehler (24:59):
You are mean Mr Malou, mr Hamoudi?
Mo Hamoudi (25:03):
yes, I am done I am finished.
I am finished with you.
Okay, I am going to extractaccountability out of your
client one way or another, andthat's what I'm going to do.
I don't know.
Karen Koehler (25:15):
Mr Hamoudi, that's not how we act in Harvard
.
Mo Hamoudi (25:19):
I don't care, I need you to respect me.
I am not a Harvard student.
Karen Koehler (25:21):
I am a big bad lawyer, way bigger than you.
And see, there are 20 lawyersover here sitting here and we're
all taking notes of yourbehavior.
Mike Todd (25:32):
I think we need to record this conference then yeah
, I was going to say, if theyallowed it to be recorded,
they'd have a lot of proof andhad you agreed in the first
place, you would have had reallygood evidence to tell this
judge.
Karen Koehler (25:41):
All right, this meeting has to be concluded
because you're mad and mean andwe don't play that.
Mo Hamoudi (25:49):
That's just the way I am.
That's literally kind of how itgoes.
I believe you.
Mike Todd (25:56):
I'm sure.
I'm just curious.
Can you ask them if it's?
Mo Hamoudi (26:05):
a policy for their drivers to go the wrong way on
the freeway?
Yeah, you could ask them that.
They're just not going toanswer it.
Oh, I'm sure they're going tosay they're not their drivers
the way they're, they don't knowthe way they've designed this
is that you have amazon and youhave lawyers that work for
amazon okay, then lawyers thatwork for amazon hire law firms
okay to do their work, and whatthey do is these lawyers are not
(26:26):
, they have no power.
They go to lawyers for Amazon.
We have a discovery conference,it's strip matter firm again,
and what do we do?
And they go.
You do nothing.
So they come in and go.
My hands are tied, I can't doanything.
So what we're going to do iswe're going to reveal that
dynamic to the judge that theseguys are nothing, they have no
(26:47):
power, they have no say, andwhat you're dealing with is a
bunch of lawyers sitting downhere on Terry Avenue in Seattle,
too cowardly to show up in thecourt and step up and defend
their client.
Karen Koehler (27:02):
Ruthless Mo go away.
Mo Hamoudi (27:05):
Okay, I'm going away.
Mike Todd (27:08):
Sorry, I'm winding him up, you wind me up, but,
karen, it's the truth, karen.
Mo Hamoudi (27:10):
Okay, I'm going away.
Sorry, I'm winding him up, butyou wind me up, but, karen, it's
the truth, karen.
Karen Koehler (27:13):
Okay, okay.
Mo Hamoudi (27:14):
It's the truth.
Okay, it's the truth.
It's gone, but you summoned himand then now you're saying go
back His eyes got really darkwhen he was talking to me.
Karen Koehler (27:22):
He really hated the you know, oh, you were
firing me when I talked to himin little boy language.
Mo Hamoudi (27:27):
But the thing is is that she was playing the part
and then I love her so much Ican't get angry at her.
You did, though I just wasstarting to get a little and I
was like what is she?
Mike Todd (27:38):
doing.
She did good by just bringingup Harvard that many times,
because that can wind you up forsure.
That winds me up for sure.
Karen Koehler (27:46):
Although I am very proud of Harvard right now.
Oh, that's the thing I wasgoing to say.
Mike Todd (27:50):
Politically, it's a play on the fact that a lot of
hoity-toity lawyers do that, butreally Harvard does good work.
Karen Koehler (28:01):
They went and bowed to the king and so I'm
happy with them.
So maybe I should have said,yale, we'll do that next time,
next time, say Yale, say Yale,we'll do that next time, next
time, say Yale Say Yale, Don'tsay Harvard Anyway this is the
story of our lives.
Mo Hamoudi (28:13):
Yeah.
Karen Koehler (28:13):
Going about our way, just trying to do our job.
Mike Todd (28:17):
Just asking questions and getting the same answer
over and over again After tworequests, because you know they
needed more time to write theseobjections.
Of course.
Karen Koehler (28:25):
They didn't.
Mo Hamoudi (28:31):
Well, because they have to have meetings with the
other firms that they've hired,so they can tell them not to
answer, all right.
All right, okay, we're done,okay, yes, bye, bye.
Yeah, so Monday, beautiful day so sunny come to
office and guess what you getpooped on?
Yeah, pooped on by Amazon.
