October 25, 2024 • 33 mins
David Matthews is the Firm Founder of Matthews and Associates.
David has been chosen through US News & World Report as one of the Best Lawyers in America from 2016-2023 and repeatedly voted by his peers as one of the top trial lawyers in the country.
He has tried more than 175 cases to verdict and helped injured people across the country attain some of the largest verdicts or settlements in pharmaceutical litigation against the makers of such drugs as Phen-Fen, Rezulin, Vioxx, and Bextra-Celebrex.
Connect with David on LinkedIn: https://www.linkedin.com/in/david-matthews-a3a51811b/
Visit Matthews and Associates: https://www.thewagstafflawfirm.com/
On This Episode, We Discuss…
David has been chosen through US News & World Report as one of the Best Lawyers in America from 2016-2023 and repeatedly voted by his peers as one of the top trial lawyers in the country.
He has tried more than 175 cases to verdict and helped injured people across the country attain some of the largest verdicts or settlements in pharmaceutical litigation against the makers of such drugs as Phen-Fen, Rezulin, Vioxx, and Bextra-Celebrex.
Connect with David on LinkedIn: https://www.linkedin.com/in/david-matthews-a3a51811b/
Visit Matthews and Associates: https://www.thewagstafflawfirm.com/
On This Episode, We Discuss…
- How the Landscape of Mass Tort Litigation has Evolved Over the Years
- Complexities of Pharmaceutical Litigation
- Strategic Elements of Mass Tort Litigation
- Camp Lejeune Water Contamination Case
Mark as Played
Transcript
Episode Transcript
Available transcripts are automatically generated. Complete accuracy is not guaranteed.
Speaker 1 (00:01):
Unless you really truly understand the components of general and specificalisation.
I think you're doing yourself and your client a disservice
of getting into a litigation and to you really understand
those those components, and you know that's just a starting point.
Speaker 2 (00:20):
You're listening to the Legal Mastermind podcast presented by Market
My Market with your hosts Eric Bersano, Ryan Klein, and
Chase Williams, the go to podcast for learning from the
experts and the legal community about effective ways to grow
and manage your law firm.
Speaker 3 (00:38):
Hello and welcome to another episode of the Legal Mastermind podcast.
Today I have with me attorney David Matthews, who is
the firm founder of Matthews and Associates. David, Welcome to
the podcast.
Speaker 1 (00:52):
Good morning Eric.
Speaker 3 (00:54):
So if you wouldn't mind start out just with the
brief history on yourself and how you got.
Speaker 4 (01:01):
To where you are today.
Speaker 1 (01:03):
Sure. So my name is David Matthews. I used to
be Dave Matthews, but someone started using that name, so
I've went back to David. So it's not to be confused,
although it does help with reservations at dinner and such.
But yeah, I'm David Matthews. My firm is Matthews and Associates.
(01:23):
I come from a big family in small town Wisconsin,
where I grew up in a farming community, if you will.
I went to school at the University of Wisconsin and
studied political science. I also studied Spanish and studied in
(01:46):
Mexico for my last year college and didn't really think
i'd be using a Spanish as much as I do now,
so it's been a big help. But after college in Wisconsin,
I packed up my four foot long Honda Civic with
(02:06):
my clothes and I moved to Houston, Texas, where I
worked bartending and with a plan to go to law school.
So I had to raise some money, which I did
and ultimately applied to South Texas College of Law in Houston.
At school kind of known for I would say, producing
(02:29):
trial lawyers is what I pretty much always wanted to do.
I wanted to I wanted to help people, I wanted
to speak for them. And I became a lawyer from
South Texas College of Law and I graduated in nineteen
eighty eight and I have been in Houston ever since,
(02:50):
and it's been It's been a great city, a great
place to litigate. I have an office in New York
and California, but my main office is here in Houston,
where we have over fifty people lawyers, doctor, nurses, medical staff,
(03:14):
and legal staff. Where we look at cases and determine
what cases we're going to take. And that's what I
have been doing for a long time. I left a
defense firm where I first started representing insurance companies in
large corporations, but after a couple of years, I realized
(03:36):
that was not for me and I wanted to be
a lawyer representing people. And I have been a plaintiffs
lawyer as we can be called or are called, ever
since nineteen ninety and that's been that's been my practice
(03:58):
in Houston, Texas and across the country. I have a
national practice. We represent people from across the country in
the cases ranging from pharmaceutical, medical device and pharmaceutical cases
to pesticide cases, two cases involving clergy abuse, but generally speaking,
(04:23):
I only represent individuals against companies and entities for negligence
and gross negligence.
Speaker 3 (04:32):
Yeah, and I saw in your bio that you know
you were involved in the Finn Fenn case, you know,
way back when that was that one of the first
big drug cases that you know, kind of set the
tone for a lot of these pharmaceutical cases that are
being handled today.
Speaker 1 (04:51):
I think that's right, you know, I think that is
one of the very first cases that some people call
mass tort. That's not a great name, but it is
better adopted, if you will. And I think that one
of the very first cases was the fen Fen case.
I would say just prior to that, I worked on
the breast implant litigation and the injuries to women square
(05:12):
norma autoimmune disorders injuries like that. But then following that
case was the fen Fen litigation, which was the van
fluoramine that caused the valveulopathy and significant heart and heart
lung injuries. And that was one of the first cases
that kind of took on the front of multiple plaintiffs
(05:38):
and sometimes filed in one complaint or one petition in
a state. So yeah, I think that's very true that
that was one of the first.
Speaker 3 (05:48):
So I'm interested for someone who's been doing it as
long as you have to be involved in that. You know,
probably a lot of trail blazing back then. Are things
very similar today? Is the way that you you know,
went through trial on that to what you're dealing with
today or.
Speaker 4 (06:05):
Has everything changed?
Speaker 1 (06:07):
I would say that there are some things that stayed
the same, but a great many things have changed. You know.
One one thing that has really changed is the MDL
scenario and the involvement of the funds that have came
in kind of in the forefront in the last I'm
(06:27):
going to say, five six, seven years, wherein these financial
institutions and funds that are produced to invest in litigation.
I think it has changed the complexity, and I think
there's been some backlash because of it. That might be
the difference. I think the similarities are. You know, when
(06:51):
I started and I have tried to verdict at this
point dozens of these cases, which is probably somewhat different
then then most people that get into mass toward I
think they get in with the idea of of accumulating
or acquiring a big number of cases and then and
then hoping to settle these cases somewhere down the line.
