Engaging Experts
After 25 years helping litigators find the right expert witnesses, Round Table Group’s network contains some of the world’s greatest experts. On this podcast, we talk to some of them about what’s new in their field of study and their experience as expert witnesses.
Engaging Experts
Engaging with Panel Experts, Dr. Jolie Brams and Mr. Kevin Quinley
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In this episode…
What truly makes the attorney-expert relationship work? In this revealing conversation, host Noah Bolmer sits down with two veterans of expert testimony, forensic psychologist Dr. Jolie Brahms and insurance expert Kevin Quinley, to unpack the nuances of this critical professional partnership.
The discussion takes us behind the curtain of expert witness work, revealing what both sides should know but rarely discuss openly. From that crucial first phone call where relationships are established to the diplomatic art of declining problematic engagements, our guests share candid insights about navigating the complex human dynamics at play.
Both experts emphasize that respectful communication, clear expectations, and professional boundaries create the foundation for successful collaborations. They reveal the red flags that signal problematic engagements, share strategies for delivering unwelcome opinions, and offer practical advice for working effectively with diverse legal teams.
Particularly valuable is their guidance for newer expert witnesses. Technical expertise alone isn't enough – successful experts need emotional intelligence, communication skills, and thick skin. As Dr. Brahms eloquently puts it: "We're keeping alive our judicial system, which is what makes us a democracy." This perspective elevates expert testimony beyond mere transaction to a crucial component of justice itself.
Whether you're an attorney who works with experts, an expert witness yourself, or simply fascinated by the inner workings of our legal system, this conversation offers rare insight into relationships that shape courtroom outcomes. Subscribe to Engaging Experts for more illuminating discussions with the professionals who help determine the course of litigation across America.
Episode Introduction and Guest Introductions
Speaker 1This episode is brought to you by Roundtable.
Speaker 2Group the experts on experts. We've been connecting attorneys with experts for over 30 years. Find out more at roundtablegroupcom.
Speaker 1Welcome to Engaging Experts. I'm your host, noah Balmer, and today I am excited to welcome two distinguished panelists all returning guests to the show. First off we have Dr Jolie Brahms. She's the owner of Brahms Associates, a psychology practice and forensic psychology consulting firm with extensive experience in both criminal and civil matters, ranging from state and federal sentencing to educational litigation and beyond. Dr Brahms holds a doctorate in clinical psychology from Michigan State. Dr Brahms, welcome to the show, thank you.
Speaker 1Also joining us is Mr Kevin Quinley, founder of Quinley Risk Associates, a risk management consultancy and expert witness service provider. Mr Quinley holds numerous certifications in insurance management, adjustment and underwriting, among others. He has a master's in government from William Mary. Mr Quinley, thank you so much for being on the show. It's my pleasure. Thanks for the invite. Of course, let's jump into it. So this series of panel discussions is on the topic of relationships. Every engagement is dependent not only upon expertise and experience, but it's a web of interactions between members of the trial team and the expert. At the core is the relationship between witness and attorney. Mr Quinley, how do you get off on the right foot with attorneys?
Speaker 3That's a very good question and let me quick hit, take a minute to quick hit on some ideas in no particular order. Number one, on the first call be more on receive mode than send. Okay, You've got one mouth and two ears.
Speaker 3We've all heard the no-stream. Number two ask good questions. What I mean by that? To assess your fit for the case, such as the universe of documents that need to be reviewed. That's very critical. Is there a scheduling order on the case? If so, what deadline dates for work product do those present? Is there a conflict check? Is the subject matter area in your expertise area?
Speaker 3Number three it's an audition, but I would say, don't be too salesy. If they ask you about your bona fides, feel free to explore those. Be interested, be engaged with your energy up. Do your homework on the case, if you can, beforehand. What I mean is this Sometimes you'll get enough information on the case where, in advance of that audition phone call, you can either Google the case or, if it's a federal case, go on Pacer and look up information about the case. That can quickly, doing a little bit of homework, orient you to the contours of the case, the general thrust of the case, and enable you to ask smart questions. Get all deadlines clear up front and don't overcommit.
Speaker 3I think that's important.
Speaker 3Be clear that you are not an opinion for hire.
Speaker 3I think I always try to make clear that I won't know what my opinions will be until and unless I review the materials, I don't guarantee a favorable opinion.
Speaker 3But if I can't give one, I will pick up the phone, not write to you pick up the phone and explain it to you and set the ground rules in a follow-up engagement. You know, in terms of billing the materials that you need and be willing to sleep on it if it's not super time sensitive you know there's sometimes when you learn about a case, I don't want to be pressured into making a hasty decision and I will buy myself some time, just like one day, and say, look, let me process what you've told me and look at the entire continuum of other obligations I have currently with other cases continuum of other obligations I have currently with other cases professional meetings, personal vacation and get back to you. So I think being willing to say no thanks and maybe recommend somebody else if you honestly self-search and don't have the bandwidth, those are all some quick stream of consciousness tips on how to get off on the right foot with counsel.
Speaker 1Dr Braum, same question how do you like to get off on the right foot with an engaging attorney?
Speaker 2I think that getting off on the right foot is starting from the very beginning, and that means returning phone calls. I get many, many attorneys call me and they say you know you were highly recommended, but we got two other people and you're the only person that only returned her phone call but, most importantly, returned her phone call with some interest and knowledge on the other end. Now I'm very fortunate. I have a practice director and if you have a busy forensic practice, I strongly recommend you get someone to work up front, because as the busier you get, the more calls you're going to have at all times of day and night, the more demands, the more reports to proof.
Speaker 2But what really really has promoted my business and I don't mean that in a sales way, I mean that in a professional manner is just not my work.
Speaker 2And again, I'm sure Mr Quindley will agree with me, you have to be perfect in what you do, you have to be very thorough. It's what she does at the front end. She knows my business, she really understands civil and criminal litigation and when these people call she basically vets people and she also talks to them about who I am and what we can do and she generates not sales, but enthusiasm, but enthusiasm. She also sets, as Mr Quinley states, limits and boundaries. What are the expectations, what funding is available, all of those things. And she provides these people also with other expert consultations and testimony that I've given. So that upfront shows your practice to be professional and it creates a whole ambiance for the rest of the consultation that you are not somebody who just was found off the street, that you're a knowledgeable person, that the people who work with you will get things done for your case, for your clients. So that is, to me, is the most important first step.