Amazon poop.
Karen Koehler (00:14):
It is like bird poop.
It drops out of the sky, itgoes splat.
It's totally ugly, stinky andamusing all at the same time.
Mo Hamoudi (00:23):
Okay, what I call disclosure.
We do not have ananti-disparagement agreement
with respect to this case thatwe're going to talk about with
Amazon, and why don't you tellus what we're talking about
today, karen?
Karen Koehler (00:40):
Okay, so they sent us poo-poo.
As I already said, we served ina row.
Well, okay, start at thebeginning.
A different lawyer had thiscase and realized that they were
being taken advantage of andbrought it to us to handle.
So we got involved and Amazonwas very unhappy with that.
Mo Hamoudi (01:01):
They were very unhappy with it.
Karen Koehler (01:03):
And we filed a minute complaint, which they
were very, very, very unhappy.
And then we served a discoveryon them.
So, so unhappy Very much, soVery, very, very the case had
been going on for a couple well,for a year at least, before we
got involved.
Yes, we turned everythingaround.
So then they got the discovery.
And then what did they do?
Mo Hamoudi (01:24):
They didn't give us that.
They gave us 11 pages.
Karen Koehler (01:26):
No, they asked for a continuance.
Mo Hamoudi (01:29):
Oh wait, that's right.
They asked for one extensionand we were courteous.
Karen Koehler (01:34):
And then what did they do after the first
extension?
Mo Hamoudi (01:36):
They asked for a second extension.
Karen Koehler (01:38):
A second, because they're working so hard
on this discovery.
I mean, amazon has layers andlayers and layers of
administration.
They have about a thousandlawyers on the case, in-house
and out-house, and what did weget?
Mo Hamoudi (01:54):
Bubkis A poo-poo Bubkis.
We got nothing, man.
Karen Koehler (01:59):
It's so bad and I know you guys don't believe us
, so here we go.
This is just.
Mike Todd (02:06):
We should like start having a star system for who can
do good or who can't I meanthis would be a minus, okay.
Karen Koehler (02:15):
So question number one tell us who your
experts are.
Now there are new court rulesthat say if you have an expert
or any information you can't saywell, we'll give it to you when
the case schedule, when thetime that the judge sets is
right there is no time that thejudge set that's right for
discovery other than timely.
(02:36):
So it says identify each personyou expect to testify at trial
as an expert.
Okay, answer.
Mo Hamoudi (02:43):
Amazon has not yet determined which experts it
expects to testify at trial.
If and when such experts areretained, appropriate disclosure
in accordance with the casemanagement order will be
provided.
Karen Koehler (02:56):
Okay, do they have experts?
Mo Hamoudi (02:59):
I don't think they have experts.
Karen Koehler (03:00):
They could have experts.
They could have experts.
I don't know.
Mo Hamoudi (03:03):
Well the case is so old For them to say they don't
have experts.
They could have experts.
They could have experts, Idon't know.
Well, the case is so old Forthem to say they don't?
Karen Koehler (03:07):
have experts?
This says no, but they don'tsay that.
They say they've not determinedwhich experts will be
testifying at trial.
Mo Hamoudi (03:12):
That means they have them.
Karen Koehler (03:14):
Thank you.
Mo Hamoudi (03:15):
And they just don't want to tell us.
Karen Koehler (03:17):
They're not going to tell us until the case
management schedule says butthat's against the rule.
Mo Hamoudi (03:22):
That's not the rule .
Okay, rule breakers.
Karen Koehler (03:24):
Okay, so when they're bad and they do stuff
like this, who follows up?
Mo Hamoudi (03:30):
Kristen does, and then I do.
Karen Koehler (03:32):
Wait, you got to do the Ruthless Mo thing.
Mo Hamoudi (03:34):
Oh it's.
Karen Koehler (03:35):
Okay, when we follow up with this, who will be
following up?
Ruthless Mo?
Ruthless Mo will be followingup.
Mo Hamoudi (03:44):
Ruthless Mo.
Ruthless Mo will be followingup.
Karen Koehler (03:48):
And what will Ruthless Mo be doing?
Mo Hamoudi (03:49):
Be ruthless.
Karen Koehler (03:51):
Okay, but you've got to show how ruthless you
are.
Mo Hamoudi (03:54):
I'm going to tell him give me my discovery, give
me my documents.
I want it and I want it now.
That's what I'm going to do.
He is too.