(07:14):
That's never been my intent, nor my my desire to
be involved in that way. And so I think that
you know, there's that's changed. There's there's many more case
acquisition groups and maybe so few cases, so few law
firms that that actually take the case from A to Z.
(07:38):
That is, they take the case on, they get to
know the point if they file the case, they work
up the discovery on the case, and and then they
they set the case for trial and they try the case.
So although those things still occur, there's just a great
many more percentage wise lawyers that that are just kind
(07:59):
of case acquisition groups. So, you know, my firm is
still what I consider to be a trial firm. You know,
we we do nothing more than any other case, regardless
of it's mass tward or not. That is, understand the case, obtain,
retain the experts that are necessary to show the causation
(08:25):
that this particular drug or this particular medical device causes
this type of injury generally and then specific to a
particular client, that it caused the injury to that client.
And so you know, we we still file cases across
the country, and currently I'm filing in Chicago and Saint Louis,
(08:50):
Los Angeles, Oakland, Alameda County, Miami, Philadelphia, New York. Wherever
we need to, we are able to and file cases
and plan on trying those cases. The verdict and unless
it makes sense and the defendant offers money to a
(09:12):
client and a client and it's right for that client
on a case by case basis, we make that decision, then.
Speaker 3 (09:19):
Yeah, I'd love to get your input, you know, for
our audience who isn't as well versed in mass Towards.
Speaker 4 (09:25):
About what I would say would be some of the warnings.
Speaker 3 (09:28):
I think, you know, Mass Towards has looked at sometimes
as you know, easy money.
Speaker 4 (09:34):
They're going to invest a dollar and going to make
ten back.
Speaker 3 (09:37):
And there's lots of firms out there that work in
mass Towards and the and they and they're you know,
they understand all the ins and outs of it. But
the way I see it is, I've talked with lawyers
who invested a lot of marketing dollars into.
Speaker 4 (09:51):
Something a little too early and the facts of the
case change.
Speaker 5 (09:55):
Or they get sold on doing all this marketing and
grabbing all these cases and don't realize some of the
downstream costs.
Speaker 4 (10:01):
You might have to borrow money.
Speaker 3 (10:03):
Everybody thinks the case is going to settle in three years,
and it's five or six years. So I'd love to
hear your experience, you know, from someone who does it
firsthand for a while, you know, maybe some warnings or
advice to someone who's considering getting into the mass towards.
Speaker 1 (10:20):
Yeah, you make some good points, because it does seem
to be an easy endeavor, and I think it's really
just the opposite. I think that that people, you know,
the lawyers that want to get into this field need
to first understand you know, causation, and that is can
I prove are you able to prove that a particular
(10:44):
drug or particular device caused a particular injury? And really
there's two components of that. Of course, there's the the
issue of general causation. Is a drug capable of causing
a particular injury and that is in the general population,
And so I think one needs to start there, and
that requires what I consider to be a lot of homework.
(11:08):
You must understand a study or in most cases multiple
studies to see where the overall implication is or do
you have the the relative risk needed, do you have
the odds ratio needed to prove a particular injury? So
(11:29):
I think the warning start there. You know, have you
done that the work yourself, have you understood it? Have
you talked with an epidemiologist as an example, to determine
if that injury could be caused by a particular drug
or device or pesticide for that matter. So I think
we start there, and secondly, we then talk with our client,
(11:52):
a potential client, to see if that specific client had
a specific injury caused by a particular drug or device
or pesticide. And that means that you have to understand
the confounding factors within your plaintiff. That is, could it
be another cause? And is there a doctor, is there
(12:14):
an expert? Is there a scientist that can tell you
that I have been able to exclude other causes and
this particular product is a substantial contributing factor to that
specific injury in that plaintiff. So I think I think
one has to start there. And unless you really truly
understand the components of general and specific causation, I think
(12:39):
you're doing yourself and and your client a disservice of
getting into a litigation and to you to you really
understand that those those components, and you know that's just
a starting point, you know, then then then we talk about,
you know, is that drug and as we often see,
you know, drugs have a of shelf life, if you will,
(13:02):
whether they're actually branded by the innovator or the manufacturer
that invented that particular drug in a field, and after
a time that drug will become generic. And are your
cases clients that took the generic version of that drug,
(13:23):
Because if they are, you must understand the litany of
cases involving generic drug liability and whether you can bring
suit and find liability against the generic manufacturer. Because there's
a case by the name of Mincing that we were
working on litigation with regulin, which was some fifteen years ago,
(13:44):
and the US Supreme Court came down with a determination
that a generic manufacturer cannot be held liable for a
defect in a warning the lack of warning to a
particular patient, because they can't change the warning. Warning has
to be changed by the brand, manufacturer or the innovator
of the drug. And therefore they got ah, they got
(14:06):
a pass. The generics did so before investing the time
and energy and money on cases, you've got to understand
who that manufacturer is. And that seems simple and yet
and it's really not. It's something that takes some work,
some legwork, some understanding, and some discussions with whether it's
(14:28):
a warning expert, whether it's a toxicologist, whether it's a doctor,
in the field of the of the area in which
you're pursuing a case to see what they would need
for a warning and what they had for a warning
at the time. So there's another you know, kind of
say cautionary tale as too. Not only can that particular drug,
device or pass a psyche cause injury, but is it
(14:51):
that's identifiable to a true brand or innovator manufacturer?
Speaker 3 (14:56):
Now is one of the things that you have to
also prove is that the manufacturer knew that their product
could cause this, like for example, roundup lyso fate you know,
linked to non Hodgkins lymphoma. Do you have to prove
that they knew that it was linked to that or
is it just good enough to say, hey, you use
this product.
Speaker 5 (15:16):
We know it's linked to non Hodgkins lymphoma. We're telling
you right now that we can tie that to you,
and they're they're on the hook for that.
Speaker 3 (15:25):
So if there's something new coming out, is that what
an attorney really needs to also dig into.
Speaker 1 (15:29):
Well, I think that what we ultimately have to prove
is a company new or should have known of a
particular defect, of a particular danger propensity of a drug
or device or pesticide. And you know, I'm going to
say this, Eric, you know, nine times out of ten
we will find that they actually did know. We might
(15:51):
not know in the beginning, but you know, I think
with diligent discovery, whether it be written discovery, requests for admissions,
requests for production, interrogatories, or actual depositions themselves, nine times
out of ten we're going to be able to show
a jury in And this is really what you know
upsets juris is not only should they have known, but
(16:12):
you know, the documents just substantially reflect that they did know.
