Last time, we set the table with special-education attorney Tim Adams to discuss the big 9th Circuit win for parents of kids with IEPs (individualized education protocols). Now we dig in to Irvine Unified School District v. Landers and Gagliano.
After covering the fact that the school district, to get out of helping a dyslexic student get the help she needed, spent over $1.13 million on its attorneys in over five-years of litigation involving a “trial by experts.” In this discussion, Tim Adams explains that IEPs are a constitutional right, so school districts are not legally permitted to consider their costs. Yet school district spokespersons take to the press to decry how these lawsuits are breaking the bank. So what is going on here?
Tim Adams’ biography.
Appellate Specialist Jeff Lewis' biography, LinkedIn profile, and Twitter feed.
Appellate Specialist Tim Kowal's biography, LinkedIn profile, Twitter feed, and YouTube page.
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The California Appellate Law Podcast thanks Casetext for sponsoring the podcast. Listeners receive a discount on Casetext Basic Research at casetext.com/CALP. The co-hosts, Jeff and Tim, were also invited to try Casetext’s newest technology, CoCounsel, the world’s first AI legal assistant. You can discover CoCounsel for yourself with a demo and free trial at casetext.com/CoCounsel.
Announcer 0:03
Welcome to the California appellate podcast, a discussion of timely trial tips and the latest cases and news coming from the California Court of Appeal and the California Supreme Court. And now your hosts, Tim Kowal and Jeff Lewis, welcome
Jeff Lewis 0:17
everyone.
Tim Kowal 0:17
Well, you're supposed to say you're Jeff Lewis and I'm the nice I'm Tim kowal. Come on, Jeff, you gotta follow the script here. And then I say, I think I have it memorized here. Both Jeff and I are certified appellate specialists, and as uncertified podcast co hosts, we try to bring our audience of trial and appellate attorneys some legal news and perspectives they can use in their practice. And today, we are continuing our conversation with Tim Adams special education attorney, and we are going to dive deep this time into the special into the special education case of Irvine, Unified School District versus landers and Galliano. If you didn't check out the last episode, you should do so, get caught up to speed. We spent that discussion, that part of the discussion, setting the table so that we can understand why the school district spent a million dollars, actually, more than well over a million dollars litigating this case, they spent a million dollars just on their side of the attorney's fees. That's before they have to pay. Your court ordered attorney's fees, and after your public records request where you found out that that their attorneys charged them over $1.1 million maybe you'll think about increasing your rates. But Jeff, I interrupted you for purposes of a teaser. I hope that doesn't offend our audience. But Jeff, could I ask you to put your question to Tim again, because you left off with a very trenchant question and observation, yeah, the
Jeff Lewis 1:35
$64,000 question was without revealing privileged communications and confidentiality and the information about this particular kid. Is it possible the Irvine Unified School District waged this war not because of this particular kid, but because of the cumulative impact that this kid's issue might have across the board on all the Irvine schools. They were trying to use super expensive lawyers to kind of draw a line in the sand. You know,
Tim Adams 2:01
that would make sense, Jeff, but I but it's interesting, because we, we were concurrently litigating and have over the same number of years, you know, very similar issues, asking for almost the exact same type of remedy, meaning a private program, even the exact same school and the other law firms in this district were settling all of those cases, almost all of those cases. So in fact, you know, following well within our statistic, the one I discussed in the last session, you know, you know, still same 5% are going to hearing, but most cases are, we're settling. So it really was hard to try to figure out again, this is not a precedent, legal precedent setting type of case. What I can say is that there may have been some concern from the district and possibly embarrassment that you know what they were calling accommodations over the years were actually modifications, right? So they were significantly modifying curriculum for this particular student and explaining that the modifications were, in fact, just accommodating that student. So it's just so if you're giving a student a different grade level curriculum entirely, you know they're in sixth grade and they're getting third grade curriculum where, you know, another lower grade level that's a pretty significant modification, as opposed to an accommodation. That may be extra time on a test, but it's the same grade level as as the one that they're in or sitting in the front of the class, which is also an accommodation. In fact, when I question witnesses in the in the administrative trial, they couldn't define really well the difference between the two. They were using modifications and accommodations interchangeably. Well,
Jeff Lewis 3:47
are you telling me, like similar to a DNA lab that you know botches up DNA testing and evidence testing, that I can imperil criminal prosecutions going back decades, that perhaps the school district's inability to properly categories, categorize accommodations versus modifications. There might be some landmine there in terms of past cases, absolutely,
Tim Adams 4:08