Speaker 1Let's talk a little bit about some of the intangibles that go along with those initial phone calls. You had said, Mr Quinley, not to be too salesy. Can you go into that a little bit? How does somebody have a demeanor that shows professionalism but isn't necessarily trying to pitch the attorney?
Speaker 3It's a good fine line to walk a tightrope to walk. You want to be confident, but I think less promotional and more descriptive of what you bring to the table, if applicable. When I talk to prospective attorneys and we start covering that terrain, obviously I'll volunteer to send them after the call a copy of my current CV. And then I have been a contributing editor to some of the training textbooks used by a national organization for training people in insurance claims. I've given 300 presentations, I've been engaged in 160 cases, I've testified in 50 plus depositions and 15 trials. So just to give them that's factual, you know, like you know it ain't bragging if it's true, but to be factual and to let them know you know this is not a hard sell and I'll say that it's not a hard sell. I'm not selling a hard sell and I'll say that it's not a hard sell. I'm not selling, you're buying and you know I'd love to work with you.
Speaker 3If the stars align, we'll get to that in terms of bandwidth and deadlines and size of the universe of documents.
Speaker 3But I think that's where you just factually F-prompt it rather than being you know, but spend most of that initial time listening and then give them an honest reaction as to whether you think you can be a resource or not, which is not exactly the same thing as warranting a favorable opinion. I always caveat my reactions by saying, based on what you've told me, I think there's some traction there where I might be able to help as a resource. I think there's some traction there where I might be able to help as a resource. But even if you end up bailing on the case because you don't think you can support them or there are weaknesses in the case, you're providing a service for that. So that's a long-winded answer as to how to be more informational than promotional and augment that with a follow-up and I love the point that Dr Voms made that you follow up, as you promised to, with your CV and a fee schedule and, if they ask, and a professional biography.
Speaker 1Dr Voms any tips on demeanor?
Speaker 2Yes, the way that I look at everything I do in terms of the sales, the issue, as Mr Quinley talked about, it's authentic marketing. It is who you are over the course of time. Now Mr Quinley states he's been doing this for 47 years. I've been doing it for 42 years. I don't think we're in a competition for age or looks, but, for example, I had an attorney call me who I did know from before. Very nice firm, medium-sized firm.
Speaker 2I do a lot of personal, not a lot. Several personal injury evaluations for them, and they were stating how this woman was in an accident and that she has significant emotional trauma from that. Given the nature of the accident, that's understandable. But he also mentioned that she was already on social security disability and he said that that was for depression. Now I know, because I've done this for more than four decades, is it's very difficult to get SSI and she had to have another diagnosis than depression and thus we need to look into her premorbid functioning more than just an assumption. There's much more to it than meets the eye. So the fact that's a very simple example, but you have to use your years of knowledge to basically do the crystal ball.
Starting Off Right with Attorneys
Speaker 2I have people call me up about cases and I tell them what to do and they're like how did you know to do that? Now do I tell them what to do because it doesn't get me involved. Sometimes, many times I think this is extremely important, especially if you have a long career ahead of you is you give information that is helpful, without the expectation of getting that case. You become a colleague and you make it very clear in that conversation I've given you this information about. I do a lot of death penalty work, a lot of very high-profile criminal cases, and I realized that not everything that anyone has to offer will cover all bases. So what I say is even if you don't hire me for this, consider me a friend and colleague. You know we always talk personally. Where did you go to law school? Who do you know have a real personal conversation? And when they know that this is not a pressured situation, because in truth, although I want to work with people, I don't need the work.
Speaker 2But it's always important to have that. But that's not the reason for the call and what I find is that years later it could be eight months later, it could be three years later. I will get a call back either from them or from someone they know, because I acted as a colleague and not someone who's there just to provide a service. And that is what the attorney-expert relationship should be. It should be colleagues. We have boundaries, we have demands.
Speaker 2As Mr Quinley states, we don't get paid for an opinion. We get paid for our time and expertise. As a psychologist, I put that in my releases all the time, that we are paid for our time and expertise and not to provide an opinion. And I know sometime I hope we'll talk about bad opinions, because there's always bad facts and bad opinions, so there's ways to handle those that actually be very proactive. So, again, it is a relationship and if you have an attorney who calls you and you don't feel you can establish that relationship, it never ends up good.
Speaker 2Very briefly, and there was an attorney that called me I won't give any more details who was perfectly nice on the phone. She was perfectly polite and appropriate, but there was no way to establish any excitement about the case with her, no way to establish a connection. And I did take that case and the case is terminated, it's been pled out, but it was a miserable experience, I think, for both of us, because I was looking for a collegial connection and some excitement about the case and she was very factual and bland and I don't think it was a good fit. I don't think it was a good fit and I don't think it was from the beginning. Not that we did not help the client, because I believe we did help the client, but I believe in some ways we could have been more effective and just better had there been a mutual meeting of the minds.
Speaker 1That's an excellent segue to red flags. What are the sorts of things? You've mentioned a few, dr Brahms, regarding a lack of excitement, somebody who doesn't maybe appear totally invested in the case. What are some of the other red flags that you look for during initial calls and maybe your first meetings together before you've accepted the engagement or when the engagement has just begun?
Speaker 2I think that there are many red flags, that you have to be experienced and willing the other word is willing to accept, because many people really want consultative work and they're willing to overlook those red flags. One of them is a lack of curiosity when you talk to them about possible hypotheses and possible ways that a case can go. There are people who look at things very simply, and so I was contacted about two months ago by a personal injury attorney who did not work for a personal injury firm. They worked for a corporate litigation firm and they were asked to do this personal injury case by a client who spent I don't know how much probably a million dollars a month easily, as they were the firm that dealt with this client's gigantic international business and I believe they were talked into dealing with this personal injury matter. I got a one-sentence email from the attorney who says what do you know about X, y or Z if you're interested to call me? That was it. No, dr Brahms. No, thank you, nothing. We did contact him by email and he says well, all I need is to do one of those psychological tests and give me a diagnosis. Well, I wrote him back and I said a diagnosis means nothing in terms of personal injury. You have to look at functionality history. There's a vast amount If you want to really represent this person appropriately. It's more than a diagnosis. And he wrote me back an unpleasant letter, an unpleasant email, stating that he had found three other experts who knew what they were doing and I did not know what I was doing.