Karen Koehler (04:05):
All right, I'm going to do he is too.
All right, it's going to beworse than that, though.
Mo Hamoudi (04:08):
It is going to be worse than that.
I'm in a good mood, it's sunnyoutside and you're asking
Ruthless Mo to come out.
It's going to take a little bit, but I've got to read more of
these and I'll get angry.
Karen Koehler (04:18):
All right.
Number two identify anddescribe all the facts upon
which your denial of liabilityis based.
Okay, let's stop here Now.
Liability means cause of theincident.
Mo Hamoudi (04:31):
Okay, yeah.
Karen Koehler (04:33):
I think that the Amazon driver was going the
wrong way down the highway.
Mo Hamoudi (04:36):
Yes, yes.
Karen Koehler (04:38):
Okay, yes, right , yes, there shouldn't be too
much dispute in that.
Going down the wrong way of thehighway yes, all right, there's
a little bit more, becausethere's also vicarious liability
.
We just asked for liability,okay, so remember their driver
was going which way down thehighway Wrong way.
(05:01):
The wrong way down the highway,and so it should be pretty
simple, right?
Yes, okay.
Mo Hamoudi (05:08):
But it's not simple .
There is a complete paragraphof.
Karen Koehler (05:14):
No, you've got to read it because it's so bad.
Okay, as fast as you can.
Mo Hamoudi (05:18):
Amazon objects to this interrogatory as it is
overbroad, unduly burdensome andnot reasonably calculatedly the
discovery of admissibleevidence.
This interrogatory impersonallyseeks to obtain impressions,
conclusions and opinions ofcounsel.
As it seeks informationprotected by the attorney,
client privilege and work,product doctrine, discovery
exemptions afforded consultingexperts, trial preparation
materials and our informationafforded any other applicable
(05:40):
protection or privilege,plaintiffs refer to the general
denials and Amazon's answer toplaintiffs' amended complaint
and to the affirmativeallegations and our affirmative
defense and so forth.
Therein Amazon further objectsto the extent this
interrogatory's prematurediscovery is ongoing and calls
for investigation up to andincluding in the time of trial,
subject to and without waiving.
Karen Koehler (06:00):
First, of all, you did that really good.
Okay now.
So they make this hugeobjection and now they're.
This huge objection, yes, andnow they're going to answer, are
they?
Mo Hamoudi (06:11):
Kind of this is so silly.
Amazon responds that it did notemploy the defendant.
The defendant was anindependent contractor under the
terms of his agreement withAmazon.
Amazon did not employ orcontrol any person involved in
the accident, nor was Amazonpresent at the scene, nor does
Amazon have any personalknowledge of the accident.
Any damages sustained byplaintiff as a result of
(06:37):
plaintiff's own contributorynegligence and or the unforeseen
superseding intervening acts ofdefendant over whom Amazon had
no control, additionalaffirmative defense is pled in
the case other than supersedingnegligence, or apportionment
were pled to preserve them onthe basis that facts would come
in light as an investigation anda discovery process gives rise
to the basis.
Such affirmative defenses arefrom allegations.
In the absence of completion,pretrial discovery and
additional information thatshould be revealed by discovery
(06:58):
proceedings, includingdepositions, amazon does not
possess sufficient informationto fully respond to this
interrogatory at this time.
Mike Todd (07:08):
Amazon reserves the right to supplement its response
to this interrogatory.
Mo Hamoudi (07:12):
I think you're ready to do a side job as an
auctioneer?
I think so.
Sold, sold for $5.
Mike Todd (07:17):
Sold for $5.
Karen Koehler (07:17):
There was nothing said in this whole
answer.
Mike Todd (07:20):
No.
Mo Hamoudi (07:21):
What?
No, there wasn't.
Karen Koehler (07:23):
Wait, wait, Mike .
What happened in this accident?
Mike Todd (07:27):
I don't know I just told you, we told you oh, the
guy was driving the wrong waydown the freeway.
Yes, okay, say that right.
Karen Koehler (07:35):
I mean, uh, yeah , yeah, I, that's an easy one I
I'm confused as well.
Mike Todd (07:41):
I I feel like if you're driving the wrong way
down the freeway, we're not justtalking about like a one-way
alley or something like that,we're talking about the freeway.
Karen Koehler (07:52):
Okay, we go to interrogatory number three and
now what they're going to do.
See, remember that answer wejust read.