I think that that, and with this case in particular, and this is all public information, you can read this in the underlying O, H decision for this student. So we're not revealing anything privileged or confidential, but the district in particular, had conducted its own cognitive testing and had had actually made a number of errors, and it was inaccurate testing finding that the student was a well below average intelligence when they admitted to making a number of errors, and then had to retest, and the lead psychologist at Irvine unified, so it was a series of problems, I think, with this child in particular, they kind of botched, they botched the cognitive tests, and then used that as a basis to formulate an IEP that was inappropriate. And then, on top of it, couldn't really define the difference between an accommodation and amount. Modification continue and continue to tell parents that what they were, in fact, modifying was just an accommodation. So we're talking about really sophisticated parents. You know, moms, as the Wall Street Journal, acknowledged as a lawyer, is executive works for government agencies, dads in the tech business. I mean, these are pretty savvy parents, but if your school district's telling you, hey, it's just a we do this for other kids. It's just in a combination. No big deal. You know, what's the harm? You know, you may just sign that IEP and say, go ahead. But after you saw the combination of problems we ended up getting into, perhaps it's Irvine wanting to sort of redeem itself for all these embarrassing errors. I don't know. All right.
Tim Kowal 5:40
Well, let me, let's, let's remind the audience of the outlines of the case we're talking about, and then we could start coloring inside the lines here. So the case, again, is Irvine unified versus landers and Galliano, the Ninth Circuit came out with a memorandum decision in it was late last year, 2023 so as you mentioned, it's not precedential, but we're trying to figure out why the district fought so hard in this case. The case started with before an administrative law judge at the Office of Administrative Hearings. There was a 10 day hearing, basically a trial there, and the family won initially, but then the district appealed that to the District Court. The district court remanded it back to the ALJ to make some additional findings, the family won again in the ALJ. Before the ALJ, the district appealed to the district court again, and this time, the District Court affirmed and awarded fees to the parents for their attorney's fees of over $300,000 by contrast, the district had throughout the life of this case, incurred bills over 1.11 point 13 million that the district appealed both the ruling and the fee Award and the Ninth Circuit affirmed in Toto, and the basic facts of the case as I understand it, Tim is that the student was falling behind in reading. I think there was a the parents believed that there was dyslexia. She was in sixth grade, but reading at a third grade level, and apparently not on track to graduate high school. And then we were talking, you and Jeff were talking about, there is this dispute between the parents and the school about what modifications or accommodations are necessary. They couldn't come to an agreement and and tell us what happened. The parents went out and pulled the pulled the student and put it, put her in private school, I believe, and then sought reimbursement. Tell us. So that's that's my Yeah,
Tim Adams 7:46
thanks, Tim. That's a good summary. So, so we got involved in the case in 2018 and that's precisely what happened. I think what I had explained to Jeff is that it wasn't as much of a dispute as about about accommodations and a modifications, it was the district really couldn't give parents a clear definition of what they were doing and what they were whether it was an accommodation or a modification. So part of the problem is that, because of that confusion, I think that the IEP would, I mean, was tainted for a number of reasons. In addition, like I, you know, had mentioned to Jeff, and my last answer was, there was, you know, they made a number of errors in the cognitive testing. If you don't know where a student what the student's potential or ability is on on the cognitive level, it's really hard sometimes to formulate an appropriate IEP again, making the assumption that her cognitive ability is a lot lower than it really but so even when the district acknowledged those errors, you know, they couldn't really fix the years of, you know, a comp modifications, which were they were calling accommodations that had already been implemented. And by that time, by the time the parents removed, decided, hey, my my child is three years behind in reading, we need to take action and do something. You know, that's when they decided that maybe private school that specialized, private school that specialized in helping students with learning differences, including dyslexia, was the right choice. But this is after years of giving, and you asked that question in my last session, years of giving the district an opportunity and trusting that the district was going to do what was appropriate for their child, yeah,
Tim Kowal 9:27