Speaker 2Now the red flag was number one, that first email. The red flag was you don't speak to anyone. You don't speak to your little brother like that if he just bothers you. Okay, you don't send anyone an email like that. My second email was as cursed as the first one. You don't get somebody work with someone who's convinced that all you want is a 10-minute evaluation for a diagnosis. And the other issue was the fact that they were a corporate litigation firm. What are they doing? Personal injury for? Now, what I do is Mr Quinley does is I Google as I talk and my practice director Googles as she talks. We Google the firm. She'll tell me that she's the one who told me initially that they were a corporate litigation firm. So it did not work out. But those are red flags Now, briefly, had I done this case and I had gone first of all, legally, I have to go way beyond a diagnosis.
Speaker 2Professionally, I have to go way beyond a diagnosis. If I just listened to what he said for the money, I would be hurting my career, my reputation and I would not be helping that claimant, I would be hurting my career, my reputation and I would not be helping that climate.
Speaker 1Mr Quinley, same question what are some of the red?
Speaker 3flags that you look for in initial conversations for a new engagement. Well, I have my own pet list, in no particular order. Number one would be unrealistic deadlines and timelines. I'm talking about last minute hair on fire, 11th hour engagements, where they've known about the deadline for months and now they've delegated to some legal assistant or paralegal find me somebody who can fog a mirror. I'm sorry, I'm not McDonald's. Would you like fries with that? We are professionals. I don't put it that way to them.
Speaker 3But inwardly, my internal dialogue is WTF. What have you been? Which is legal, legal abbreviation? You can fill in the blanks mentally. What have you been doing on this case for so long? Do I want to get into that environment? Okay, enough said.
Speaker 3Number two comments like this I'm shopping around for an expert. Okay, I'm not in a gasoline price war. This is not a commodity environment. What I offer, I try to offer, is a bespoke, customized work product. So if I get a sense that it's a commodity or my last expert bailed on me, that's a red flag. Now, it could be perfectly legitimate reasons. I've had them illness, death, whatever but I need to know the context of why that prior expert is no longer on the case.
Speaker 3Another comment I will write the report or disclosure for you. You just need to sign off on it. Okay, I'm sorry, I don't do business that way. I'm not going to. You know, as Dr Brom said, it's my name and reputation on the line. So if they say I'm going to make things easy for you, I'm going to write the report, no, when the red light goes on and I'm sworn in to testify, or walk into that courtroom the longest walking journey in the world from outside with the bailiff saying it's your time, mr Quinley, I'm the one who's got to defend that. So if they say I will write it for you, to me that's a red flag. Or I need a report and experts saying such and such. Okay, again, they want to put channel my opinions into a prefab mold.
Speaker 3No, doesn't work that way. I'm going to reach my own independent conclusions. Or they need another expert in an adjacent subject matter discipline. But they want me to go beyond my swim lane, beyond the bounds of my professional expertise, and basically get two experts for the price of one. For example, I work in insurance claims processes.
Speaker 3A lot of these cases also involve insurance coverage questions and interpretations. That's a somewhat adjacent but separate field. I consider myself an expert in one but not the other. But sometimes they are interrelated and they want to push the boundaries of where I'm willing to go. They want to push the boundaries of where I'm willing to go, tire kickers, which appear to be focused inordinately on costs and budgets and constraints.
Speaker 3I understand the need for cost consciousness, but I don't want to feel like I'm micromanaged or have to say, mother, may I, before I do anything on a case, how much will it cost? How long will it take? It'll take. However long it takes, it will cost whatever it does cost. My focus is on doing a thorough job, not on wondering gosh, am I going to get a bill complaint here?
Speaker 3A couple final thoughts. A firm that I've had at one or two firms say we don't pay retainers, have a great day. And then they've come back to me after trying to find an expert who will work for them without a retainer and said, yeah, we'll pay the retainer, I'll prep you for the deposition on the morning of I'll meet you that morning. No, I don't work like that.
Speaker 3I tend to be OCDC and there are issues that I want hashed out pre-deposition or pre-trial with counsel. None of this stuff. I've made that mistake before at the beginning of my expert witness journey the morning of that doesn't work. And finally, I've had this happen a couple of times where retaining counsel says trial is a month away, do not spend any time prepping. No, no, it doesn't. Again, it doesn't work that way. I'm not going to. I'm going to spend time prepping because I'm the one who's going to be called up there on the witness stand and I know it could be settled. It could be continued whatever. And I know it could be settled, it could be continued whatever. Little shop of horrors. Tour of what I consider personally. Red flags.
Speaker 1Some of the guests that I've interviewed have mentioned that one strategy or tactic that attorneys will sometimes use is to choose a higher profile expert, such as yourselves, and just having that name attached to the case can drive the case towards a settlement. Has that happened to either of you and, if so, do you put anything in your contract to make sure that you get paid in case of a settlement?
Speaker 2I can answer that one. Yes, it does happen, both in a good way and a bad way, and it depends what the lawyer understands. I have been used in cases, especially criminal defense, as a checkbox. They have to hire a forensic psychologist. They do. They don't really understand what you do or what you're doing.
Speaker 2I can talk about this because it's on the news.
Speaker 2I had a case where the attorneys, in my view, did not do what they were supposed to do and they used me as a check box and did not give me the resources I needed, did not give me the time that I needed.
Professional Demeanor and Avoiding Red Flags
Speaker 2I don't want to be a check box and no one should do that, both for the client as well as for yourself. But I will have to laugh and state that someone's experience as myself or Mr Quinley hiring someone like this sometimes does move a case along, and I've had cases where I'm like, oh great, I get to work with these people, and this happened maybe three, four times in my career and the minute they see me opposing on their side, opposing counsel, just settles. So I didn't. And as far as getting paid, I probably spent, you know, at that point, 10 hours looking at the records and I bailed for what's fair. So, yes, I believe that, having someone I've been on both sides of cases and sometimes I testified against people that are very, very I could put this in your face type of people nationally know people and, yes, it does put fear into the other side.
Speaker 3I would have to confess infrequently. I have had a few cases where retaining counsel, well into the case, with some key deadline approaching, has indicated to me that my presence on his side helped spur case resolution. But as I, much as I would like to think that my footprint is such that the sheer mention of my name is an intimidating factor to the opposition, I have to candidly say you know I don't know whether it's flattery I, out of 160 where I felt that happened, I'd love to see that happen. But I don't have the hubris of buying into that and saying that for that reason it would scare off or have a material impact on case resolution or progress.
