She Married Her Uncle. Then Killed Him.

You can feel it before the first question is even finished: the witness is about to lie. The problem is not whether you can prove it. The problem is when you should prove it. We talk through real deposition strategy and trial lawyer decision-making for dealing with false statements in sworn testimony, including the risk of confronting a lie too early and watching it get “fixed” the moment opposing counsel calls a break. 

From police reports signed under penalty of perjury to high-stakes civil cases where self-preservation is the motive, we explain how we build a clean foundation, lock in testimony, and then decide whether the best impeachment moment belongs at trial in front of a jury. We also get into the mechanics of questioning liars without getting hypnotized by theater: drilling into time, place, sensory details, and sequence, and recognizing how made-up stories often lack the texture of real memory. 

We shift to expert witnesses and the credibility landmines that come with them, from exaggerated credentials to omissions that can blow up an entire opinion. And we tackle a classic modern fact pattern: traffic camera footage contradicting a “green light” story, plus how false memory can be used to soften what still functions like a lie. We close with a blunt truth from our own practice: plaintiffs have to be honest with us, or the case is over. If this helped you think differently about deposition prep, cross-examination, and witness credibility, subscribe, share the episode with a lawyer friend, and leave a review. What’s your rule for when to confront a lie?

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Hosted by Karen Koehler and Mo Hamoudi, trial lawyers at Stritmatter Law, a nationally recognized plaintiff's personal injury and civil rights law firm based in Washington State.

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Mo Hamoudi
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https://www.linkedin.com/in/mo-hamoudi-77a38733/

Stritmatter Law
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Transcript

Lying Under Oath Sets The Stakes

Karen Koehler 0:06

Liar, liar pants on fire.

Mo Hamoudi 0:08

Okay. Some people lie in depositions. The good ones do it really well. In trial too. In trial too, but the bad ones get caught. So we want to do a topic on liars and depositions.

Karen Koehler 0:22

And trial.

Mo Hamoudi 0:23

And trial.

Karen Koehler 0:24

Everywhere.

Mo Hamoudi 0:24

Everywhere. All right. I think the way we start this is that talk to us a little bit about knowing you're going

The Trap Of Confronting Too Early

Mo Hamoudi 0:32

into a deposition where you know that the person's already lied. Like in a document or in a report, and you know it's a lie. And you're going to be able to prove it. How do you go about dealing with that?

Karen Koehler 0:46

You tell us.

Mo Hamoudi 0:46

Well, no, I okay. You tell us. I mean, the classic one is a police report. Um, you know, if you have a police witness, because they have to file reports as part of their jobs. And what they do is that every police department requires you, when you sign a um uh police report, to say that you're doing it under penalty of perjury.

Mike Todd 1:06

So it's like uh it's like a That's the first line of defense of uh of you getting in trouble if you lie.

Mo Hamoudi 1:12

Yeah, that's the first line of defense. They're required to tell the truth. And um so the way I approach it is is that um I don't come out of the gates and go, read that, and you're, you know, there's no like Perry Mason moment. Um laying the foundation about everything that the police officer did that day, how they showed up, little menial facts. And then you you put the report in front of them and you get them to double down now in a deposition under oath, that yeah, that's that's the truth, right? But my decision is not to confront them about that in a deposition. Because um, in a deposition, and I've had this happen with police officers, when you confront them about it and say, hey, that's a lie, the attorney can say, I would like to take a break at this time. And you don't get to know what the attorney or the police officer is talking to the to him about it, and they talk, and he comes back and he says later, and I've had this happen, hey, I want to correct my testimony. I made a mistake. You know, it's an honest one. So the the the weight of it, the weight of like the the lie is completely lost. So you you now have that him doubling down twice on it, and I think that if it's a significant enough lie, you wait for that and you go to trial, and you need that in front of the jury. You need him, you need the jury to see him be confronted with the lie and how he immediately reacts to it. That's the value of dealing with it in that situation. But that's that's the police situation. What about situations that you're familiar with?

Karen Koehler 2:57

Well, I'm familiar with that situation, but there are so and we'll do depositions first.

Mo Hamoudi 3:02

Okay.

Karen Koehler 3:03

There are so many liars, and there's so many different ways of lying,

What Counts As A Lie

Karen Koehler 3:07

and it's still the minority. I think that most people tell the truth.

Mo Hamoudi 3:13

Yes.