and as we've talked about in the last session and then in our interview last last year, in January, 2023 you know, there is a large and growing number of of children with with a need for IEPs and children on the autism spectrum somewhere, somewhere between one and one in 40 to one even one in 30 children with autism, that number just keeps growing. It's an alarming rate. And so this problem of of the need for IEPs is not. Going to go away. So in the in the districts, you know, in fairness to the district, the district is probably looking down the future a bit and trying to figure out how it's going to fit within its budget to to make all these accommodations and modifications for a growing number of students and stay within its budget. So what is the, you know, that's a policy question. I guess there is a and ultimately, probably a legislative determination. Did the to the ninth circuit? Do you think, did it have any concerns about, about yielding to to the student the students need in this regard, and that there would be a floodgates problem? And well, if every, if every student and parent litigates these questions and gets everything that they're entitled to. That would be great for the students, but it's going to break the bank. Well,
Tim Adams 10:49
you know, that's not even a consideration under the under federal law that governs this area. You know, whatever the student requires to ensure that they receive an appropriate education, a program that's reasonably calculated to confer a benefits that student that's appropriately ambitious for that student, cost is not really a consideration, and that's not really something that the law allows the courts to even consider at all. And so that wouldn't, and didn't come up in any of the discussions with the panel the ninth circuit panel,
Tim Kowal 11:20
yeah. So these, these costs, maybe I didn't understand it. So the cost is not supposed to be a concern. Is that just because whatever the cost of the IEPs are that will be, the bill is going to be taken care of by the federal government? Well,
Tim Adams 11:36
unfortunately, the federal government has never fully funded. You know, the idea for states. So the state's gonna, you know, have to pick up the difference. They do get funding and, but, but, yeah, I think unfortunately for a lot of public agencies that are struggling, grappling with this, I mean, that's what, where they have to, you know, talk to the, you know, federal government, talk to Congress and figure out, how do we get more money to the states for special education? I mean, certainly we had, we saw a huge increase to cover compensatory education after covid, given the number of kids that had fallen behind. But, yeah, there isn't really enough money, generally given by the feds, enough to support many kids with IEPs, but it's not cost is not written into the law as a an IEP team consideration, in fact, the if the IEP team brings it up, that's a significant procedural violation, because they're not considering the needs of the student, but rather how cost effective the program is, so that the aim of the Law is to ensure that the student receives that appropriate education. And so whether that education is, you know, a $5,000 cost or a $50,000 cost, it really wouldn't matter under the law. It's whatever that child requires to ensure that they're meaningfully accessing that education. Yeah,
Tim Kowal 12:59
as the I recall, one of the one of the observations made in the Wall Street Journal article is that there's nearly over 46,000 formal complaints or mediation requests filed nationwide, and that was from the 2021 22 frame, and you had mentioned earlier your your Office files, I think you said a couple 100 a year, and 95% of those you said, result in in a settlement. You know, only 5% or so wind up in litigation. But the Wall Street Journal article also mentions that that number 46,500 formal complaints filed, and this is nationwide, 46,500 that number is up 27% from the prior year. Do you happen to know if that's an anomaly, or can you confirm that that number of complaints against school districts is is on the rise? Is that a trend?
Tim Adams 13:57
It is, in fact, on the rise. And I do recall in our last I would say the session that we did, initial session we did in January of 23 that we saw a significant increase in the number of filings post covid, because you've got a lot of kids that fell really far behind, and some school districts in California went virtual for up to even More than one school year, up to almost two years, students who are on virtual programs and students that require intervention one to one, and in person, they can suffer immensely by being compelled to go virtual that long. So you're gonna see a lot more filings. In fact, my prediction was we're going to see covid related Special Education litigation, or with all, as you can see, all the ups and downs that you can go in appeals for 10, at least a decade. You know, there's a two year sash limitations, but that doesn't mean your case ends right. You can keep going and, you know, depending on where the appeals go, and you. You know, the the, you know, the the chart that I sent you, the track, the appeals in this case were like a sort of a, it's almost like a tree branch. You've got the initial case and you've got, you know, different appeals going in different directions on different issues, and attorneys fees, orders are appealed, and everything else. So all that stuff takes a long time to get through on the Apollo. In
Jeff Lewis 15:23
my experience, my limited exposure to IEPs, some school districts use the meeting process, the assessment process, the documentation process, to kind of run out the shock clock. I mean, that time to do all that for any particular kid could take months. It could overlap into multiple school years. So before parents even meet a guy like you, the case could be going and so that could be another reason why these covid related cases might be delayed until parents wake up and realize maybe the school district isn't serving them well, right? So
Tim Adams 15:56