Speaker 2But you know, mr Quindley, I believe that the quality of the work that an expert does does push towards settlement. I believe that if you write an articulate report, if you do an articulate deposition, it clearly pushes towards settlement. And absolutely, and obviously, when you and I do these things, you only do it from my perspective. You know, I only think about the other side. Whether it's a plaintiff or defense attorney depending who I'm going to retain by or, mainly in criminal cases, a prosecutor, you're always thinking 10 steps ahead. You write honestly, you perform honestly, but you, the best expert in the world, thinks ahead. They don't think just about what they have to say. They think about questions that people are going to ask. They don't think just about what they have to say.
Speaker 3They think about questions that people are going to ask. I totally agree. And then the decision turns on the quality of your work product rather than my brand name, however exalted I would like to think it is.
Speaker 1Excellent points. So we've accepted our engagement, we're continuing on. It's going to be a positive engagement. What makes for a positive relationship during the engagement, once we have got beyond the initial phone calls and we're right in the thick of it.
Speaker 2Well, someone told me the other day, noah, that the best thing would be alcohol, that alcohol would definitely solidify our relationship. But again, I've known him for about 15 years and I think our relationship is already solidified. But when I knew this podcast was coming up, I thought that would be something interesting to share. But I think that what he meant was, besides the fact that drinking is something he likes to do, I think it means that moving along means that we have to have consultations, that you can't just have an expert do their thing and leave them alone. There has to be communication. And the problem that we run into is, when there's no communication, you're not updated, there's no hypotheses tested. You have got to have a continuing dialogue with your expert as this case moves on.
Speaker 3And I love the focus on relationships because I think that is great and I think that is aspirational. However, I will also say that in this work you find a whole range of quirky personalities and sometimes retaining counsel, they ain't looking for a relationship, it's more transactional, and so I try to be open to either style. I would love a relationship to start occupying that trusted advisor role that I think Dr Brahms has described. But not every attorney wants that and I've had some quirky and among experts you've got quirky personalities who might have the personality of a dead duck but they're still, you know, very authoritative. But in terms of I'll be briefer here in terms of a recipe for positive interactions or relationships, Number one is to set clear expectations, and that goes back to the engagement letter with the appropriate disclaimers about what you will and will not cannot deliver, the boundaries of your subject matter expertise, no warranty of a favorable opinion or a case outcome. Number two over-communicate. I totally agree with Dr Bombs there. To over-communicate with counsel. Err on the side of over-communicating, Because sometimes they'll. You know, I have found out by accident that my deposition is set for 20, some days ahead, where the case has been set for trial. My God, if I hadn't checked in, how would I have found out? So be proactive about that. Number three if you've got a jumbo bill, if you've got a really big bill coming, get out in advance of that and communicate that in advance to the client. That hey, this month's bill, this quarter's bill, is going to be higher than normal. And here are the context factors for it Big supplemental document production, some additional depositions. The scope of the engagement has increased. But don't never surprise the client with the size of the bill. Let them know beforehand, prepare them, and I think it's no guarantee but it helps grease the skids on that.
Speaker 3And finally, this goes echoes an earlier Be willing to pull the ripcord early if you cannot help, If you get into whatever the counsel tells me on that first call I take with a grain of salt, Not because I assume they are liars. But, as I say, the flattest pancake has two sides. And when retaining counsel contacts you, they're advocates, they're paid advocates and they're giving you one side of the case. And I usually find out that it's not black and white. There are shades of gray as you dig into the case materials. And if it's so gray that you don't think you can help then, I think, be willing at an early.
Speaker 3But in fairness to you and in the interest of transparency, I don't think I can help your case. Sometimes it's in a gray period, a gray phase where I will say, look, I've analyzed how this insurance claim was handled. There are some problems here. Some aspects I can defend, others I can't. I'm going to have to give ground where I must so I don't compromise my own credibility and with an eye toward future cases, inconsistency, but there are other aspects of the case that I can defend. If you're okay with that, then let's proceed on that basis, with those caveats. And I've had counsel say you know you're right, I agree. Sometimes it's the client who wants to fight it, but they understand and so it may not be that you're all in or you're all out. But you say, like every case has strengths and weaknesses, and some of those weaknesses I think you have to flag for counsel and say, look, I'm not gonna, I'm not gonna joust at windmills on some of these points, but I think it will boost my credibility on those points I can defend.
Speaker 1Yeah, along those lines. As you've both stated, an expert's duty is to the neutral truth, and you put that in your engagement letter. Sometimes I am not going to give you an opinion other than what my opinion is, regardless of what you want my opinion to be. You had just stated some of the methods that you use to give bad news to your engaging attorney and to the end client. Dr Brahms, how do you go about communicating bad news to your engaging attorney?
Speaker 2Well, I'll be honest with you. I've had a couple of cases in the many years I've done this that it truly is bad news. There's absolutely nothing that myself or any other expert can do to help a defendant that's in criminal cases. There's nothing that anyone can do in terms of sentencing. There's nothing diagnostically. There's nothing that anyone can do in terms of sentencing. There's nothing diagnostically. There's nothing to be myself or do I believe anyone else can do. However, bad news is not always bad news. There's cases that I have where I do not believe that my testimony is going to be helpful. I believe that my testimony would be hurtful because we would be picking at straws, we would be taking little minute details and making them into big things, and that is going to make a jury not trust the attorneys, not trust me. However, there are things that I advise and ask to be a consultant on a case to help that attorney deal with direct examination or cross-examination. I can give you a very brief example.
Speaker 2As you well know, there are many, many allegations of child sexual abuse in this country. Some of them absolutely seem valid. Some of them come from situations where there's questionable reasons for the outcry, and many times these children are being interviewed in small counties, where the interviewing techniques can be very coercive, very contaminating, and there's obviously been, if anyone knows this, 40 decades or four decades of research on this issue. I was early in my career to help develop some of these techniques, some of these interview techniques. But, very briefly, I believe that there's very little information for me to testify about. But I believe that this county has not hired the right person or has the right protocols and I think there are things that can help the attorneys bring that into the attention of the court, the jury or whoever. I can help them look at the family dynamics. There are many, many ways that I can help besides testimony.
Speaker 2Not everything that we do is testimony and there are bad facts. Most of the cases I have have bad facts. The people I work with are not very functional people. There's always bad facts. The people I work with are not very functional people. There's always bad facts.