Karen Koehler 3:14

Uh, but there are liars. Um or when you get to the critical fact, people are willing to bend the truth because they want to come across. Well, you know, there's many reasons for lying, as there are liars, right? Maybe they just don't want to get in trouble. Maybe they don't want to have a money judgment entered against them. Maybe they, you know, didn't tell their spouse that they were doing something.

Mo Hamoudi 3:41

Is lying a too strong a word?

Karen Koehler 3:43

No.

Mo Hamoudi 3:44

Is you know, like it suggests like some ill motive.

Karen Koehler 3:48

No, it doesn't. A lie is just not telling the truth.

Mo Hamoudi 3:50

Okay, all right. Making sure that's okay.

Karen Koehler 3:53

Intentionally not telling the truth. Not like mistakenly.

Mo Hamoudi 3:57

Okay, so a mistake and failure to tell the truth, is that a lie?

Karen Koehler 4:00

No, that's a mistake and failure to that's just being confused and not thinking, not taking your time and not thinking.

Mo Hamoudi 4:08

All right, keep going.

Karen Koehler 4:09

A lie is more intentional.

Mo Hamoudi 4:11

Okay, okay.

Karen Koehler 4:12

It's willful.

Mo Hamoudi 4:13

Okay.

Karen Koehler 4:14

So that's what we're talking about today. Right. All right. Are the liar liars.

Mo Hamoudi 4:17

Liar liars. Pants on fires. Pants on fires.

Karen Koehler 4:19

So um just even identifying, like you said, are they gonna lie? Aren't they gonna lie? Sometimes you can figure it out ahead of time. And there's if there's a collision, you know, that's one of the common ones. Like you said, it's in the police report.

Mo Hamoudi 4:35

Yeah.

Karen Koehler 4:36

So you're looking at what they're saying, you're looking at actually what happened. Nowadays we have cameras.

Mo Hamoudi 4:41

Yeah.

Karen Koehler 4:42

That has changed everything.

Mo Hamoudi 4:44

Yeah.

Karen Koehler 4:44

So uh sometimes they give those statements before they've seen the camera and it's completely contradictory. And maybe they'll just change their testimony and say, Well, I didn't know, which often happens, right? Because they're not really trying to lie. Yeah. That's not what we're talking about. We're talking about people that are actually lying, like the bad bad lies. Yeah. We're talking about bad lies.

Mike Todd 5:05

You're talking about bad lies too. That's what I was gonna say. It's like you're not talking about this person saying, you know, oh, they don't chew gum normally. You're talking about they intentionally did something, and I'm intentionally trying to divert you from what the truth is. Correct. Material lies.

Karen Koehler 5:25

Yes. So my uh my best example of this case is

Walking Into A Known Liar Deposition

Karen Koehler 5:30

the McNamara wrongful murder trial in uh Grant County. Oh yeah. So in that case, as we alleged, that the niece's wife uh it's always fun to describe that situation. Denise wife, which wasn't a funny situation because she killed him, according to the jury.

Mike Todd 5:53

Um killed her uncle husband.

Karen Koehler 5:55

Killed her uncle husband um in Belize. But that wrongful murder trial was full of her lying. Like I knew in deposition she was gonna lie, I knew in trial she was gonna lie, and she was represented by John Henry Brown. So that was gonna be even more chaotic lying involved. So you go into something like that when you know they're gonna lie, and you just gird up. I mean, first of all, second of all, who are you as a lawyer? And what do you want out of that? Right? You're looking at two things. One settle, you know, maybe this will help settle your case, which I'm almost never looking at. Um, or you're looking at how do I avoid summary judgment because they're gonna lie and they're and then they're and then my client's dead, and so they could probably win if they're lying. How can I protect against that? Right? So you have to create, you have to and then the third thing, of course, is I want to kick their butt in trial.

Mo Hamoudi 6:59

Yeah.

Karen Koehler 6:59

Um, how am I gonna lay the foundation for that? So I'm gonna I'm gonna go back and tell you the story. So deposition is happening. This is pre-COVID, and he is living in a condo downtown, across from the courthouse, kind of down, and the deposition He is. Who is her husband, her husband, her, her non-hus, her, her attorney at the time. J HB Alcalm. And that's where the deposition is held, is in the conference room at the very top. Did you help set that up, Mike?

Mike Todd 7:35

Oh, yeah, I was there.

Karen Koehler 7:37

The conference room.

Mike Todd 7:38

No, I remember this situation very clearly.

Karen Koehler 7:40

Tell me, tell me how you set it up.