there are specific timelines, like the assessment timeline, once a parent assigns, what's called an assessment plan is 60 days, but it also the timeline tolls during off track periods, like a summer period, for example, will you'll pick up again when the school year starts? So yeah, they could go on, technically, for a number of months, and we could be waiting for a long time. Unfortunately, there was no extension on the statute of limitations, so you can't you can no longer file covid related claims. We have had a handful of cases where we usually agreed to toll the statute of limitations, and we're still litigating covid related claims because that statute of limitations was told by agreement between the parties. And we may do that in circumstances where, you know, our calendars are getting busy and both sides maybe have conflicts, and it may be difficult, unlike you know, the district court or superior court that may be amenable to allowing a continuance, you know, the Office of Administrative Hearings has very strict timelines that they have to adhere to that are enforced by the California Department of Education. And so, you know, having a due process hearing continued longer than six months is going to be a huge problem for them, and they won't let it happen, so they force you to make a decision. But you know, I think that, you know, they those cases that were filed back then, you know, I would say most, in most circumstances, those students were, you know, were significantly deprived of, you know, I had a recent decision in our my clients favor over 500 hours of compensatory education that was missed during covid. That's a, one of the largest we call compensatory education decisions we've ever seen. It's, you know, this is five, over 500 hours of tutoring that this child is owed for roughly, you know, I think it was about an 18 month time frame
Tim Kowal 17:55
going back to the to the costs. The reason, the reason, I had a question, and I was I was a little confused by your answer about what that the district, the district's analysis or discretion about issuing an IEP is not supposed to consider cost. And the reason I thought that was interesting, I went back, I was looking at the Wall Street Journal article, and I saw that there was a spokeswoman for the for the district, who who said or is reported as saying in this Wall Street Journal article that Irvine unified typically spends between half 1,000,001 million per year to reimburse families for private schools. And I thought it was interesting that the that a spokeswoman for the for the district is talking about the enormous cost that these IEPs are draining from the district, when technically, legally, the district is not allowed to consider those costs. That's correct. So there
Tim Adams 18:51
is a conflict. I mean, in reality, they do consider the costs. We know that they do, but in the context of an IEP, when you're having a discussion about the unique needs of the child. Costs cannot come up as the official reason why they've decided that a program is not appropriate for a student. It has to be based on their unique needs. But behind the scenes, they're absolutely talking about the fact that, you know, they don't want to spend 40 or $50,000 in a private school. Can they do this in house. This is something that they will discuss, but they just won't discuss it in the context of the IEP meeting. Now, the cost does come up in the context of settlement discussions. Obviously, you know, we're going to have, we can have out of IEPs, and we often do settlement discussions. And the districts, you know, if we come out the gate with a, you know, significant ask in terms of cost, the district will say, hey, that's just more money than they want to spend. And so it does come down to dollars and cents often. But as far as the official response and the reasons why a student may need or not need a program, it can never really consider cost. There are. There's, there's a, there's just a, you know, it's really focused and tailored to the students unique needs, right?
Tim Kowal 20:05
And the reason for that, I believe, originates in the California constitution. Doesn't it that the Cal doesn't the Constitution give a right to free and public education, absolutely.
Tim Adams 20:16
But again, you know, even without California law, which is helpful. And I think in many cases it is, is, you know, even more helpful than federal law. We're looking at the the idea, which is the federal law that that governs this area of practice. So that's the the statute that and that, essentially, California Education Code and regulations would mirror. But California certainly the Constitution guarantees a free education. And
Tim Kowal 20:44
if the it's just an interesting conflict, as you put it, that that they're not legally allowed to consider costs. But obviously we all know that they are considering costs, so it's a little bit of a of a perverted consideration if, well, I'm thinking about this, but I'm not gonna let you know that I'm thinking about this, or I'm not gonna say it out loud. Well,
Tim Adams 21:05
Tim, the irony though, is, if they're really considering costs, why would they spend $1.13 million well, right, right? And it's not like that, you know? I mean, they were spending it over the course of years. So when you're seeing that you're spending hundreds of 1000s of dollars on a private law firm, that's that whose partners are billing over $1,300 an hour, like, you know, we're only again, fighting over a $40,000 program. I mean, it's not, I mean, do the math,
Tim Kowal 21:33
right? Well, but I think, as Jeff mentioned in our in our previous session, that maybe they're sending a message, maybe, maybe they're happy that that there's a public records act request that, confirming that, yeah, we spent 1,000,001 almost 1,000,002 on litigation fees, and we'll do it again. Don't try us.