Speaker 2So how do you deal with the fact that a defendant had a prior criminal history? How do you deal with the fact that in elementary school he broke a desk? What do you talk about? Well, from my perspective, I would talk about the whys. We don't hide facts. We deal with them. So our job is delivering bad news, but yet with good news with it, if at all possible, with some other way to be of assistance to that team or that attorney, if possible. But yes, it is our job to deliver bad news and many times I'll hear about a situation and I will warn people up front. I think this might be more bad news than good news, but do not hide anything from me, because you hide something from me and that's a huge issue is hiding information, because if you're on cross and you don't have everything given to you, you might as well not testify. You might as well just lose the case for the attorney and attorneys like to hide things and I am very strident about that. I need to hear what is happening.
Speaker 1On occasion it'll be one expert and one attorney and that's pretty straightforward, but very often there's large trial teams with a lot of moving parts. There may be multiple experts from different areas, there may be some experts in the same area, there may be paralegals, there may be assistants and a lot of different people. To what extent do expert witnesses interact with the rest of the trial team and do you prefer to try and work directly with the engaging attorney, or is it okay for you to interface through an intermediary like a paralegal or an assistant?
Speaker 3I feel comfortable with any of them and I think an effective expert witness needs to set aside job titles and treat anyone within that law firm structure as the client. Now, obviously I'd prefer to. You know it depends on the context, substantive issues on the case. I want to speak with the attorney, whether it's a partner or associate, on the case. If it's logistical issues with regard to specific documents, I need clarification on or need additional documents, clarification on timelines. I think it's important to contextualize the kind of information own.
Speaker 3I try to be unfailingly respectful and polite and essentially build good karma with every strata of the organization and hierarchy of that law firm so that, as opposed to an elitist view that I only deal with the partner, I only deal with the attorney. Because if you're curt, if you're brusque, if you take out your frustration on one of the lower, let's say the less exalted members of that hierarchy, I don't want them. You know. I want those frontline people, whether it's a paralegal, a legal assistant or receptionist, to say you know, mr Quinley is a pleasure to work with. I always thank them, always tell them have a nice day. It sounds trite, but I just think it helps in building this relationship and having constituencies, with multiple constituencies within the firm, saying yeah, he's easy to do business with.
Speaker 2You know that's an excellent point and I just like to elaborate on that. I believe that experts need to understand how attorneys work and they have to understand how we work. Obviously, when there's the initial phone call, I need to set something up via Zoom with the attorney. I'm not going to hear about a case totally from a paralegal. That would not be appropriate because those mutual decisions and relationships cannot be established. But they have to understand how we work.
Delivering Bad News to Attorneys
Speaker 2I understand that attorneys are very busy. I know the people I work with and I understand the roles of various people in those firms and, like you, I'm nice and all those things are important. But to understand where you can get information from, who has to get authority to do certain things is important. But what I find is many times they didn't understand what we do. They do not understand the amount of work it takes to do what we do. I've had the last. I'm not complaining. I'm very, very grateful to be doing well and be respected, but I probably have gotten up at five o'clock in the morning for the last two months and desperately trying to get things done.
Speaker 2I have a case on Friday. It might only be a 50 slide PowerPoint, but every one of those took tremendous research into the, into the discovery, consideration about how to make that, how to present it, how to organize it, what should not be in there. These are huge tasks. This is not getting up and taking five minutes to put together a little funny slide deck in order to really be ready to testify, to understand all of the timelines and the issues and the people. There's a tremendous amount that goes into this and I think attorneys need to know what it's like to live our lives as well and how we conduct our business, and so a lot of young forensic people get into this field and they really do not understand what attorneys do and therefore, unlike Mr Quinley, they don't have a lot of respect for people. It's like get me to the partner. I don't want to talk to you, whereas you can gather a lot of not only good points but information and assistance from other people in that firm.
Speaker 2So it's a mutual street, knowing what we do and we have to know what they do.
Speaker 3I think that underscores a crucial point of being proactive in one's communication with counsel. In other words, do not assume that they have top of mind awareness of your need for information as to the progress and status of the case, whether it's a rebuttal report deadline oh, by the way or a deposition date, or a trial date or a Dalbert type of exclusionary motion that, oh, by the way, has been filed against you. Take the bull by the horns. Do not assume that they will inform you timely. A lot of them do, but don't assume it. Put it on a regular follow-up diary, just a friendly check-in.
Speaker 3Has anything new that's newsworthy on this case happening that I should be aware of? Do you envision any deadlines over the next 60 days that have implications for my role in the case, and so on and so forth? That kind of regular follow-up. It's no guarantee, but I see it as a safeguard because they don't understand how we work and probably never will. That's where you get a bunch of experts together and, as therapy, they share stories about these types of weird situations. But there are some ways to try to prevent them and preempt them.
Speaker 1On the flip side, what else can attorneys be doing to be better attorneys vis-a-vis their experts?
Speaker 2I would say be intellectually curious and educate yourself. I don't expect I do not. I know that I can never do what Mr Quindley does. I'm not going to be a risk assessment person. He's not going to do what I do.
Speaker 2But if we were both attorneys working on a case, I know that I would want to find out as much as possible about what I need from an expert and what an expert might do and how to have a conversation with that person. You know, and I think from what I do, some of the things are commonality. So if I talk about parenting styles, every attorney should have read, you know, parenting Magazine or they should have listened to the Oprah show or whatever, and heard about these things. But what I find is that the way to be an excellent expert in what I do is to read the New York Times every day if possible, to listen and to learn about the world.
Speaker 2In the job I have, I'm very fortunate that I travel everywhere and I go to people's homes and I sit in their trailers and their apartments and at McDonald's and I've heard stories and I've had the blessing to be able to really understand the world around me. It's hard to just be an expert and know one field and that's all you know. I think that you have to see things in a much bigger picture and I think attorneys, to be good attorneys, need to have a better understanding of more than just what they do every day. Tastes are complicated, people are complicated and you do best when you are a worldly person.
Speaker 3And because it's complicated, be proactive, and again I hate to sound like a broken record. Do not wait to the last minute. Do not treat your expert witnesses like the fast food drive-thru at McDonald's. We are professionals, we're not the expert equivalent of an emergency room, and so be proactive, get your experts lined up early, be transparent, be thorough. Another mundane thing is pay your freaking bills on time. I mean, I have had you know.
Speaker 3Virtually all of my cases involve situations where somebody is claiming that the insurance company did not follow through on what it promised to do. Okay and I'll be on. Let's say Okay and I'll be on. Let's say the insurance carrier side of that. And my engagement letter clearly spells out the timeline for payment of my invoices, okay. And where they just ignore that, and, among other things, I appeal to their sense of fairness. Look, I'm trying to make a case that XYZ Insurance Company is a company that stands by its promises and here they're delaying and foot dragging and not living up to the very commitment that they signed on for at the beginning. Come on, help me out here. And so it marginalizes, it sends a message to the experts. Sometimes, you know you really don't matter.