So it's it's a it's a tough one, you know
what the sciences of course, the changes over time, and
there are cases that there was there was a company
that could not have known of a particular would I
(16:32):
say defect that could be a marketing defect that is
that they didn't want about an injury that could be
caused by it, but there was no way to know.
That is a that's a rare that's a very rare circumstance.
Speaker 3 (16:46):
Yeah, and I think you're right, you know, when I
saw some of this information myself, you know, one being
like talcum powder. Another one that I think most people
would would know would be like the Ford roller rollover
cases and then the Firestone tires that that when the
information came out that they knew it, they just were
going to bake it into their sales numbers.
Speaker 4 (17:08):
Like you mentioned, the juries. Get so upset about that,
And I.
Speaker 3 (17:11):
Don't think the general public understands that these companies are
just making a financial decision and saying, Okay, it's going
to be too expensive for us to go back and
change the production for this medical device or this vehicle
or this pharmaceutical.
Speaker 4 (17:26):
We'll just run with it and see what happens.
Speaker 1 (17:28):
Well, I think that's that's true to a large extent.
At that point in time. You know, these companies have
spent tens of millions of dollars in a particular pivotal
clinical trial or R and D or the marketing of
their prepared to market a mass market if you will.
(17:50):
You know, I think about YOS. You know, when YOS
came out, they had three thousand plus sales reps that
were already trained prior to the the the FDA granting
the approval of box and lo and behold. It was
a monster seller, and it was a two billion, three
(18:12):
billion a year drug that they really didn't adequately research,
but they did know that there was a clotting issue
associated with it, but they just, you know, from the
evidence that we saw, just ignored it and pushed on
and not just not just slowly approached the marketplace, but
(18:36):
but flooded the marketplace with you know, sales reps in
every doctor's office, in every internal medicine doctor, every treater
with these cocks two inhibitors that that you know, were
this going to be this great pain reliever for people
with arthritis or rheumatoid arthritis. That that turned out to
(18:57):
be a disaster, and of course the drug was removed
from the market. But you know, it's sad that this
is becoming that this is much more the norm than
the exception, and that is the mass marketing of drugs
and devices without adequate work up. And you know, and
the fact that what they give the FDA or don't
(19:20):
give the FDA is often the difference to whether a
drug is approved or not.
Speaker 3 (19:28):
Yeah, speaking of marketing, I'd like to kind of shift
gears to more of the marketing on the legal side.
Speaker 4 (19:35):
For these cases.
Speaker 3 (19:37):
You know, one of the biggest changes I've seen over
the last fifteen years is just the way that.
Speaker 4 (19:43):
These cases can be obtained.
Speaker 3 (19:46):
And I would personally warrant anybody who's looking to get
into these cases who doesn't have a lot of experience,
you know, be careful what you hear from the marketers
because they make all their money up front. Whatever you
get might be worth a lot, it might be worth nothing.
Do you have any advice when it comes to, you know,
marketing for these cases. You'd already talked about, you know,
(20:07):
doing your research and making sure that you do your
homework before you jump in. But as far as you know,
if there's a firm out there that wants to get
ozempic cases or something else that's that's going on these days,
how to go about vetting those marketing firms.
Speaker 1 (20:24):
So I would start by saying, yeah, I agree with you.
There's been a tremendous shift, if you will, and just
by volume. I think part of this involved the Camp
Lijune litigation which I am involved in, which was the
water contamination case in North Carolina which Camp was June
was the marine camp that housed both marines and families,
(20:49):
and the federal government. A bill was passed some two
years ago in August that they were going to compensate victims.
There was a studied on that showed equipoise or a
likelihood that the water contamination causes a number of injuries,
(21:09):
including over ten different cancers, Parkinson's disease, and some birth effects.
So this was in a document and this came out
and you know, by and large, you know, any lawyer
that does any of this type of work, or maybe
wasn't even doing this type of work, thought this was
(21:31):
the greatest case ever. And because of that, there was
an onslaught of ads that hit the airwaves. I think
it was really unprecedented that over a billion dollars was
spent in advertisements across the country. Because of the speed
by which people were trying to acquire these cases and
(21:53):
the number of vendors marketers that were involved, there was
a tremendous amount of fraud. It came in every way,
shape or form that these cases were acquired by groups
that either were not qualified to take in acquire cases
because they couldn't understand if one was real or not,
(22:15):
or there was active fraud by the marketers. And I'm
not you know, claiming particular one was or wasn't, but
it happened to be an awful, awful a bunch of
fraud across the board in campus that has carried on
just throughout now in the last I would say, you know,
three or four years, five years starting just before that,
(22:39):
but that really culminated. I think in the numbers, you know,
how do you prevent how do you with these these
groups that acquire cases, how you work with them to
make sure you've got real cases as opposed to a
fraud plaintiff. And I think that there's no perfect way.
I think that that I've learned personally is I need
(23:01):
to be more hands on. I need to take those
first leads to immediately talk to every single one of
those clients, either you or a lawyer in your firm
needs to be hands on with that. Make sure that
they understand that you know that you are their lawyer,
make sure that they are a real plaintiff with a
(23:23):
real injury, and immediately order medical records to see if
you know you we all need, you know, two things
in these cases, it doesn't really change. You need proof
of exposure or proof of use and proof of injury.
And those are two distinct, distinct areas that you you
(23:44):
must produce evidence to bring a case or ultimately to
try a case, ultimately to prevail. So you know that
means that means expedited medical record review. You know, talk
with clients, get those first records and look at them.
See does this is this really a Parkinson's disease? Is
(24:06):
this really uh you know, kidney cancer?
Speaker 2 (24:10):
Uh?
Speaker 1 (24:11):
Is this? You know I'm looking at these right now, specifically,
I'm looking at deppel Bavera case. Deppel Bavera was a
uh was a drug injectible of birth control of injection
used since the nineties, has been around a long time
and some time ago, not that long ago. A study
(24:33):
from France from using the Socialized Medicine France French database
showed a huge increased risk for Deppe of Bavaria use
in meningeoma or brain tumors in women. A really big case,
really difficult case to prove specific and general causation, but
(24:54):
also generic issues. But that said, uh, big injuries, big
case A Vizor manufacturer Engineeric at two thousand and five.