Mo Hamoudi (07:59):
Yeah.
Karen Koehler (07:59):
They're going to invoke it, so Are they wizards?
Like the next series ofquestions, will just say hey,
see our answer to that one thatwe just did.
Mike Todd (08:10):
Yeah, exactly.
They're just going to keepsaying go back to that long
answer.
That meant nothing.
Karen Koehler (08:14):
So we ask number three, we ask if someone else
is involved, and they say hey,go back, we invoke it.
They say specify all facts uponwhich your affirmative defenses
are based.
They invoke it.
Okay, oh my God, okay.
Mo Hamoudi (08:33):
You know, okay, I'm going to have a discovery
conference with these guys andI'm going to tell these lawyers
why are you wasting my time?
Now I'm getting angry.
I am reading this.
This is an entire waste of mytime, entire waste of my time.
Why did they do this?
Why?
Karen Koehler (08:52):
did they do this ?
This is why Amazon lawyers saythat Mo is not cordial, of
course.
Mo Hamoudi (08:58):
This is an entire waste of my time.
Karen Koehler (09:00):
Why are?
Mo Hamoudi (09:01):
you making me read these words.
Karen Koehler (09:04):
After two requests for continuances.
Who does this?
Mo Hamoudi (09:09):
What kind of professional drafts responses
like this?
This is an entire waste of mytime.
This is an entire waste ofresources.
This is worse.
The denials here, the denialshere.
These people are untetheredfrom truth, from reality.
They're irrational.
(09:29):
He's going off.
No, I am.
This is pissing me off because,okay, all right, stop, all
right.
Karen Koehler (09:37):
All right, ruthus Moe, I backed you off.
Mo Hamoudi (09:40):
Okay.
Karen Koehler (09:40):
Okay, interrogatory number five this
is one that the courts havedrawn up.
This language, by the way, isall kind of form language.
The questions, and this one isa form question.
It's basically regardless ofwhether you agree that you're
faulted or not, tell us all,each, identify, each and every
(10:03):
policy of insurance maintainedby you that may apply to the
claims or may be liable tosatisfy, or any part of the
judgment, and that includes thename of who's insured, the
entity who issues a policy, thepolicy limits, the policy
periods, any exclusions, anydecisions affecting coverage,
(10:25):
and go on and on and on.
Now, again, this is basically acourt-based request.
Mo Hamoudi (10:34):
Like do you have insurance?
Do you have insurance?
Do you have insurance?
Not a trick question and justto clarify for me.
Mike Todd (10:42):
This is the insurance that amazon has, not their
third party.
Yeah, this is this.
Karen Koehler (10:47):
These are responses to amazon just amazon.
Mike Todd (10:50):
This is only there's a whole separate set of
attorneys that are dealing withthe other side.
Mo Hamoudi (10:55):
Okay all right okay amazon objection is in their
octagon grounds it is overlybought and duly burdensome,
seeks irrelevant information andis not reasonably calculated to
lead to the discovery ofadmissible evidence.
You under breath and scope ofAmazon's insurance program and
the circumstances of thisaccident render this
interrogation excessive, giventhe facts and claims in this
litigation, amazon furtherobjects to this interrogation on
(11:17):
the basis that it seekssensitive and confidential
proprietary business informationyeah, sensitive and proprietary
business information as to itsinsurance.
Karen Koehler (11:26):
Sensitive like emotional, they might cry.
Mike Todd (11:30):
I think they are crying.
Mo Hamoudi (11:31):
Additionally, Amazon objects to this
interrogatory misleading,assumes facts not in evidence,
as Amazon did not employ orcontrol any person involved in
the accident, nor was Amazonpresent at the scene, nor does
Amazon have any personalknowledge of the accident.
Further, Amazon objects to thisinterrogatory to the extent it
requires Amazon to make adetermination as to available
insurance coverage.
Karen Koehler (11:50):
Subject to Okay so.
Mike Todd (11:52):
Wait, they just said that they don't have any
awareness of the accident.
Karen Koehler (11:57):
Yeah, Because, they weren't present at the
scene.
Mo Hamoudi (12:00):
Well, they were present at the scene.
You know how they were.
They're tracking those thingsDigitally present.
Mike Todd (12:06):
The scene.
Might they track all those?
I mean because it's an Amazonbranded van that they were
driving right.
Karen Koehler (12:12):
No, no, this is different, not this one.
This is the Flex program.