Speaker 3We just want the work product, we want the opinion, we want the access, but pay you for your services. Manana, you know the lawyer is getting a paycheck or a draw and or a bonus. I'm not in a situation anymore where I have a paycheck and I'm fortunate, like Dr Brahms, that I'm very busy. But still I think that pay your bills on time, be early, be transparent, be thorough, be communicative with the expert.
Speaker 1Without naming names. Are there attorneys that you would not work with again and, if so, how do you handle when their firm contacts you?
Speaker 2That's a very difficult question, but I think it's an important question. You mentioned the name firm. We could start off talking about individual attorneys.
Speaker 1Sure.
Speaker 2And I think that you could either be very gentle and factual. It will not go over well. Nothing you say is going to go over well. You could say something like we worked on this case three years ago. I'll be honest with you. As Mr Quinley was saying, it took two years to get paid. I had to write the judge to get paid. I was a little concerned that you were so busy. You didn't really have time to discuss the case.
Speaker 2I don't think it went well and I really have other priorities right now. I can try to refer you to somebody else. That's what I can do, and they're not going to like you. But you also do not have to be, you know, forced into again in a situation that you don't want to work in, and that happens to me. I work with a lot of small town Ohio, especially in Ohio attorneys Not that they're bad people, but they are just not up to par in terms of going filling, not just the billing, although they don't always file that, but just in terms of what Mr Quinley is saying, staying in touch, having interest in the case, communicating, and it's a lot of work for nothing. As someone I know would say, it's too much sugar for a dime. It's just too much. But no, are they not going to like you? And you have to say to yourself does it matter? Do I really need this aggravation? And I have other things to spend my time on.
Speaker 3And that, I think, is a key point in terms of where you are in the life cycle of your career. Yes, as an expert, frankly, yes, you're starting out and trying to get traction, trying to get business and trying to get cases. I have taken those 11th hour hair on fire assignments.
Speaker 3I have taken cases with attorneys with whom I didn't feel that simpatico All of us have, and so hopefully you develop some positive snowball traction with your practice and word of mouth and you have a nice flow of cases and you have the luxury of saying thanks, but no thanks To your original question are there certain attorneys that you don't want to work with again? Absolutely yes, just like there are probably some attorneys who would not want to work with me again. I understand that. So I think the situation that you frame calls for the utmost diplomacy and delicacy, and I'm not sure how much detail that the expert needs to get into. I think it is. It is certainly you thank them for thinking of you.
Speaker 3Okay, but you can. You can plead workload, that's true, and with constraints, there are a whole lot of ways to diplomatically say no. You can offer them a copy of an article, you can recommend to them another expert in your field and, you know, be a resource that way. But I would hesitate to get into, you know, the fact that they were foot dragging on bills. They were difficult to work, all of which may be true, but I think I would soft pedal that, not go there and have some very plausible, legitimate other reason, and you don't have the bandwidth because it happens to be that particular attorney.
Speaker 2But then, mr Quinley, they tell you they're going to get continuance because they desperately want you. So they'll get a continuance. I hear that all the time. They'll get a continuance. But I want to talk about young forensic experts. In whatever field, you're right, there is a real goal that people have to have and that is to do whatever is necessary to get experience, to have that experience not just on your resume but in your head, that you have done case after case, and even if they're small cases or even if you don't like the attorney, that you have that. But what some experts get into, which is to basically be, as one of my colleagues states, a bottom feeder.
Speaker 2A lot of people are stuck in their careers to always work with small cases, attorneys who aren't well known, never getting a lot of word of mouth because of where they do it, and it really does take. We talked about marketing and sales. As mr quinley stated way at the beginning of this of this podcast, there is a point in time that you have to sell yourself if you're young, and it has to be done in a way of authenticity of who you really are it's. I would like to tell you that nowadays, nobody looks at a newsletter. Nobody looks at email. The only way that you are going to get referrals is by word of mouth. Maybe if you teach somewhere.
Speaker 2I don't think there's anything wrong with being assertive and aggressive. And if there's a local organization of attorneys, you know whether it's a local, your city bar group. They meet for lunch every month or whatever it is. If at the beginning of your career, be willing to do that, you meet a lot of people, you learn a lot, you develop poise and expertise. But it is difficult and you have to make sure that over your career that you're moving up and you're not moving sideways.
Working with Trial Teams Effectively
Speaker 3And I think the way to get those word of mouth referrals is essentially doing a kick ass job. That's right. On those initial and subsequent cases, what do I mean by that? I mean that you're analytically thorough and impartial in looking at the case. That you meet every deadline without being a drama king or queen. That you provide as immaculate a written work product, bulletproofed and vetted as you can if it's a full 26 report or a disclosure in state court. That you are prepared or over-prepared for that deposition and in the unlikely event because I say one out of 10 of my cases actually go to trial that you're likewise for trial. So it's such a kick-ass job that when that case is over, whether they prevail or not, whether they settle the case or not, they say to themselves and to colleagues this guy or this lady is the real deal. And so you don't do that by handing out cards at a train car. There's a role for that the thoroughness of your report, your rapport, your soft skills, your testimonial preparation and performance within those highly stylized forums.
Speaker 3I call it a performance art. I think giving testimony and trial are very related but not quite identical performance arts. And the more you do it, hopefully the more comfortable you become and the better you become. Always have a growth mindset of improving upon the last. I look at reports and testimony that I gave 10 years ago. It's cringeworthy now I look back on it because at the time I was relatively green. That's not to say I'm at some exalted stage right now. The point is it's an iterative process. You're learning and you're trying to improve each time.
Speaker 2You know you're very articulate in what you say and I agree with everything that you share, and they're words. You have to practice them, them, but you practice them by understanding the absolute importance of what we're doing in this field. And what we're doing is we're keeping alive our judicial system, which is what makes us a democracy, it's what makes us a civilized society, and the judicial system is the basis of everything. And when we and it's for me, it's the basis of someone's life, for you maybe, mr Quindley, it's more financial. You know, what you're doing has to do with more keeping business appropriate and people getting the right, whether it's a business or a person getting the right outcome, whatever it is. We have a real responsibility to do what we do, and a forensic expert has to understand that. I think that's part of what we, as we mentor our colleagues, and we're at the point that we do mentor. I think that's important.