You know, we immediately are all over these medical records
if we can find them. You know, when you have
an older case, you also have another issue with you know,
obtaining medical records, because we know that that often hospitals,
(25:19):
doctors' offices destroy records after ten years, sometimes last. So
now you have the added obstacle of approving your injury
with without medical records. Pretty tough to do. That said,
I think that's what one needs to do. You need
to be vigilant. You just you cannot allow a company
(25:39):
to tell you know, here's here's one hundred cases and
good luck to you, you know, and then this just
keeps going on without what I would say, at daily
checks and balances of determining proof of use, proof of injury.
So I would start there.
Speaker 4 (25:56):
Yeah, I think you need to do just as much
due diligence into who you're marketing with as you do
into whether you want to work in the case, there's
two ends of the spectrum as I see it, there's
innocent ones, meaning a lot of times a person sees
these ads, they're promised thousands, if not millions of dollars,
and they call a couple of the phone numbers and
(26:18):
they say, do you have kidney cancer?
Speaker 1 (26:19):
No?
Speaker 4 (26:20):
Do you have kidney cancer no?
Speaker 3 (26:21):
The third time they say yes, you know, because they
feel like, well, I'm injured, but maybe I don't have
the exact injury that's going to get paid, so they
slip through the cracks. And then on the other side
of it, if you're doing due diligence and to talking
to a marketing company, make sure that the company that
you're working with is actually doing the marketing. I know
that sounds more than obvious, but I know in Camp
(26:43):
Lejune what was happening is there was so much money
going around. These marketing companies didn't want to say no
to anybody who had a budget, so they would go
out and look for other people to help bring in
these cases. That means that the attorney is ultimately responsible
from where that case came from.
Speaker 5 (27:00):
But if they hired marketing company A, and marketing company
B was hired by marketing company A and was doing
something nefarious, meaning ignoring TCPA violations or doing something to
bring these cases in that wasn't above board, the attorney was.
Speaker 4 (27:15):
Ultimately on the hook for that. So do your due diligence.
Speaker 3 (27:19):
A lot of these firms that I see are spending
lots of money on this.
Speaker 4 (27:22):
It's worth the extra time to make.
Speaker 5 (27:23):
Sure that you're working with somebody who's complying with all
the advertising laws.
Speaker 1 (27:27):
I completely agree, Eric, And I'll say this. You know,
I've been doing this a long time, and I've worked
with groups that I know personally and I know that
they're actually getting the cases. But if there is a
new group I want to work with, I will get
them on a zoom call and I will say, listen,
are you getting the cases? Look at me in the
eyes and tell me are you getting these cases or not?
(27:50):
Are you getting from vendor at BC and D. And
then I'll go visit them. If they're in Chicago, I
will go to Chicago and I will sit down with them.
If they're in San Diego, I will go to Sandia.
Let's say, show me your operations, so you know how
many people you have answering phone calls, what are your
checks and balances? You know, what do you have in
mind to prevent fraud? And how are you doing it?
(28:11):
And I think it takes that extra step, especially now.
Maybe didn't ten years ago, but it does now, and
so I think it's it's crucial that you take the
time to do it right.
Speaker 3 (28:22):
Yeah, I think over the last I was saying ten
to fifteen years, there's so many positives that are happening,
meaning there's more specialized services. You've got someone who can
just do your intake, You've got someone who can market
you for social media. You've got TV and broadcaret paths
and streaming audio or streaming video, all of these different
(28:44):
options that I think are helping to make the industry
overall more efficient, because I don't think this existed fifteen
years ago, where you had all these specialized companies that
focus on one link in the chain for this client acquisition.
But like in the industry where there's a lot of
money going around, you have some bad actors, or you
just intentionally or you just have people that aren't as
(29:05):
good as others that want to join in the game.
Speaker 5 (29:08):
So any any last things you would say on you know,
marketing and the mass towards to someone who's kind of
considering going in that way, because I see every year
at these conferences there are successful PI attorneys that go,
I've been hearing about this mass toward thing for a
while now, and I want to jump in.
Speaker 4 (29:26):
Any last things you would say to that person.
Speaker 1 (29:29):
Yeah, I think the points that we've talked about are crucial.
They're very important. I would say this I would designate
a maybe you call them whatever you want to call them.
I call them a compliance data person. But somebody that
is that's their job to make sure internally we have
a two really crack pot you know, data managers here
(29:52):
that I really rely on. Guys. I can't do that.
I mean, I have oversight when I talk to clients,
But in terms of the data, the intake the medical reviews,
make sure that that they they comport, make sure that
they work that this isn't you know, if you see
a red flag, it's probably meaningful, you know, respond to
(30:13):
it and don't just say, well, I'm sure it was
just you know, I'm sure it was just to aberration.
You know, No, it's probably a real problem. And so
I would you know, designate someone that is, uh that
that's their duty to you know, look for that that
fraud and make sure that you're getting real cases from
(30:36):
you know, real clients. Yeah.
Speaker 3 (30:38):
The other thing you said that I think can't be
overstressed would be creating that relationship in the beginning. And
I think you'll probably saw this in Campbella June. There
were so many people who were signed up with multiple
law firms because they get signed up by law firm A.
Speaker 4 (30:55):
Law firm A sign them up, didn't communicate well with them.
Speaker 3 (30:59):
They might have reached out law firm AY several timesn't
hear back, and they're like, I don't know if I'm
really covered in this, and they'll sign up with law
firm B. So you had lots of these dual reps
that one person was signed up with two or three
different law firms. If you can create that relationship in
the beginning and they know that you're working with them
and communicate.
Speaker 5 (31:18):
How that process works and what timelines are, otherwise this
person might just see another ad and say, I'm going
to go sign up with somebody else because I don't
know that my attorney's working for me.
Speaker 1 (31:30):
Yeah. Absolutely, and I think everything you just said is
right on, and I think that you know, I'd like
to think that we're going to get better, that there
won't be any fraud and it'll but but frankly, there
is just too there's too much money at play here
(31:51):
with these with the marketing groups. But I would also
stress that you know, get to know the groups that
you're working with, really really know personal as opposed to
you know, a phone call here there or a discussion
about how many cases you think you want and how
much per case there is. I just think that's such
a that's nothing more than a starting point, and you
(32:13):
really need to get to know people.
Speaker 3 (32:16):
Well, David, I really appreciate you sharing your knowledge and
experience with the audience. Is there anything that you wanted
to cover at the end here, or at least let
people know how to get a hold of you if
they've got questions someone with your experience. I'm sure there
was a lot of attorneys that would like to pick
your brain.