Tim Adams 21:53
I don't know if they're that happy. I mean, I did, I did see that they're they've posted for a new top level administrator in Irvine recently. So I'm not sure if it's related or unrelated. I have it confirmed, but, you know, I they are making some administrator changes at the highest level, you know, and this is subsequent to this journal article.
Tim Kowal 22:15
Yeah. I mean, even though this is a fantastic result for your client, it doesn't change the fact that it was a very grueling procedure to go through, and very costly for you and the you know, for your firm, I'm sure, and for the for the client, for the parents. So it's, it's not like it's a beacon that, you know, all comers welcome. You know the the purse is open. Just come and take whatever you like. You're still going to have to fight tooth and nail to get a result like this. You do. And
Tim Adams 22:43
you know, this is this case is very unique in many respects. I mean, we haven't seen a case like this. As I mentioned, Mike, you mentioned my quote in the in the journal, we haven't seen a case like this. I haven't seen a case like this in my career that goes on this long, where the district's willing to spend this much money. So, like I said, you know, there are a number of theories. One of them is that this was a bit embarrassing for them. You know, perhaps, you know, they were concerned about a number of other complaints being filed related to modified versus accommodated curriculum and education on IEPs or and, you know, there were a lot of mistakes made. So how do you you know they, I think they, they want it to be right, you know. And I think that when the public is not aware of how much any agency like Irvine Unified is spending, I mean, your average person doesn't show up to, you know, Irvine unified board meetings to ask questions, to dig in as to why they're spending money on this particular law firm, and what they're spending, you know what? You know what there's you know, you know what the issues are in a particular issue or particular case, then it's hard to you know it. It's hard to really track and appreciate you know what's the what this is costing and whether it's worth it, yeah. So you know, until this blinding spotlight, as I said in a recent newsletter to my to my clients and colleagues of the journal article, I don't, I don't think most people knew anything about how much districts really can spend on cases like
Tim Kowal 24:17
this. Yeah, all right, well, let's close this out on on the human element. How is the student doing? Is now under her but you know, she's getting private tutoring, and she's the parents are getting reimbursed for that. How is she doing on her track to graduate?
Tim Adams 24:32
So great. She's at a different school. You know, that school in particular only went to eighth grade, and so she matriculated to a high school program. She's still in a private high school program. Unfortunately, there's litigation still pending. My firm isn't handling the current litigation. I'm still very much in touch with the family, but she's thriving. She's doing well. And, you know, we've had multiple courts and decisions, you know, since. This case regarding the substance of the concern, even beyond the modifications and accommodations, whether she required private programs for it to continue to say yes. Other administrative law judges have continued to say yes, and surprisingly, many of the IEP offers that came after this, you know, this decision and well into other school years. Because keep in mind, we were only litigating a couple of years of IEPs. The IEPs happen every year. So this student, you know, it's not a static process. The district has a duty to have at least one IEP a year, and we called it an annual IEP and make an appropriate offer to that student, depending on what their needs are at the time. We call that, you know, really a snapshot. You know, there's a case called Adams versus Oregon, not affiliated with me or my firm, but they we call it the snapshot rule. We have to consider the needs at the time and then making, they have to make an offer of placement and program based on those unique needs so consistently, year after year we've had, we've seen this family through colleagues of mine, go through other due process hearings and still prevail. And you know, Irvine has largely from my understanding, again, not representing on later cases, but have been making very similar offers to prior school years. So from my perspective, you would think that there'd be an incentive to adjust those IEP offers to make them a bit more defensible. But we've not seen, you know, large adjustments in or change in behavior on the school district's part. It's almost like an assembly line, you know, they show up, they make an offer, and, you know, parent disputes it because it's more of the same, yeah,
Jeff Lewis 26:48
well, and these, these professionals, are all trained, you know, they go to the same trainings. They all have similar they go to the same IEP, so I imagine it's a lot of it is by rote in terms of, oh, we'll classify this kid as this, and we'll offer them that it's around the cookie cutter, right? Many
Tim Adams 27:02