Mike Todd 7:41

We walk into the room, it's windows on three walls of the thing, like floor-to-ceiling windows. So he wants us to set up the camera who's gonna be filming the witness against the sun, basically shining in. So I'm like, this isn't gonna work. And uh he's like, okay, he's got donuts out and he's acting all gregarious and happy, like, hey, how's it going? So glad to see you. And I'm like, okay, this guy's freaking this is the first time I've met him. So I didn't really, I had never met him in person, but I had heard about him because I mean he had defended the Wa Me case, and I remember all of that very clearly.

Karen Koehler 8:26

Yeah.

Mike Todd 8:27

Um, and uh yeah, he was he he was all like isn't this a great location for a deposition? Like, isn't this awesome up here, you know? And I'm like, what why does any of that matter, man?

Karen Koehler 8:41

He's weird.

Mike Todd 8:42

We're just here to get a specific thing, not this whole dog and pony show you got going on. Yeah.

Karen Koehler 8:48

So so he's this Mr. Gregarious, and he's quite tall.

Mike Todd 8:52

Oh, yeah.

Karen Koehler 8:53

And uh Mr. Gregarious, and we sit down, and his client comes in and sits down, and that's the first time I'm able to look at her, and I look in her eyes, and she looks back at me, and then it was just a full-on war. From that moment on. I just looked in those, she's very beautiful, dead eye.

Mike Todd 9:17

Yeah, but she's got dead eyes, she has shark eyes, man.

Karen Koehler 9:20

And and uh and it was full-on war. And so you can cut you need to come prepared. Obviously, you read everything, which you know, there's not a lot to read when it happened in Belize and you left the country, and and there's not the great greatest investigation that was done down there. I mean, you know, they did what they could and they wanted her to come back and she wouldn't. And you know, there's all this stuff, and the allegations, of course, are absolutely you know, they made a movie out of this.

Mike Todd 9:51

Oh, yeah, no, it was it was crazy.

Karen Koehler 9:53

Yeah, it's called Forbidden Love or something like that.

Mike Todd 9:56

Well, that and there were multiple uh, you know, like reality crime shows that have reported on it.

Karen Koehler 10:03

Yes, it was a it was quite the phenomenal thing, and and so you have to when you have someone like that, I engage. And that is unusual. Um, I think for some females

Using Micro Details To Break Stories

Karen Koehler 10:23

to understand that a female is gonna engage with them like that. She was used to engaging with men and having them do whatever she wanted. Like she is.

Mike Todd 10:31

Well, that was her thing. She she liked to control everything.

Karen Koehler 10:34

Yes, and including her lawyer.

Mike Todd 10:36

Yes, which she was very good at.

Karen Koehler 10:38

Yes. And and then here and go bang, bang, bang. And so she would they give an answer, and you just never let that answer stay. Then you want to know, well, that you know, what was what color was this, and where was this? And you go to all these little teeny micro details. That's what I do, because we're testing memory, and a liar will mix things up. A liar will have multiple different stories.

Mike Todd 11:06

Yeah, because they have the truth and then they have the truth that they've created, and then they have little other lies that they've used to work different angles, and eventually they forget some.

Karen Koehler 11:18

Yeah. Like eventually, when this is gonna get the trial, and we can talk about later, it'll turn out that she told people so many different stories of what happened. Uh, but here it's like, could you smell anything? No. Could you see anything? No. You know, what were you doing? Every single thing about that. And what did you do? Did you go and uh get help right away? No, I laid down and spooned him. Yeah. Uh, but you don't see the blood coming out of his head, you don't smell it, it doesn't, you know, you don't feel it all over you.

Mike Todd 11:51

There's no cold.

Karen Koehler 11:54

Yeah. So I'm I'm I'm looking at um, I'm looking at smell.

Mike Todd 12:00

You're looking at you're looking at facts that a normal person might be able to remember when asked, and a person that's lying won't have thought of anything to create for.

Karen Koehler 12:09

The details. They will have this factual chain, but they can't visualize it because they just made it up.

Mike Todd 12:16

Because it was never real.

Karen Koehler 12:17

Yeah. So I'm looking for that. And and that is something that time and a time, again, is a commonality for me when talking to someone who's really making something out, their explanations don't ring true. You can't feel them. They're not, they're not in a, you know, I'm a human, I'm the human-focused person, right? Looking at how a jury's gonna see that, you don't, you don't get it. Like it's not, it could sound logical.

Mike Todd 12:46

Well, and people I think people that feel empathetically, they don't feel things from people that lie because it's not real.