Speaker 1 (32:32):
Yeah. Sure, Well, I mean I'd welcome discussion if someone
wants to discuss the process. Yeah. I have been doing
this probably as long as anyone has been doing mass
towart at this point. I guess you know, I was
there in the in the nineties and the you know,
mid nineties, and I've been there in this space since.
(32:55):
I'm happy to discuss. Eric, if someone please feel free
to let them know my TechEd info.
Speaker 3 (33:01):
Absolutely, we'll put in the show notes. Thanks again, David,
appreciate your time.
Speaker 2 (33:05):
Thanks Eric, Thanks for listening to the Legal Mastermind podcast
presented by Market My Market. If you can check out
additional episodes and recaps at Legalmastermind podcast dot com.
Unless you really truly understand the components of general and specificalisation.
I think you're doing yourself and your client a disservice
of getting into a litigation and to you really understand
those those components, and you know that's just a starting point.
Speaker 2 (00:20):
You're listening to the Legal Mastermind podcast presented by Market
My Market with your hosts Eric Bersano, Ryan Klein, and
Chase Williams, the go to podcast for learning from the
experts and the legal community about effective ways to grow
and manage your law firm.
Speaker 3 (00:38):
Hello and welcome to another episode of the Legal Mastermind podcast.
Today I have with me attorney David Matthews, who is
the firm founder of Matthews and Associates. David, Welcome to
the podcast.
Speaker 1 (00:52):
Good morning Eric.
Speaker 3 (00:54):
So if you wouldn't mind start out just with the
brief history on yourself and how you got.
Speaker 4 (01:01):
To where you are today.
Speaker 1 (01:03):
Sure. So my name is David Matthews. I used to
be Dave Matthews, but someone started using that name, so
I've went back to David. So it's not to be confused,
although it does help with reservations at dinner and such.
But yeah, I'm David Matthews. My firm is Matthews and Associates.
(01:23):
I come from a big family in small town Wisconsin,
where I grew up in a farming community, if you will.
I went to school at the University of Wisconsin and
studied political science. I also studied Spanish and studied in
(01:46):
Mexico for my last year college and didn't really think
i'd be using a Spanish as much as I do now,
so it's been a big help. But after college in Wisconsin,
I packed up my four foot long Honda Civic with
(02:06):
my clothes and I moved to Houston, Texas, where I
worked bartending and with a plan to go to law school.
So I had to raise some money, which I did
and ultimately applied to South Texas College of Law in Houston.
At school kind of known for I would say, producing
(02:29):
trial lawyers is what I pretty much always wanted to do.
I wanted to I wanted to help people, I wanted
to speak for them. And I became a lawyer from
South Texas College of Law and I graduated in nineteen
eighty eight and I have been in Houston ever since,
(02:50):
and it's been It's been a great city, a great
place to litigate. I have an office in New York
and California, but my main office is here in Houston,
where we have over fifty people lawyers, doctor, nurses, medical staff,
(03:14):
and legal staff. Where we look at cases and determine
what cases we're going to take. And that's what I
have been doing for a long time. I left a
defense firm where I first started representing insurance companies in
large corporations, but after a couple of years, I realized
(03:36):
that was not for me and I wanted to be
a lawyer representing people. And I have been a plaintiffs
lawyer as we can be called or are called, ever
since nineteen ninety and that's been that's been my practice
(03:58):
in Houston, Texas and across the country. I have a
national practice. We represent people from across the country in
the cases ranging from pharmaceutical, medical device and pharmaceutical cases
to pesticide cases, two cases involving clergy abuse, but generally speaking,
(04:23):
I only represent individuals against companies and entities for negligence
and gross negligence.
Speaker 3 (04:32):
Yeah, and I saw in your bio that you know
you were involved in the Finn Fenn case, you know,
way back when that was that one of the first
big drug cases that you know, kind of set the
tone for a lot of these pharmaceutical cases that are
being handled today.
Speaker 1 (04:51):
I think that's right, you know, I think that is
one of the very first cases that some people call
mass tort. That's not a great name, but it is
better adopted, if you will. And I think that one
of the very first cases was the fen Fen case.
I would say just prior to that, I worked on
the breast implant litigation and the injuries to women square
(05:12):
norma autoimmune disorders injuries like that. But then following that
case was the fen Fen litigation, which was the van
fluoramine that caused the valveulopathy and significant heart and heart
lung injuries. And that was one of the first cases
that kind of took on the front of multiple plaintiffs
(05:38):
and sometimes filed in one complaint or one petition in
a state. So yeah, I think that's very true that
that was one of the first.
Speaker 3 (05:48):
So I'm interested for someone who's been doing it as
long as you have to be involved in that. You know,
probably a lot of trail blazing back then. Are things
very similar today? Is the way that you you know,
went through trial on that to what you're dealing with
today or.
Speaker 4 (06:05):
Has everything changed?
Speaker 1 (06:07):
I would say that there are some things that stayed
the same, but a great many things have changed. You know.
One one thing that has really changed is the MDL
scenario and the involvement of the funds that have came
in kind of in the forefront in the last I'm
(06:27):
going to say, five six, seven years, wherein these financial
institutions and funds that are produced to invest in litigation.
I think it has changed the complexity, and I think
there's been some backlash because of it. That might be
the difference. I think the similarities are. You know, when
(06:51):
I started and I have tried to verdict at this
point dozens of these cases, which is probably somewhat different
then then most people that get into mass toward I
think they get in with the idea of of accumulating
or acquiring a big number of cases and then and
then hoping to settle these cases somewhere down the line.
(07:14):
That's never been my intent, nor my my desire to
be involved in that way. And so I think that
you know, there's that's changed. There's there's many more case
acquisition groups and maybe so few cases, so few law
firms that that actually take the case from A to Z.
(07:38):
That is, they take the case on, they get to
know the point if they file the case, they work
up the discovery on the case, and and then they
they set the case for trial and they try the case.
So although those things still occur, there's just a great
many more percentage wise lawyers that that are just kind
(07:59):
of case acquisition groups. So, you know, my firm is
still what I consider to be a trial firm. You know,
we we do nothing more than any other case, regardless
of it's mass tward or not. That is, understand the case, obtain,
retain the experts that are necessary to show the causation
(08:25):
that this particular drug or this particular medical device causes
this type of injury generally and then specific to a
particular client, that it caused the injury to that client.