Mo Hamoudi (12:14):
This is the Flex program.
Karen Koehler (12:26):
Yeah, but they still have their little phone to
carry around, so they knowwhere they are, they know what
they're doing.
All right, okay, or I assume?
All right, we're not going tolike we don't have to say who
their insurance companies are?
No, I won't say okay.
However, it says after layingout a certain amount of coverage
.
It says a certain amount ofcoverage.
Mo Hamoudi (12:43):
It says Well, it says that After laying out a lot
of how much their limits are,it says the part where it says
any policy beyond this scope,beyond this yeah, any policy
beyond this is beyond areasonable scope of the present
case and therefore not relevanthere, given the nature of the
facts and claims that issue inthis litigation.
If plaintiff's counsel believesdisclosure of higher levels of
(13:04):
the insurance tower is necessaryin this case, counsel can
schedule a CR26I conference.
Karen Koehler (13:11):
If we think that we're going to get a lot of
money, then they might have togive us more information.
Mo Hamoudi (13:17):
More insurance.
So they're basically tellingyou how much the claim is worth.
Okay.
Karen Koehler (13:20):
They think it's worth, then they have to sign a
certification.
Mo Hamoudi (13:25):
Why do they do that ?
Why do they have to sign thatone and not the other ones?
Karen Koehler (13:28):
Well, they're supposed to sign all their
objections.
You know, supposedly that wasthe old school.
Mo Hamoudi (13:34):
Yeah.
Karen Koehler (13:34):
But in this one they're supposed to write down
the name and sign it of who ismaking the special certification
, Because, shocker, we've had somany cases where they've lied
about how much insurance isavailable.
Mike Todd (13:49):
Not they, not just.
Karen Koehler (13:49):
Amazon.
Mo Hamoudi (13:50):
Yeah, not Amazon.
Karen Koehler (13:51):
Other, other people.
So for all of these defendants,we always put the special
certification.
This is not a special Amazonprovision.
Okay, all right, so I want to.
We've got two, and we alreadytalked about the sanctions
certification.
This is not a special Amazonprovision.
Mo Hamoudi (14:01):
Okay, all right, so I want to.
We've got two and we alreadytalked about the sanctions
orders.
We did.
Karen Koehler (14:07):
From the case where they signed certification
and lo and behold, there was waymore insurance.
Mo Hamoudi (14:12):
Okay.
So now I want to talk to youabout and get some insight.
We have these two particularinterrogatories that they have
not really responded to,interrogatories that they have
not really responded to.
What's the process of goingthrough and scheduling a 26I
conference and talking to them,and how would you approach that
conference with answers likethat.
Karen Koehler (14:37):
Oh, I still want to go through all of them.
Oh, you want to go through allof them.
Okay, wait, okay wait, we'llpick another one because you
know because.
They're very similar.
Mo Hamoudi (14:45):
They're all very similar.
All of them tell us tobasically go pound sand.
Karen Koehler (14:48):
But in addition to the interrogatories, of which
, again, none of them.
Mo Hamoudi (14:57):
And an interrogatory is A question Okay
, a question, that's all Okay.
Karen Koehler (15:02):
But they include the discovery request, includes
request for production, meaning.
So we're asking for documents,yes, so let's see which one do I
really like here?
I think well, they don't likeany of them.
Mike Todd (15:23):
None of them.
Karen Koehler (15:24):
None of them.
They're all the same objections.
So pick whatever your favoritequestion is and read it to us.
Mo Hamoudi (15:32):
Tell me which number I would say Okay.
Karen Koehler (15:40):
Which one?
Mo Hamoudi (15:42):
I'm looking, I'm looking, I'm looking.
Uh, I would say request forproduction number 14 oh my gosh,
you really went down yeah,because I think that's an
important one okay.
Karen Koehler (15:54):
Quest for production number 14 all
documents related to the amazonflex program, including policies
, procedures and guidelinesapplicable to drivers.
Okay, that's the shortestsubject of all of them.
Yeah, okay, go ahead Well justfor our sake.
Mo Hamoudi (16:10):
The Flex program is a program where you can take
your personal car and then youcan enter into an agreement with
Amazon and use your personalcar to deliver Amazon packages.
Mike Todd (16:21):
It's like being an Uber and are you an independent
contractor when you're doingthat?
Mo Hamoudi (16:25):
By contract, you are.
Mike Todd (16:27):
Who then?