Karen Koehler 12:56

You know, there's a whole lot of stuff about, well, you can tell they're lying if they look up to the left and if they do that. And and there's probably some truth to that. What I notice when somebody is lying, because I'm a super observant person, is it's even when people are telling the truth, I'm looking at the micro. I'm always looking at those little micro things. And we don't even notice it unless you're really studying it. Like what's moving, what's clenching, is there perspiration, where the eye is going, um, what's the speech patterns, what are their legs doing? How are they leaning? Like all this little stuff, and as the day is going on, you're still watching all that and figure and watching all this unfold of oh, you know, so I think well.

Mo Hamoudi 13:49

Well, I mean,

Mannerisms Versus Hard Facts

Mo Hamoudi 13:50

kind of what I think is you're kind of talking about the psychology of a lawyer.

Karen Koehler 13:54

But that's how you question them.

Mo Hamoudi 13:56

Yeah, you yeah, and and and I think that it's effective to be talking to the person about facts and circumstances around the lie rather than the lie itself. So um you're asking them, yeah, well, what time was it? Who was there? What were you doing? How did you end up in that situation? Um, the mannerism stuff, I'm a little bit cautious of because you know, I've represented people who confess to crimes.

Karen Koehler 14:26

It's all that were hard. That did not happen.

Mo Hamoudi 14:28

Well, they can fake it. That's the thing. Yeah. And so it'd be the opposite. Yeah, I've, you know, these are people who have confessed to a crime they never committed because the person asking them a question was relying heavily on the psychology of their actions and being, well, why isn't this person crying? And anybody would cry if a loved one died. Anybody would show emotion. Why are they keep looking up and down? Um, I think that like that stuff is just it's it's hard to read. But um this is, I think it gets a little bit harder. It looks like the person you were deposing was clearly a liar because they had killed their husband. They've been found by a jury to have killed their husband. Not a jury, no.

Karen Koehler 15:09

Not at that time.

Mo Hamoudi 15:10

No, by jury?

Karen Koehler 15:11

Not at that time.

Mo Hamoudi 15:11

Not at that time. Not at that time. Okay. Later. Later. They they were they had been found later to have killed their husband. And so I guess the By my jury. By your jury. By your jury.

Karen Koehler 15:21

But before they went in there, they could not be she could not be prosecuted criminally in the United States because she killed him in Belize.

Mike Todd 15:27

Yeah, I see. And so she would and she wouldn't go back to Belize so they couldn't prosecute the criminal. And the U.S.

Karen Koehler 15:32

had never extradited someone from Belize to this day.

Mo Hamoudi 15:35

Yeah. Extradited somebody to Belize, not from Belize. To hear from Belize.

Karen Koehler 15:40

No. Oh, yeah.

Mo Hamoudi 15:43

Send somebody back.

Karen Koehler 15:44

Yes. Okay. The B.S. has not ever done that.

Mo Hamoudi 15:46

Okay, so so you knew so you're in like a kind of like a situation where this person, you know, this person's motive to lie. If they're gonna lie, who the hell would confess to having killed somebody, right? So like that's like a huge motivator, like self-preservation motivator. I am not going to tell you the truth. And how obvious was it in your situation? Like, how obvious was that motive, like to self-preserve? Like, was it so apparent? Like, was the evidence so clear?

Karen Koehler 16:18

She went out, set her sights on her uncle.

Mo Hamoudi 16:21

Yeah.

Karen Koehler 16:22

And within, you know, a matter of months, he had signed over every single thing that he had to her, including the family farm of generations, his social security, his bank accounts were double. He had bought a new truck, he bought her, you know, he'd paid for her. Um, it was just, it was really awesome.

Mike Todd 16:39

Then they moved, then he paid for them to move to Belize and set up a Ben Breakfast there.

Karen Koehler 16:46

Ben and Breakfast. Yeah. So, and he had life insurance. And he had life insurance. Which he signed over to her and said he had disinherited his his adult children. So she saw she that her motive was incredible.

Mo Hamoudi 16:59

Why did she ever testify? Why didn't she plead the fifth? I mean, if there was stuff that happened in the United States that she did before the United States.

Karen Koehler 17:10

She was represented by a genius named JHB.

Mo Hamoudi 17:13

I would have knew that he she was gonna get off. Well, because what's crazy is that she can't be prosecuted. Well, that's not necessarily true because that she was she was represented by a genius, and that's what that's not necessarily true because if if some of the acts, if some of the acts of getting the asset assignment had occurred in the United States. They all had, I think. Okay, and then the motive to kill, the intent to kill, was developed in the United States, but the act was committed outside the United States. She had been in I don't know that you could prove that because she had been in Belize for a while before it happened. Before it happened. Okay, that's tough. I don't know. Modern day, I think it maybe may be a little bit different.