times, yes, in fact, you know school districts, and this helps them to address the administrative components of the IEP, but they'll have IEP goal banks that they're using, that they're making adjustments to recycling things here and there, and of course, they're trying to, or at least alleging that they're tailoring them to students, but they will, you know, they will have a template that they often start with and then modify it as they go. And often this template and these IEPs without the district admitting it, in many cases, are predetermined before they even show up to the IEP meeting. Now, the IEP team includes the parent. They're, you know, parents are among the most important, of course, people at that meeting, and they have to make decisions. But it's really meant to be an IEP team, including parents in District discussion. And it's meant to be a collaboration. It's meant to be, let's really drill down on needs of the student and then determine if you know what if anything, the student needs, and what changes we should be making to the IEP from year to year. But in reality, there's a lot of behind the scenes discussion by the school district. Tim, you know, we talked about cost. It's course, and cost is a very important component. Won't come up, but it's the elephant in the room in the IEP meeting. Yeah,
Jeff Lewis 28:25
Tim, I know we need to wrap it up, but I gotta go back seven questions and ask one follow up question. When a kid is found to be owing or owed 500 compensatory hours of education, what is the practical, real world remedy for that is that kid's sentence to detention in Saturday school for 500 hours. Are the parents paid money? Is the kid given special tutoring? What is the fix for that kind of deficit? And
Tim Adams 28:48
just to clarify so it's not it that was not this child. So it was not this child. This was a different case. But you know what I referenced about the 500 hours more? You know recent decision by an administrative law judge. But what happens is, it really the remedy is relatively flexible, and what we typically do when we file a due process complaint is we're going to state the issue, and we're going to state what the law requires is a proposed resolution. So we're asking that, you know, the court to consider our proposed resolution as the remedy, and the judge could say, Yes, we like your proposed resolution, or completely throw it out, even if they agree with this on the issue. And so I what I see often is that the the school districts, you know, have a little bit of flexibility. They can provide. What they'll say is that the service, if it's something that's in the future, like 500 hours of compensatory tutoring could be delivered by either a qualified district staff member, credentialed teacher, or, you know, a private provider and and you know, they'll give the they'll give the flexibility to the school district to make that. Decision on how that service is delivered, as far as timing, they'll also give a range of time to allow that service to be delivered. So we're not going to try to squeeze it into a summer that would be a bit overwhelming, or during a regular school year, right?
Jeff Lewis 30:15
And is maybe self evident, is the remedy always remedial in nature, or is there, like, a damages or compensatory, sorry for your trouble component,
Tim Adams 30:27
so that we don't have money damages in this, in this area, so we it's going to have it's typically, you're getting this the student or the family is getting reimbursed for something they've already paid for, like in the Galliano case, they've already paid for the private school, they're getting that back, or, you know, they're, they're getting something in the future that hasn't yet been provided, like a compensatory number of hours.
Tim Kowal 30:50
So self help is the watch word here,
Tim Adams 30:53
right? Yeah, so
Tim Kowal 30:54
the parent you see your child slipping behind and the school's not not playing along, you better just do what you can to get your child to help he or she needs and deal with getting reimbursement later often,
Tim Adams 31:05
yeah. And, I mean, it's, it's, you know, unfortunately, I think you know, all of us parents have to are put in positions where, if we don't see the school acting quickly enough, I mean, you do have to take the bull by the boards and handle it yourself. You know, as long as you've noticed to the district that you don't agree that their IEP is appropriate, typically, there's a couple ways to give notice. You can do it either at the IEP meeting, where you express you have concerns and that you intend to privately place or supplement with private services, or you can do it by a letter. We call it a 10 day, 10 business days prior to when you start that service. One of
Tim Kowal 31:44
the reasons I love these conversations Jeff is because, after an hour of of conversation with with an expert like Tim Adams, I get more than I could have out of, you know, 10 hours or 100 hours of trying to research this subject. And now I get to hold myself out as a kind of a quasi expert, just enough so that I can tell, tell potential clients or parents who are having these troubles to call Tim Adams.
Tim Adams 32:07
Thank you Tim, and thank you Jeff. All right, Jeff,
Tim Kowal 32:10
well, that's gonna that's gonna wrap us up today. We want to thank Tim Adams again for joining us, and this has been a two part conversation. Hopefully you were able to join us in our previous episode, and we're we're going to wrap up this episode. If you have tips, if you have tips for us on topics and guests that you'd like to see on the podcast, please drop us a line at [email protected], otherwise, look, look to us next week for a new episode on how to lay the groundwork when preparing for an appeal. See you next
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