So you individually are, you'renot under the umbrella of a
third-party company.
Mo Hamoudi (16:35):
No, you're not.
You're an individualcontracting with Amazon.
Now, Karen can educate youright now about vicarious
liability very quickly.
Karen Koehler (16:45):
If Amazon controls you while you're doing
the job, enough, then you are ina relationship with.
Mike Todd (16:52):
Amazon.
That was my question.
Is you're actually working forAmazon?
Karen Koehler (16:57):
Happens all the time in our Uber cases and our
Lyft cases.
Mike Todd (17:01):
It's the same with Uber and Lyft.
They try to play that same gameand they've lost that several
times now, right.
Mo Hamoudi (17:08):
So what we're asking for is documents related
to that program and policies andprocedures and guidelines that
Amazon imposes on their drivers.
Mike Todd (17:17):
And they're objecting to that.
Mo Hamoudi (17:18):
Well, yeah, they're objecting to it.
Well, yeah, they're objectingto it.
No-transcript.
(17:50):
In this litigation, amazon alsoobjects to the extent this
request seeks information and ordocuments protected from
disclosure by theattorney-client privilege to
work, product doctrine or anyother applicable protection
protection.
Mike Todd (18:02):
Yeah, that's a lot of words and I'm just going to say
no, because all of that to thatI heard is them trying to say
our policies don't affect us atall.
But how can they not whenthey're saying that that
person's not an employee?
Karen Koehler (18:20):
they do.
They're just being beingobstructionists.
Mike Todd (18:22):
Yeah, they're just trying to stand in the way and
slow everything down, so ittakes longer and longer.
Mo Hamoudi (18:27):
This is why I got angry earlier.
Mike Todd (18:29):
Oh yeah, I honked the horn Okay.
Mo Hamoudi (18:31):
Okay, so I want to.
Karen Koehler (18:32):
No, self-education, I'm going to
read this.
Mo Hamoudi (18:35):
Okay, all right.
Karen Koehler (18:36):
It was my idea, dang it, okay, sorry.
Mo Hamoudi (18:44):
okay, I thought I was trying to back off.
Karen Koehler (18:45):
Okay, I'll back off okay, um, we are now going
to role play.
Oh, we are.
Yes, I love it.
Yes, we are.
I sent a letter this morning toamazon that said dear amazon,
did you see my letter?
No, let me see the letter Isaid dear, okay, you can read my
letter I want to read theletter and then we'll go from
there okay, okay, and you senthim an Amazon response to this.
I sent a note, an email.
Okay, okay okay To Mr, I can'tremember.
Mo Hamoudi (19:09):
Oh, dear counsel, our team just took a vote and
agreed that these are some ofthe worst incomplete,
over-objectedto, non-responsiveanswers to discovery we've seen.
Please sign the verificationpage specifically regarding
(19:29):
insurance PS.
Disclosure of all insurancemeans all Mohammoudi will be
taking the lead in shepherdingyou properly through the
discovery process.
Oh, you've tasked me already,karen.
Okay, all right.
Mike Todd (19:48):
I imagine you in an Indiana Jones outfit, with the
whip.
Karen Koehler (19:51):
Yes, so they already know what's coming If
they've done their due diligence.
Well, they have know what'scoming If they'd done their due
diligence?
Mike Todd (20:03):
Well, they have to because you just got done
working with them.
What, oh yeah.
Mo Hamoudi (20:09):
Well, okay, here's the fun part.
They don't know what's comingon Friday and this is not going
to be published until after,After they file the motion for a
protective order and theobjection I'm gonna file for the
judge to enter the protectiveorder.
It's going to be a doozy.
I've been working on it.
It's going to be a big one.
Karen Koehler (20:29):
Okay.
Mo Hamoudi (20:29):
That's going to be fun.
Karen Koehler (20:30):
Stay back on track.
Mo Hamoudi (20:31):
Okay, I'm back on track.
Role playing I'm role playing.
Yes, okay, all right, back ontrack.
Karen Koehler (20:37):
So we're going to have our first discovery
conference, in this case, yeah.
It's going to be Mr Amazon.
Yeah, is it?
Mike Todd (20:46):
going to be in person .
Karen Koehler (20:49):
No, they never wanted to be in person.
Yeah, oh.
First of all, what are yougoing to ask them?
Mo Hamoudi (20:54):
What do you mean?
Karen Koehler (20:55):
Before we set up the call what do we want to do?