Karen Koehler 17:54

FBI watched her probably in I don't know that they ever officially close it, but yeah, I mean I talked to them multiple times. They talk to the clients. I mean, they talked to her.

Mo Hamoudi 18:03

But what about the harder situations? That to me is just like the self-preservation motive to lie there is so high that like a person who's watching that, they're gonna be like, well, obviously she's gonna lie. She's not gonna admit to anything that gets minutely close to like, yeah, I killed him because of this stuff. So, but what about like the liars? Like, I don't know, how many experts you've deposted,

Expert Witness Lies That Explode

Mo Hamoudi 18:27

thousands. And experts who lie about, you know, their credentials. Have you ever had that situation, like where expert says, oh yeah, I'm the I went to college so-and-so, but I'm an expert so-and-so. I've had an expert like this. This expert heralded himself, heralded. And this was the biggest fire pant lie. I mean, a pants on the fire lie. That um he said, um, I'm the I'm I went to all these colleges and I'm I'm so uh special and I'm so great, but he didn't know, he didn't know the digging I did, I found out he had a felony conviction. Okay, and and the reason I found out this is because he was such a self-pontificator. Like loves to talk about himself. He'd given a speech that they had recorded, and in the speech he says, Oh, when I was a wee young man, I was convicted of a felony, but they never disclosed it to us. It wasn't a big deal, but when he was on the stand, my co-counsel said, Hey, you know, you will, you know, this, but you're a felon. And like literally the whole courtroom went, What? And the other side didn't know it. That had spent hundreds of thousands of dollars on this guy. And like the guy's sitting there, and he goes, Excuse me? What and then it was the most beautiful moment unraveled on the stand. How dare you! That was when I was blah, blah, blah, blah, blah. And I have redeemed. And he's like, Yeah, but why didn't you tell us this? Why would you not disclose it? It was the most well-executed, it was, you know, it wasn't there was a good, legitimate explanation for it.

Karen Koehler 20:16

Well, here's the here's the issue here legally is that it's not probably even relevant. No, but once you don't, once you lie about something, it goes to your credibility.

Mo Hamoudi 20:26

Yeah, yeah.

Karen Koehler 20:26

It becomes fair game. So when you lie about something, it can really hurt you, just like that guy. Like that wasn't relevant.

Mike Todd 20:33

No, it was like it was like a burglary. He could have even you could have even played that off as something that you forgot about, except for the fact that he mentioned it in a speech. In a speech. But but my point is, he if he had said, if he had admitted it ahead of time, he would have had a defense for it. Because he didn't, yeah. The defense doesn't work. That makes you look more like a liar at that point. Yeah. You're going, I didn't do it, I didn't do it.

Mo Hamoudi 20:57

No, and and so I just thought like at that point, everything he had just talked about was called into question. And and so, and so we didn't we didn't even ask him any real cross questions. All we went up was was like, yeah, you you have you seem like a very accomplished person. You've talked about your experience, you've done so many fantastic things. You're a felon. And then we sat down after this little exchange, and it was like, what do you do with that? Like, because the other side didn't even know about it. They didn't have a prep. Yeah, they don't have any cross to go back and say, hey, let's talk about the nature and they didn't want to even get into it. So like the whole thing just like ended with that. And the guy's like, so don't don't don't I think that's that's that's a fun one.

Karen Koehler 21:46

Dorothy Clay Sims made a career out of dismantling experts. She would um you would tell her who the experts were, and then she had a team, and they would go get their education records. Do you know how many experts lie about their educational career?

Mike Todd 22:02

I'm sure. Oh, that's oh wow, I'm sure it's extremely. common because it's shocking because it's just become common with everybody.

Karen Koehler 22:09

It's shocking. And or she would go and and and also get their transcripts. And like they would, I mean the amount of tests that were flunked or their their class standing. And they're making you know millions of dollars a year being experts. But she she became quite quite known for that. And and um I've sent her several experts. She never found me anything that horrible um but yeah.

Mo Hamoudi 22:36

But that's that's a everybody lies. But that's a really good you know because like think about it.

Karen Koehler 22:40

When I say everybody I mean all classes of of women I would say everyone.