And so you know, we we still file cases across
the country, and currently I'm filing in Chicago and Saint Louis,
(08:50):
Los Angeles, Oakland, Alameda County, Miami, Philadelphia, New York. Wherever
we need to, we are able to and file cases
and plan on trying those cases. The verdict and unless
it makes sense and the defendant offers money to a
(09:12):
client and a client and it's right for that client
on a case by case basis, we make that decision, then.
Speaker 3 (09:19):
Yeah, I'd love to get your input, you know, for
our audience who isn't as well versed in mass Towards.
Speaker 4 (09:25):
About what I would say would be some of the warnings.
Speaker 3 (09:28):
I think, you know, Mass Towards has looked at sometimes
as you know, easy money.
Speaker 4 (09:34):
They're going to invest a dollar and going to make
ten back.
Speaker 3 (09:37):
And there's lots of firms out there that work in
mass Towards and the and they and they're you know,
they understand all the ins and outs of it. But
the way I see it is, I've talked with lawyers
who invested a lot of marketing dollars into.
Speaker 4 (09:51):
Something a little too early and the facts of the
case change.
Speaker 5 (09:55):
Or they get sold on doing all this marketing and
grabbing all these cases and don't realize some of the
downstream costs.
Speaker 4 (10:01):
You might have to borrow money.
Speaker 3 (10:03):
Everybody thinks the case is going to settle in three years,
and it's five or six years. So I'd love to
hear your experience, you know, from someone who does it
firsthand for a while, you know, maybe some warnings or
advice to someone who's considering getting into the mass towards.
Speaker 1 (10:20):
Yeah, you make some good points, because it does seem
to be an easy endeavor, and I think it's really
just the opposite. I think that that people, you know,
the lawyers that want to get into this field need
to first understand you know, causation, and that is can
I prove are you able to prove that a particular
(10:44):
drug or particular device caused a particular injury? And really
there's two components of that. Of course, there's the the
issue of general causation. Is a drug capable of causing
a particular injury and that is in the general population,
And so I think one needs to start there, and
that requires what I consider to be a lot of homework.
(11:08):
You must understand a study or in most cases multiple
studies to see where the overall implication is or do
you have the the relative risk needed, do you have
the odds ratio needed to prove a particular injury? So
(11:29):
I think the warning start there. You know, have you
done that the work yourself, have you understood it? Have
you talked with an epidemiologist as an example, to determine
if that injury could be caused by a particular drug
or device or pesticide for that matter. So I think
we start there, and secondly, we then talk with our client,
(11:52):
a potential client, to see if that specific client had
a specific injury caused by a particular drug or device
or pesticide. And that means that you have to understand
the confounding factors within your plaintiff. That is, could it
be another cause? And is there a doctor, is there
(12:14):
an expert? Is there a scientist that can tell you
that I have been able to exclude other causes and
this particular product is a substantial contributing factor to that
specific injury in that plaintiff. So I think I think
one has to start there. And unless you really truly
understand the components of general and specific causation, I think
(12:39):
you're doing yourself and and your client a disservice of
getting into a litigation and to you to you really
understand that those those components, and you know that's just
a starting point, you know, then then then we talk about,
you know, is that drug and as we often see,
you know, drugs have a of shelf life, if you will,
(13:02):
whether they're actually branded by the innovator or the manufacturer
that invented that particular drug in a field, and after
a time that drug will become generic. And are your
cases clients that took the generic version of that drug,
(13:23):
Because if they are, you must understand the litany of
cases involving generic drug liability and whether you can bring
suit and find liability against the generic manufacturer. Because there's
a case by the name of Mincing that we were
working on litigation with regulin, which was some fifteen years ago,
(13:44):
and the US Supreme Court came down with a determination
that a generic manufacturer cannot be held liable for a
defect in a warning the lack of warning to a
particular patient, because they can't change the warning. Warning has
to be changed by the brand, manufacturer or the innovator
of the drug. And therefore they got ah, they got
(14:06):
a pass. The generics did so before investing the time
and energy and money on cases, you've got to understand
who that manufacturer is. And that seems simple and yet
and it's really not. It's something that takes some work,
some legwork, some understanding, and some discussions with whether it's
(14:28):
a warning expert, whether it's a toxicologist, whether it's a doctor,
in the field of the of the area in which
you're pursuing a case to see what they would need
for a warning and what they had for a warning
at the time. So there's another you know, kind of
say cautionary tale as too. Not only can that particular drug,
device or pass a psyche cause injury, but is it
(14:51):
that's identifiable to a true brand or innovator manufacturer?
Speaker 3 (14:56):
Now is one of the things that you have to
also prove is that the manufacturer knew that their product
could cause this, like for example, roundup lyso fate you know,
linked to non Hodgkins lymphoma. Do you have to prove
that they knew that it was linked to that or
is it just good enough to say, hey, you use
this product.
Speaker 5 (15:16):
We know it's linked to non Hodgkins lymphoma. We're telling
you right now that we can tie that to you,
and they're they're on the hook for that.
Speaker 3 (15:25):
So if there's something new coming out, is that what
an attorney really needs to also dig into.
Speaker 1 (15:29):
Well, I think that what we ultimately have to prove
is a company new or should have known of a
particular defect, of a particular danger propensity of a drug
or device or pesticide. And you know, I'm going to
say this, Eric, you know, nine times out of ten
we will find that they actually did know. We might
(15:51):
not know in the beginning, but you know, I think
with diligent discovery, whether it be written discovery, requests for admissions,
requests for production, interrogatories, or actual depositions themselves, nine times
out of ten we're going to be able to show
a jury in And this is really what you know
upsets juris is not only should they have known, but
(16:12):
you know, the documents just substantially reflect that they did know.
So it's it's a it's a tough one, you know
what the sciences of course, the changes over time, and
there are cases that there was there was a company
that could not have known of a particular would I
(16:32):
say defect that could be a marketing defect that is
that they didn't want about an injury that could be
caused by it, but there was no way to know.
That is a that's a rare that's a very rare circumstance.
Speaker 3 (16:46):
Yeah, and I think you're right, you know, when I
saw some of this information myself, you know, one being
like talcum powder. Another one that I think most people
would would know would be like the Ford roller rollover
cases and then the Firestone tires that that when the
information came out that they knew it, they just were
going to bake it into their sales numbers.
Speaker 4 (17:08):
Like you mentioned, the juries. Get so upset about that,
And I.