Mo Hamoudi (20:59):
We want to record this.
Hey, do you mind if we record a26I conference?
Yeah, no that's not going tohappen, okay, well, we're going
to move to ask the judge torecord it.
Karen Koehler (21:10):
On what basis?
Mo Hamoudi (21:12):
Judicial efficiency , transparency and the fact that
you have obstructed discoveryin another case.
I'm going to attach the orderswith the judge.
Karen Koehler (21:20):
Well, we disagree.
Mo Hamoudi (21:21):
Okay, great, fine, we'll go with that.
Okay, fine, I went to.
Karen Koehler (21:24):
Harvard.
Mo Hamoudi (21:25):
Oh Harvard, yes, Harvard you Harvard.
Oh Harvard, yes, harvard youwent to Harvard.
Go ahead, keep going.
Okay, how about them apples?
You went to Harvard.
When are we going to get ourdiscovery?
Karen Koehler (21:39):
Did I tell you I went to Harvard?
Mo Hamoudi (21:41):
No, you did tell me you went to.
Karen Koehler (21:43):
Harvard.
Yeah, I just want to make sureyou knew that.
Mo Hamoudi (21:46):
Okay, well, since you went to Harvard and you took
probably civil procedure, youprobably understood in civil
procedure do you have anobligation to give me discovery,
so why haven't you given mediscovery?
Karen Koehler (21:57):
We did give you discovery.
Mo Hamoudi (21:59):
Okay, let me ask you another question.
Do you know what happened to myclient?
Do you know how much injuriesthey sustained?
Are you aware of that?
Karen Koehler (22:06):
You know I'm really sorry that the defendant
driver hit them, but we havenothing to do with them.
Okay, by the way did you knowthat I went to Harvard?
Mo Hamoudi (22:15):
All right, you say that one more time.
All right.
Karen Koehler (22:19):
Are you threatening me, Mr Hummity?
Mo Hamoudi (22:21):
If you say that one more time.
Karen Koehler (22:23):
You are being uncollegial.
Mo Hamoudi (22:24):
If you say that one more time I'm going to talk to
you about where I went tocollege I If you say that one
more time.
Karen Koehler (22:28):
I'm going to talk to you about where I went
to college.
I don't care about where youwent to college.
You are nothing.
You are a peon.
I represent Amazon and I wentto Harvard.
Stop breaking character.
Mike Todd (22:43):
It's hard because you just keep saying you went to
Harvard over and over.
You keep saying Harvard.
Mo Hamoudi (22:51):
But I just have a simple question Are you going to
give me the documents that Ineed to prove that your client
is liable for this collision?
Are you going to do that?
Karen Koehler (23:03):
We've already given you 11 pages of documents
and if you want the rest, weneed a protective order because
everything we do is top secret.
You don't understand.
The whole balance of the worldrelies upon Amazon.
We are so essential to everysingle thing in the whole wide
world.
And did I tell you that I wentto Harvard?
Mo Hamoudi (23:22):
Yeah, you told me you went to Harvard.
Karen Koehler (23:24):
Anyway, we need a protective order and we'd like
you to agree to that, and allthat it'll say is that we're
going to show you some documentsand then we're going to take
them away and you've got topretend they never existed and
never tell anybody about them,and we're going to hide them
back where they came from.
We might destroy them, but wemight also hide them, and they
(23:44):
should never see the light ofday.
But we really don't want togive them to you, because did
you go to Harvard?
I didn't think so.
I mean, I don't know if we cando the pinky swear code.
Mo Hamoudi (23:53):
No, but I went to a non-ABA accredited school.
That's where I went.
Oh my God, I can tell you thatI bartended at nights when I
went to school.
Mike Todd (24:01):
Hold on just a second yeah.
Hold just a second yeah.
Karen Koehler (24:07):
Rebecca, this guy did not go to Harvard.
Can you believe it?
I mean, what the heck?
I don't even know how tocommunicate with them.
Maybe didn't they say to dothat on like a fifth grade level
.
Mr Hamoudi, let me repeat, weare very important.
Mo Hamoudi (24:32):
Yeah.
Karen Koehler (24:33):
These documents are very, very top secret, top
secret.
You know like I spy with mylittle eye, yeah, yeah, yeah.
You cannot get them because youdid not go to Harvard.
Mo Hamoudi (24:50):
I'm going to destroy your client.
That's it.
Karen Koehler (24:53):
Mr Hamoudi, that's not very polite.