Mike Todd 22:45

That's everyone lies to some extent. Everyone lies. Not like malicious lies

Traffic Cameras And Convenient Memories

Mike Todd 22:50

but everybody does white lies I think for sure.

Mo Hamoudi 22:53

Well we're not and we're not talking about white lies but we're yes no but we're talking about lies are like context specific where you are why you're lying and what are the consequences of the lie.

Karen Koehler 23:04

Here's an easy lie right this is a common lie just did in a in a case you're going through an intersection and there's a T-bone collision right and and it's like who had the you know did you go through the green light the yellow light or the red light and the let's say the plaintiff doesn't even know they're like they they they have a head injury so they they can't even tell you. Yeah right they can't tell you um but that that uh defendant is gonna say oh I absolutely had the green light right and then you're gonna get the traffic cam and it's gonna show well it was yellow turning to red when they went in there now they will have been prepped before their deposition.

Mike Todd 23:53

Yeah about that of how to figure out how to lie appropriately they told the cop it was green it's yellow going to red and they don't want to say they don't want to get they don't want to be found to be a liar for saying it was green because in their mind that's what they saw thought officer or excuse me you know plaintiff's lawyer I uh uh the light was green I I might have looked away at the last second is that a lie no it's a lie but they're not gonna be able to catch them very easily in that but what are they gonna do when I say well here's the camera footage I I that's not the way that I remember it I'm sorry oh that's that's see that's pretty good that's pretty good Mike Mike they can't see the facial stuff I did but yeah yeah this is why you're off camera that's true yeah well you know that the that's like the trauma of an accident you start to build a memory right a false memory a lot of the time yeah but that's that's a harder one I mean that's the game that you make it seem like a false memory then the jury thinks it's not a lie but it's a lie and they're doing it maliciously in my opinion.

Mo Hamoudi 25:08

But I think that the false memory aspect then you go okay it's not a lie but it's a false memory. But that again I think has a domino effect on the other stuff that they're saying is that oh this person has the capacity to make errors about what they see and what they hear and what they experience. We got to really scrutinize what they said about what happened. I think that pointing it out is necessary framing it to the jury in an argument I think is a little bit different. You can't oversell be like oh this person was maliciously lying I mean like maybe they just well let's end this by talking about you know plaintiffs not are not immune from this.

Karen Koehler 25:46

Oh no and so but this is what we tell plaintiff this is the clear instruction

When Plaintiffs Lie The Case Dies

Karen Koehler 25:51

and consistent tell us everything even things that you don't think are important if we know then we can help do not lie to us if you lie to us or anything you know game over because just like the expert there even if it's not relevant if you're inconsistent if the let alone a lie right now there are there are often inconsistencies because life is life that's just life but to have a plaintiff that would actually lie I would fire them if I found out that they were lying I would fire them.

Mike Todd 26:33

Don't you think also that if they lie to you it's you're creating a strategy when when you're going into this situation if they've lied to you it's screwing up your strategy.

Mo Hamoudi 26:46

I think it does even worse not just strategy a relationship.

Karen Koehler 26:50

Well yeah for sure that's why you're firing them that's why we because we don't trust them and and and you know this is a yeah it's a bit it's a business relationship. We're investing in that client and we're not gonna do it if they're liar. So so many people that think oh there's so many frivolous lawsuits and plaintiffs are liars like sometimes it's because the the plaintiff themselves have caused that yeah but you know for a k firm like ours handling big cases we are not gonna and you there's so many ways you can find out if someone's lying because the inconsistencies will become known you are looking at all this stuff from all these different resources and records and going back from their from the beginning of their lifetime.

Mike Todd 27:29

Well that's the thing like people might want to lie about some of that stuff. You know you you people are embarrassed about things. We've talked about that before all the sex stuff or drug stuff or whatever.

Karen Koehler 27:39

Yeah you know nobody wants to admit that no I mean oh my god I've had people admit that they were having affairs I've had people admitting you know just and and the way that we say it that I say it to them is what is the thing that you would be the most worried about the defense finding out about you. Yeah you need to tell me that and everything else in between and they know I mean our clients know like all we want to do is help them um but there's some people that you know want you because you can help them and maybe they're not gonna be frank with you it's not someone that we can keep. If the soon as you find something like that out even if you're midway through a case then it's it's done.

Mo Hamoudi 28:33

By the way we could do the next step the next uh uh topic should be about

Closing Thoughts And Next Topic Tease

Mo Hamoudi 28:39

people with complicated past and like do they have the right to seek justice all right okay yeah