Speaker 3 (17:11):
Don't think the general public understands that these companies are
just making a financial decision and saying, Okay, it's going
to be too expensive for us to go back and
change the production for this medical device or this vehicle
or this pharmaceutical.
Speaker 4 (17:26):
We'll just run with it and see what happens.
Speaker 1 (17:28):
Well, I think that's that's true to a large extent.
At that point in time. You know, these companies have
spent tens of millions of dollars in a particular pivotal
clinical trial or R and D or the marketing of
their prepared to market a mass market if you will.
(17:50):
You know, I think about YOS. You know, when YOS
came out, they had three thousand plus sales reps that
were already trained prior to the the the FDA granting
the approval of box and lo and behold. It was
a monster seller, and it was a two billion, three
(18:12):
billion a year drug that they really didn't adequately research,
but they did know that there was a clotting issue
associated with it, but they just, you know, from the
evidence that we saw, just ignored it and pushed on
and not just not just slowly approached the marketplace, but
(18:36):
but flooded the marketplace with you know, sales reps in
every doctor's office, in every internal medicine doctor, every treater
with these cocks two inhibitors that that you know, were
this going to be this great pain reliever for people
with arthritis or rheumatoid arthritis. That that turned out to
(18:57):
be a disaster, and of course the drug was removed
from the market. But you know, it's sad that this
is becoming that this is much more the norm than
the exception, and that is the mass marketing of drugs
and devices without adequate work up. And you know, and
the fact that what they give the FDA or don't
(19:20):
give the FDA is often the difference to whether a
drug is approved or not.
Speaker 3 (19:28):
Yeah, speaking of marketing, I'd like to kind of shift
gears to more of the marketing on the legal side.
Speaker 4 (19:35):
For these cases.
Speaker 3 (19:37):
You know, one of the biggest changes I've seen over
the last fifteen years is just the way that.
Speaker 4 (19:43):
These cases can be obtained.
Speaker 3 (19:46):
And I would personally warrant anybody who's looking to get
into these cases who doesn't have a lot of experience,
you know, be careful what you hear from the marketers
because they make all their money up front. Whatever you
get might be worth a lot, it might be worth nothing.
Do you have any advice when it comes to, you know,
marketing for these cases. You'd already talked about, you know,
(20:07):
doing your research and making sure that you do your
homework before you jump in. But as far as you know,
if there's a firm out there that wants to get
ozempic cases or something else that's that's going on these days,
how to go about vetting those marketing firms.
Speaker 1 (20:24):
So I would start by saying, yeah, I agree with you.
There's been a tremendous shift, if you will, and just
by volume. I think part of this involved the Camp
Lijune litigation which I am involved in, which was the
water contamination case in North Carolina which Camp was June
was the marine camp that housed both marines and families,
(20:49):
and the federal government. A bill was passed some two
years ago in August that they were going to compensate victims.
There was a studied on that showed equipoise or a
likelihood that the water contamination causes a number of injuries,
(21:09):
including over ten different cancers, Parkinson's disease, and some birth effects.
So this was in a document and this came out
and you know, by and large, you know, any lawyer
that does any of this type of work, or maybe
wasn't even doing this type of work, thought this was
(21:31):
the greatest case ever. And because of that, there was
an onslaught of ads that hit the airwaves. I think
it was really unprecedented that over a billion dollars was
spent in advertisements across the country. Because of the speed
by which people were trying to acquire these cases and
(21:53):
the number of vendors marketers that were involved, there was
a tremendous amount of fraud. It came in every way,
shape or form that these cases were acquired by groups
that either were not qualified to take in acquire cases
because they couldn't understand if one was real or not,
(22:15):
or there was active fraud by the marketers. And I'm
not you know, claiming particular one was or wasn't, but
it happened to be an awful, awful a bunch of
fraud across the board in campus that has carried on
just throughout now in the last I would say, you know,
three or four years, five years starting just before that,
(22:39):
but that really culminated. I think in the numbers, you know,
how do you prevent how do you with these these
groups that acquire cases, how you work with them to
make sure you've got real cases as opposed to a
fraud plaintiff. And I think that there's no perfect way.
I think that that I've learned personally is I need
(23:01):
to be more hands on. I need to take those
first leads to immediately talk to every single one of
those clients, either you or a lawyer in your firm
needs to be hands on with that. Make sure that
they understand that you know that you are their lawyer,
make sure that they are a real plaintiff with a
(23:23):
real injury, and immediately order medical records to see if
you know you we all need, you know, two things
in these cases, it doesn't really change. You need proof
of exposure or proof of use and proof of injury.
And those are two distinct, distinct areas that you you
(23:44):
must produce evidence to bring a case or ultimately to
try a case, ultimately to prevail. So you know that
means that means expedited medical record review. You know, talk
with clients, get those first records and look at them.
See does this is this really a Parkinson's disease? Is
(24:06):
this really uh you know, kidney cancer?
Speaker 2 (24:10):
Uh?
Speaker 1 (24:11):
Is this? You know I'm looking at these right now, specifically,
I'm looking at deppel Bavera case. Deppel Bavera was a
uh was a drug injectible of birth control of injection
used since the nineties, has been around a long time
and some time ago, not that long ago. A study
(24:33):
from France from using the Socialized Medicine France French database
showed a huge increased risk for Deppe of Bavaria use
in meningeoma or brain tumors in women. A really big case,
really difficult case to prove specific and general causation, but
(24:54):
also generic issues. But that said, uh, big injuries, big
case A Vizor manufacturer Engineeric at two thousand and five.
You know, we immediately are all over these medical records
if we can find them. You know, when you have
an older case, you also have another issue with you know,
obtaining medical records, because we know that that often hospitals,
(25:19):
doctors' offices destroy records after ten years, sometimes last. So
now you have the added obstacle of approving your injury
with without medical records. Pretty tough to do. That said,
I think that's what one needs to do. You need
to be vigilant. You just you cannot allow a company
(25:39):
to tell you know, here's here's one hundred cases and
good luck to you, you know, and then this just
keeps going on without what I would say, at daily
checks and balances of determining proof of use, proof of injury.
So I would start there.
Speaker 4 (25:56):
Yeah, I think you need to do just as much
due diligence into who you're marketing with as you do
into whether you want to work in the case, there's
two ends of the spectrum as I see it, there's
innocent ones, meaning a lot of times a person sees
these ads, they're promised thousands, if not millions of dollars,
and they call a couple of the phone numbers and
(26:18):
they say, do you have kidney cancer?