Speaker 2But as a personal story and about, I think, what this gentleman's sharing is that about six months ago I got a call from an attorney and I barely recognized his name. I kind of knew he was local and he had been on the other side of a case that I was on and once he told me that I realized who he was and I said well, why are you calling me? He says because they lost big time. He says because you're the best person I've ever known. He goes I want to hire you for my case on this side. So he was able to get over in quotes losing, knowing that I had the qualifications and the ability to make the other side be more successful and that's the ultimate compliment I would say.
Speaker 3When you have an opposing counsel on a former case reaches out to you because of how impressed he or she was with your performance, that is the ultimate compliment, I think.
Speaker 2It is. It is. I certainly took it that way, and so I think what we're saying here is that this is being an expert witness is not just easy job. That is a job that has enormous responsibility, and attorneys have the obligation to choose and work with the right person and we, as experts, have an opportunity. We have an obligation. That's the same is to choose and work with the right people and to do justice where it's served and to be thorough and honest and independent. And those are difficult things to do because we're all faced with money and wanting to win and pressures, but the more that we resist those, I believe, the better it is for everybody. It is for everybody.
Speaker 3That's a great articulation of the big picture role, I think, of expert witnesses. I don't think I've ever heard it expressed better and that you know we do have a positive role and not get hung up on winning or losing. You know I've written about this, I've talked about this with fellow experts. I've been on the losing side. It's always more fun to be on the winning team. Of course, the end result. I'm focused on the process, my process, my process of preparation and my process of testifying to do the best job. I can but realize I'm a bit player in a larger drama here. It's not my case to win or lose. The fate of the case or Western civilization does not rest upon my shoulders. But I'm going to do the best job I can. Whether that helps, hurts, whether the trial is a win or a loss, I have no control over that.
Speaker 2Um, I'm going to move on one way or the other you know, I got lambasted in court last week about being emotionally involved with the defendants, not sexually, nothing inappropriate but having emotional feelings about that person. The experts, the psychological experts on the other side, were what I call formulaic. They went in and did their job. It could have been, they could be doing it to a lamppost, it didn't matter, there was no connection. Whereas I understood what this person went through, I felt I did feel sorry, I did have an emotional investment and in criminal I think in criminal and civil work you have to have an emotional investment. In death penalty work they say you need to love your client and I believe there's some truth in that, because if you don't love your client, the jury is not going to love your client.
Speaker 2But from an expert perspective, everything is not just science and it's not just scientific articles or numbers or standard deviations.
Speaker 2That person is a person, whether it's in a personal injury claim or in a criminal case, and somehow that uniqueness of that person has to be conveyed.
Speaker 2And it's very difficult, at least for me, if not impossible, not to have some feelings of empathy, for people not to be able to imagine what it's like to have lived their lives, and I do think we have to have some care and concern, even from an insurance perspective. You know, I had a case where there was a number of day schools here preschools that were being sued owned by one person because something happened at the daycare which was probably out of the owner's you know sense of it's liability because they own it but they didn't cause this to happen. And when you really look at that case, whether from a defense perspective, especially for our plaintiff perspective, these people who worked their whole lives to build this business are going to lose that business and there's responsibility there to tell the truth. There's responsibility there to try to try to engage the judicial system to come out with a fair outcome, because these are people's lives and most things that we deal with as experts do affect people, whether it's even through a business, in one way or another.
Speaker 1Absolutely. Before we wind up, I do want to address our post-trial or post-engagement practices. Sometimes expert witnesses only have their own one shining moment, their one day in court, long before a case finishes. But is there anything that you do after a case to see whether or not it went to settlement, to see who won? Do you contact the attorney and ask how your performance was? What do you do after an engagement?
Speaker 2Good question. Most of the times I don't know Mr Quinley's experience. Many attorneys, even if they get along well with you, they don't tell you what happens at the end. They don't call you up and say, hey, we got a good settlement or this is what happened. You just never hear from them. Many times I'm curious and I'll call. And the reason I'm curious is I want to know if anything I did hurt or helped the case. I want to learn from it. Obviously I'm concerned and interested in what happened, but I'm also interested in how they think I did, and I don't mean for complimentary purposes necessarily. I want to know what a juror thought. I want to know what they felt. So, yes, I think that follow-up is not only good for the relationship with the attorney but in terms of developing our own skills and understanding what works and what doesn't.
Speaker 1What form does that follow-up take? I don't know if it matters.
Speaker 2I guess my opinion it depends. I've called people up but people are busy. I've emailed people and said if you get a minute please call me.
Making Attorneys Better Partners
Speaker 3I think you have to calibrate that to the communication style and the realization that these are very busy people. I don't want to put them on the spot and I think that a phone call is more likely to do that than an email, where they can be reflective versus reactive. I do struggle with institutionalizing this as a discipline because it is so tempting to move on to the next case. What I try to do and recommend is a couple of things. Number one don't quote ask for feedback. People feel challenged and on the spot to ask for feedback, but if you ask them for suggestions I know it's a small phrasing, but Daniel Pink has this whole thing Don't ask for feedback. Ask people how can I improve After the case? What suggestions might you have for me to improve Either my reports, my testimony at the deposition, my trial performance. I don't need an instant answer, necessarily, but to pose those perhaps in written form and not to ask for feedback, but to ask them for that. People love to give suggestions, but feedback has a whole different connotation. Number two I think it's important to follow up to make sure that there have been no again Daubert-type exclusionary motions that were filed and ruled on. I've had cases where I've gone on my merry way and I got good vibes from retaining counsel. I found out months or years later that there was some judge's ruling who, as an aside, may have. It's never because I'm not qualified, but because some opinion that I gave they considered to be a quote, legal opinion, even though my reports say I'm not an attorney, I'm not giving legal advice. You know, and I didn't agree that that happens to be a legal opinion. But that's part of your as your kid, it's part of your permanent record as an expert. And I've been surprised in subsequent cases. Do you know that in the case of XYZ versus so-and-so in Colorado, xyz versus so-and-so in Colorado, the judge will. And because counsel hadn't told me, now I've learned to put in my engagement letter that they must inform me promptly of any Dalbert Dalbert type or exclusionary motion.
