Focus, Facts & Factums with Gabriel Latner

Welcome to Studying Law Around the World. I'm Claudio Claus. In each episode, I talk with lawyers, law students, and professors from different parts of the world to talk about legal education, careers, and what the profession looks like in real life. We talk about the hard parts, the surprises, and the decisions that shaped their paths. Whether you're planning to study abroad, thinking about working in another legal system, or just curious about how law works around the world, this podcast is for you. This episode of Standing Around the World is proudly sponsored by ITL Prep from Emond Exam Prep, the comprehensive resource designed specifically for internationally trained lawyers preparing for DMCA exams. We understand that the NCA accreditation journey can feel overwhelming. You can face many obstacles getting to success courses that cost too much, offer too little, or leave you more confused than when you started. 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Visit imams.chtodaythatsemod.ca and use promo code ITL 50 to claim your 50% discount on NCA exam preparation courses. Have the opportunity to interview Gabriel Letner, who works in Canada today, but he has experiences in the UK, in the US, and also in Canada. And I'm very excited to interview him today because after a short conversation, we've noticed that I hadn't interviewed many litigators in the podcast yet. So I'm very excited to hear from his side and thank you so much for joining in the podcast today. Happy to be here. I've already learned something, which is that one podcast hosts do the introduction that the guest is just sitting there. I've always thought this was something that you guys weren't added on afterwards, so I I learned something that was cool. There you go. Well, thank, thank you for sitting through it and I appreciate you taking the time to being here today. I'd love to start our conversation today, giving you the chance to introduce yourself to your audience. Sure. So, so just to start off, so I don't get accused of false advertising. I never worked in the UK and especially if Her Majesty's Revenue Service asks, I never worked in the UK. Canadian kid from Toronto always wanted to be a lawyer to the point that apparently when I was three years old, I was running around town people, I was going to sue them. So you can imagine, I had lots of friends growing up. When I was finishing high school, I learned that you could go to law school directly in Australia and in the UK. So I applied to those programs, got to school in the UK, did a Bachelors of Laws, which there is the purely academic degree. I never did the professional training that you would do to become a barrister or solicitor in the UK because I went to the US to get a masters in constitutional law and appellate litigation at Georgetown in DC because I was going to become a law professor. The problem was I was 22 when I graduated from that program and found that a little hard to get a job. So the professor who had talked me into academia pulled some strings and I got edit game doing basically writing amicus briefs for a think tank in DC. My first two years of practice was pure constitutional law, pure Appel litigation, and it was a totally unrealistic introduction to what the practice of law actually is. I was on a NAFTA visa when Matt ran out. I came back to Canada requalified, started looking for a job, didn't find a job. So I hung up my own shingle and I've been kind of doing my own thing for the last 10 years. Summarizing. I'm not great at math. So that's incredible. So thank you for clarifying on, on the UK aspect of it. And was, as you mentioned, all of these different experiences and, and even starting to work with appellate litigation, specifically in constitutional issues. I think the US it's, it's a very interesting place to to be able to do that. But I'd love to know specifically how have these experiences all throughout the world in a way or ultra, all the common law shaped your approach to, to litigation, to legal writing? And also if you could mention some of the key aspects of the differences you see in litigating in the US and litigating in Canada? OK, for sure. A couple of caveats being that I can't do a direct one to one comparison because I went to law school in the UK for undergrad and nowhere else. So I don't know how different it would be from say Canadian undergraduate degree saying for my masters in the US and then practicing very high level. I would say the UK's approach to legal education, and especially where I was, was very academically oriented, very theory oriented. You do contract law as one of four courses that you do for your entire first year. So my first year was contract law, property, criminal law, and I guess Roman law rounded it up. So you're only doing 4 courses for the entire year. It's a very, very intense program. You get into the weeds of the kind of intricacies of different legal areas to a level that I don't think innovating in American law schools might go. And then you're also studying things that I don't think you normally study in Canada, the US. So Roman law, jurisprudence as an undergrad and then some, you know, there was a, a dedicated, you know, history class, but half of your courses are basically legal history because they take you from the earliest days of the common law in England or church law and then build up to modern jurisprudence or taste books. In some case. We're going back to the 14116 hundred 1600s and you're watching the evolution of the law. So I'd say that taught me a lot about how to read. Basically the way that I approach reading a decision affect anything like that is what my professors taught me in the UK. It's a very clinical, analytical approach. You break everything down into its constituent parts and units. Harrogate them super useful US. I guess that would be the mirror image of that. They taught me how to write. So one of the biggest differences and I've noticed between the US and the Canada is the time limits and page limits that you have for submissions in the US, particularly the appellate level are extremely short compared to Canada. So in the US, you might have an appeal or a motion where each side gets 10 or 15 pages of written submissions and then 10 minutes of oral submissions. And in Canada, that's more or