Speaker 1 (26:19):
No?
Speaker 4 (26:20):
Do you have kidney cancer no?
Speaker 3 (26:21):
The third time they say yes, you know, because they
feel like, well, I'm injured, but maybe I don't have
the exact injury that's going to get paid, so they
slip through the cracks. And then on the other side
of it, if you're doing due diligence and to talking
to a marketing company, make sure that the company that
you're working with is actually doing the marketing. I know
that sounds more than obvious, but I know in Camp
(26:43):
Lejune what was happening is there was so much money
going around. These marketing companies didn't want to say no
to anybody who had a budget, so they would go
out and look for other people to help bring in
these cases. That means that the attorney is ultimately responsible
from where that case came from.
Speaker 5 (27:00):
But if they hired marketing company A, and marketing company
B was hired by marketing company A and was doing
something nefarious, meaning ignoring TCPA violations or doing something to
bring these cases in that wasn't above board, the attorney was.
Speaker 4 (27:15):
Ultimately on the hook for that. So do your due diligence.
Speaker 3 (27:19):
A lot of these firms that I see are spending
lots of money on this.
Speaker 4 (27:22):
It's worth the extra time to make.
Speaker 5 (27:23):
Sure that you're working with somebody who's complying with all
the advertising laws.
Speaker 1 (27:27):
I completely agree, Eric, And I'll say this. You know,
I've been doing this a long time, and I've worked
with groups that I know personally and I know that
they're actually getting the cases. But if there is a
new group I want to work with, I will get
them on a zoom call and I will say, listen,
are you getting the cases? Look at me in the
eyes and tell me are you getting these cases or not?
(27:50):
Are you getting from vendor at BC and D. And
then I'll go visit them. If they're in Chicago, I
will go to Chicago and I will sit down with them.
If they're in San Diego, I will go to Sandia.
Let's say, show me your operations, so you know how
many people you have answering phone calls, what are your
checks and balances? You know, what do you have in
mind to prevent fraud? And how are you doing it?
(28:11):
And I think it takes that extra step, especially now.
Maybe didn't ten years ago, but it does now, and
so I think it's it's crucial that you take the
time to do it right.
Speaker 3 (28:22):
Yeah, I think over the last I was saying ten
to fifteen years, there's so many positives that are happening,
meaning there's more specialized services. You've got someone who can
just do your intake, You've got someone who can market
you for social media. You've got TV and broadcaret paths
and streaming audio or streaming video, all of these different
(28:44):
options that I think are helping to make the industry
overall more efficient, because I don't think this existed fifteen
years ago, where you had all these specialized companies that
focus on one link in the chain for this client acquisition.
But like in the industry where there's a lot of
money going around, you have some bad actors, or you
just intentionally or you just have people that aren't as
(29:05):
good as others that want to join in the game.
Speaker 5 (29:08):
So any any last things you would say on you know,
marketing and the mass towards to someone who's kind of
considering going in that way, because I see every year
at these conferences there are successful PI attorneys that go,
I've been hearing about this mass toward thing for a
while now, and I want to jump in.
Speaker 4 (29:26):
Any last things you would say to that person.
Speaker 1 (29:29):
Yeah, I think the points that we've talked about are crucial.
They're very important. I would say this I would designate
a maybe you call them whatever you want to call them.
I call them a compliance data person. But somebody that
is that's their job to make sure internally we have
a two really crack pot you know, data managers here
(29:52):
that I really rely on. Guys. I can't do that.
I mean, I have oversight when I talk to clients,
But in terms of the data, the intake the medical reviews,
make sure that that they they comport, make sure that
they work that this isn't you know, if you see
a red flag, it's probably meaningful, you know, respond to
(30:13):
it and don't just say, well, I'm sure it was
just you know, I'm sure it was just to aberration.
You know, No, it's probably a real problem. And so
I would you know, designate someone that is, uh that
that's their duty to you know, look for that that
fraud and make sure that you're getting real cases from
(30:36):
you know, real clients. Yeah.
Speaker 3 (30:38):
The other thing you said that I think can't be
overstressed would be creating that relationship in the beginning. And
I think you'll probably saw this in Campbella June. There
were so many people who were signed up with multiple
law firms because they get signed up by law firm A.
Speaker 4 (30:55):
Law firm A sign them up, didn't communicate well with them.
Speaker 3 (30:59):
They might have reached out law firm AY several timesn't
hear back, and they're like, I don't know if I'm
really covered in this, and they'll sign up with law
firm B. So you had lots of these dual reps
that one person was signed up with two or three
different law firms. If you can create that relationship in
the beginning and they know that you're working with them
and communicate.
Speaker 5 (31:18):
How that process works and what timelines are, otherwise this
person might just see another ad and say, I'm going
to go sign up with somebody else because I don't
know that my attorney's working for me.
Speaker 1 (31:30):
Yeah. Absolutely, and I think everything you just said is
right on, and I think that you know, I'd like
to think that we're going to get better, that there
won't be any fraud and it'll but but frankly, there
is just too there's too much money at play here
(31:51):
with these with the marketing groups. But I would also
stress that you know, get to know the groups that
you're working with, really really know personal as opposed to
you know, a phone call here there or a discussion
about how many cases you think you want and how
much per case there is. I just think that's such
a that's nothing more than a starting point, and you
(32:13):
really need to get to know people.
Speaker 3 (32:16):
Well, David, I really appreciate you sharing your knowledge and
experience with the audience. Is there anything that you wanted
to cover at the end here, or at least let
people know how to get a hold of you if
they've got questions someone with your experience. I'm sure there
was a lot of attorneys that would like to pick
your brain.
Speaker 1 (32:32):
Yeah. Sure, Well, I mean I'd welcome discussion if someone
wants to discuss the process. Yeah. I have been doing
this probably as long as anyone has been doing mass
towart at this point. I guess you know, I was
there in the in the nineties and the you know,
mid nineties, and I've been there in this space since.
(32:55):
I'm happy to discuss. Eric, if someone please feel free
to let them know my TechEd info.
Speaker 3 (33:01):
Absolutely, we'll put in the show notes. Thanks again, David,
appreciate your time.
Speaker 2 (33:05):
Thanks Eric, Thanks for listening to the Legal Mastermind podcast
presented by Market My Market. If you can check out
additional episodes and recaps at Legalmastermind podcast dot com.
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