Speaker 3Now, how you enforce that between you and me, that's the difficult thing. What's going to be your sanction? The case is long gone. The cow has escaped from the barn. Okay, it's, the bell has been wrong, but still to have that? So I, if nothing else, to to for your peace of mind, or to be armed when it's thrown back in your face and your nose is shoved in it, and so I think it's important just to stay in touch. Put it on recurring diary to check in with the firm or the attorney If you've seen an article or if you've written an article as an ongoing part of your thought leadership, if you're publishing I agree, newsletters are probably overrated, but if you continue to write, if you continue to speak, if you continue to read stuff, material that you can have an excuse to check in with counsel. Put it on like a quarterly diary to check in and just to cultivate, through repetition, like water on stone, top of mind awareness on the part of the attorneys who are positioned to send you business.
Speaker 2Yeah, and always remember that they have all your transcripts from years and years ago, that they're all available and that you will be quoted on that. And it's very difficult to remember the names and facts of every case, but I was confronted from a case from 1990, let me think 93 that I was on. So this is what 93, was that 20 years ago? Easily 20 years ago to 2000.
Speaker 3I don't even know more than that 30 years it was 30 years.
Speaker 2It was no, it was no, no, it was 2000. It was 93. Yes, it was 93. So 30 years ago. And they were yelling at me why don't I remember the details? But I did remember the details. They, I looked, they handed me the Supreme Court decision, the state Supreme Court decision. I saw the name and I was able to describe the person. I knew how many people he had killed. I knew what county he was in. I didn't remember everything. I knew things like you know what problems the mom had, very generally. But they will ask you all kinds of things and it's very difficult to be consistent in every answer that you give. You know every single answer and they will pull all that stuff out. But I think what maybe we're talking about here is to have that relationship with an attorney that they are listening and know how to confront that and have looked at your life enough and your work to be able to understand what you do.
Speaker 3And to get out ahead of that I always try to cover before testimony with counsel. Look, I've written 700 plus articles over three or four decades and I don't have photographic recall of them, and my views on certain things have probably evolved over the years. Just like a doctor who's been in practice for 40 years, is he or she going to see medicine the same way as they did fresh out of med school? Or an attorney practicing? It's a good thing for those views to evolve. I was in trial in Norfolk County, massachusetts, in the summer of 2017. And the opposing counsel quoted something that I had written in the 1980s. Okay, so then that's fair game, because when I was doing all of this writing, I had no grand design to be ever an expert witness.
Speaker 3Not that it would have changed things, but it was that kind of visibility that propelled me to a level of visibility where firms and attorneys unsolicited started contacting me to serve as an expert witness. All of which is to say, look, I can't guarantee that they can't find something in that haystack of material to try to use to impeach me, or the book looking at how long ago it was and whether your thinking has evolved and whether the circumstances you know would apply in the current case. That's all fair game, as is former testimony, but I try to preempt that and say, look, they may dredge up some stuff. I can't say that they won't, but we'll just have to deal with it.
Career Development for Expert Witnesses
Speaker 1It has been an absolute informative and elucidating experience having this panel with both of you. Before we wrap up, do you have any last advice for expert witnesses, in particular newer expert witnesses or attorneys working with experts?
Speaker 2It's a very difficult area to break into because everybody wants to do it or believes that they can do it. I can't speak for you know, insurance issues or whatever, but obviously having a career prior to doing this is important. To jump into forensic work as a youth right out of school is very difficult to do and I've testified against people that have two years out, three years out and they do not have the breadth of experience. So my guess would be in my professional, my limited profession, is working somewhere first is very important, whether it's a prison setting or in a private practice, whatever that might be.
Speaker 2It's very difficult to jump into and I believe that my word of warning would be if you jump into this too early, you're going to make some serious mistakes. That it's an expert witness testimony is a responsibility and it's a complex responsibility. And if you really want to get into it, I believe into mentoring. You could be mentored by someone. You could do parts of other people's cases. You could do part of their research. You can do a lot of different things, but if you think you're going to be a TV star at age 27, that's probably not going to happen.
Speaker 3I totally agree, and it's sort of a chicken and egg situation, because to get the experience you got to get the case, and to get the case, people are looking for experience. But what I would say is technical mastery of your subject matter domain is not enough. Those are table stakes. To be effective, you need a blend of hard skills that's where the technical expertise comes in and soft skills in terms of communication, diplomacy and emotional intelligence. Let me put it this way there are people who I think have vastly greater knowledge of insurance and insurance claims than me, but they are not cut out. Maybe they dipped their toes in that water at one time, but they have no appetite for the rough and tumble of the litigation system, the adversarial system.
Speaker 3You've got to have a thick skin because you're working with very smart people. That's a non-financial benefit of the job. The flip side is you've got extremely smart people on the other side who are preparing for weeks to make you look uninformed, inconsistent and incompetent, and not everyone has the appetite or tolerance for that. The table stakes are having the credentials, having the years of experience, maybe a few gray hairs, that the publishing, the speaking, the chops, the bona fides, the availability. But to know that this is a very stylized kind of writing, it's a certain performance art when it comes to testifying, and that you know if you've got a big ego or if you're thin skinned and can't work under stress, can't work under deadline, can't work with sometimes some very quirky people, you know, but they're paying your bills. You've got to have a tolerance for all of that.
Speaker 2That maybe where the emotional quotient, the eq, comes in absolutely agree with that and I think you state that incredibly articulately, because this is not a regular job and it's not regular demands, and it is. It had. It's a. It stresses your moral life, your cognitive life, your emotional life, your personal life. Your emotional life, your personal life, your time.
Speaker 2This is not just being famous and getting up on the stand. It's serious, and I think that all the things we talked about today about the relationships I mean Noah started this off talking about relationships it is a relationship base. It's also a relationship with a jury. I mean we haven't talked about that, but the bottom line is that you have to be able to establish a relationship with a jury. You have to know how to communicate in a way that other people can understand, and that's the emotional skills, because a lot of people get up on there with technical slides and all kinds of numbers and standard deviations and Lord knows what, and what they really want to know is this was unfair. Here's the six reasons why. So you know, we have to really think about our audience as well Our audience, our lawyers and everybody else. Thank you.
Speaker 1Noah, absolutely. Dr Brahms, mr Quinley, thank you so much for joining me today, for today's panel.
Speaker 2Thank, you very much.
Speaker 1Thank you all. As always, thank you to our listeners for joining us for another episode of Engaging Experts.
Speaker 2Cheers. Thank you for listening to our podcast of Engaging Experts. Cheers. Thank you for listening to our podcast, engaging Experts. Our show notes are available on our website roundtablegroupcom.