Mo Hamoudi (24:56):
I know it's not Because I'm done being polite.
Karen Koehler (24:59):
You are mean Mr Malou, mr Hamoudi?
Mo Hamoudi (25:03):
yes, I am done I am finished.
I am finished with you.
Okay, I am going to extractaccountability out of your
client one way or another, andthat's what I'm going to do.
I don't know.
Karen Koehler (25:15):
Mr Hamoudi, that's not how we act in Harvard
.
Mo Hamoudi (25:19):
I don't care, I need you to respect me.
I am not a Harvard student.
Karen Koehler (25:21):
I am a big bad lawyer, way bigger than you.
And see, there are 20 lawyersover here sitting here and we're
all taking notes of yourbehavior.
Mike Todd (25:32):
I think we need to record this conference then yeah
, I was going to say, if theyallowed it to be recorded,
they'd have a lot of proof andhad you agreed in the first
place, you would have had reallygood evidence to tell this
judge.
Karen Koehler (25:41):
All right, this meeting has to be concluded
because you're mad and mean andwe don't play that.
Mo Hamoudi (25:49):
That's just the way I am.
That's literally kind of how itgoes.
I believe you.
Mike Todd (25:56):
I'm sure.
I'm just curious.
Can you ask them if it's?
Mo Hamoudi (26:05):
a policy for their drivers to go the wrong way on
the freeway?
Yeah, you could ask them that.
They're just not going toanswer it.
Oh, I'm sure they're going tosay they're not their drivers
the way they're, they don't knowthe way they've designed this
is that you have amazon and youhave lawyers that work for
amazon okay, then lawyers thatwork for amazon hire law firms
okay to do their work, and whatthey do is these lawyers are not
(26:26):
, they have no power.
They go to lawyers for Amazon.
We have a discovery conference,it's strip matter firm again,
and what do we do?
And they go.
You do nothing.
So they come in and go.
My hands are tied, I can't doanything.
So what we're going to do iswe're going to reveal that
dynamic to the judge that theseguys are nothing, they have no
(26:47):
power, they have no say, andwhat you're dealing with is a
bunch of lawyers sitting downhere on Terry Avenue in Seattle,
too cowardly to show up in thecourt and step up and defend
their client.
Karen Koehler (27:02):
Ruthless Mo go away.
Mo Hamoudi (27:05):
Okay, I'm going away.
Mike Todd (27:08):
Sorry, I'm winding him up, you wind me up, but,
karen, it's the truth, karen.
Mo Hamoudi (27:10):
Okay, I'm going away.
Sorry, I'm winding him up, butyou wind me up, but, karen, it's
the truth, karen.
Karen Koehler (27:13):
Okay, okay.
Mo Hamoudi (27:14):
It's the truth.
Okay, it's the truth.
It's gone, but you summoned himand then now you're saying go
back His eyes got really darkwhen he was talking to me.
Karen Koehler (27:22):
He really hated the you know, oh, you were
firing me when I talked to himin little boy language.
Mo Hamoudi (27:27):
But the thing is is that she was playing the part
and then I love her so much Ican't get angry at her.
You did, though I just wasstarting to get a little and I
was like what is she?
Mike Todd (27:38):
doing.
She did good by just bringingup Harvard that many times,
because that can wind you up forsure.
That winds me up for sure.
Karen Koehler (27:46):
Although I am very proud of Harvard right now.
Oh, that's the thing I wasgoing to say.
Mike Todd (27:50):
Politically, it's a play on the fact that a lot of
hoity-toity lawyers do that, butreally Harvard does good work.
Karen Koehler (28:01):
They went and bowed to the king and so I'm
happy with them.
So maybe I should have said,yale, we'll do that next time,
next time, say Yale, say Yale,we'll do that next time, next
time, say Yale Say Yale, Don'tsay Harvard Anyway this is the
story of our lives.
Mo Hamoudi (28:13):
Yeah.
Karen Koehler (28:13):
Going about our way, just trying to do our job.
Mike Todd (28:17):
Just asking questions and getting the same answer
over and over again After tworequests, because you know they
needed more time to write theseobjections.
Of course.
Karen Koehler (28:25):
They didn't.
Mo Hamoudi (28:31):
Well, because they have to have meetings with the
other firms that they've hired,so they can tell them not to
answer, all right.
All right, okay, we're done,okay, yes, bye, bye.
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