less, what, a 9:30? So that's what we would give someone just to schedule a motion. You'd get, you know, 5 pages of an aide memoir because no one actually keeps them to three. And then you get 10 minutes to tap trap with the judge. And the other guy would get 10 minutes to chat with the judge. And then sometime down the road, you're going to spend 2 to 4 hours of the court's time arguing about something that in the US would have been handled on your first appearance. So that's a huge difference. And it means that you have to be extremely selective the missions. So if you don't get to say I have 7 grounds of appeal and I have 3 arguments on each ground and three examples for each argument, you basically have to pick your top one or two points, make them extremely concisely, and then get out. So that it forces a level of focus that I, I don't think is necessarily forced on us by the Canadian courts. That would probably be the biggest kind of distinction that I've noticed between Ted and the US. Another one would be deadlines and court rules are treated. So in the US, I'm really talking about the federal system, which is where I have the most experience. If something is due on September 29th, it is due on September 29th. And if you try and upload it to the court system, you know at 12:01 on September 30th, it is not going to be accepted. It is going to be rejected as the late and out of time. You're going to have to bring a motion, you have to get court permission, You'll have to explain why, obviously. Whereas in Canada we have deadlines, we have some extremely strict deadlines. If you think about it, normally for a statement of claim, if you look at what it says on paper, you have 20 days to respond, 30 days if you file a notice of intent to defend. That usually doesn't happen. You might closed pleadings and get a statement of defence for six months or a year. And I'll truly, we've sort of been told by the courts don't bring motions for default judgment and everyone's entitled to a day in court on the merits, which means that a lot of procedural protections kind of get swept away. So the timelines in Ontario don't mean much. Whereas in certain US jurisdictions, you live and die by the clock. So there's a very different culture on that point. Well, that's so interesting. That's really interesting. I did, I did not know about the the flexibility and the possibilities. And it's interesting as somebody who is very much focused on a solicitor kind of practice and right now just as an articling student, but basically reading the bar materials for the barrister exam, it's, it's interesting to see all the, the deadlines and I had no idea about all the the flexibility that is actually possible. So, so, you know, keeping my audience in mind, then I guess I should take this moment to say no, there is no flexibility. And and young lawyers and future lawyers, if it says 10 days in the rules of Civil Procedure, you have to do it in 10 days. Now, the exceptions, you know, be the change you want to see in the world. But yeah, so you've been paying attention or it's just been paying attention. The big story, at least in Ontario now is that they're redoing the civil rules. We got their first or what was actually the phase two report a few months ago. In the opening of the court speech very recently, the Chief Justice was indicating that there are going to be significant changes. I think that's part of that. They're probably gonna have to change their approach to deadlines, but we'll see if that actually sticks. The problem is the rules can say whatever they want, but unless both the Superior Court and the Court of Appeal are consistently enforcing them as written, it doesn't really matter. So we can have the most aggressive summary judgment rules that you can imagine, But if the courts consistently say no, I'm not granting summary judgment, I'm not granting summary judgment. It was inappropriate for the court below to grant summary judgment. It creates a feedback loop were fewer lawyers will feel comfortable bringing these types of motions. Fantastic. Well, thank you for sharing that. As I kind of looked into your profile and based on the the meeting we had before, I realized that that most of the work of a litigator, your work with this experience as well, is often taking complicated legal problems and making them straightforward on paper, usually right for for judges to read or you know, for that decision should be made, I guess at at points as well as an oral argument. And I'd love to to hear a little more about what that process looks like. So what's your process for identifying the key issues that that truly decide a case? So there's two questions there which are really interesting. 1 is how do you make something complicated, looks simple on paper, and the other one is audio identify kind of the critical question or issue that the case is going to turn. I'll start with the first one because it's much easier for me to answer. So there's two types of complexity in cases that I see. The 1st is factual complexity. So this is a scenario where, you know, you might have parties that have been doing business together for 15 years. There's tons of different contracts, there's different emails, there's a lot of moving pieces and a lot has happened that's contributed to the mess that people are. So for complicated facts, what I like to do is kind of take it back to torque one-on-one and causation. So it doesn't matter what type of case you're doing, eventually the judge is going to have to decide it. Judges are human. Humans are better at linear thinking than we are parallel thinking. And we're narrative creatures. So we like thinking about stories, We like thinking about cause and effect. So kind of work backwards from the bad thing that happened. OK, my client lost $1,000,000. Why did my client miss lose $1,000,000? Because the other side didn't deliver these widgets on time. Why didn't they deliver widgets on time? Oh, because they didn't ship them. Why didn't they ship them? Because of this issue. And you work backwards to find the inciting cause. And then you can look at your facts set again. And anything that's not part of that chain of events, just get rid of it, minimize it. You can summarize it, stick it in the back of someone's affidavit if you think it's really, really important. But when you're telling the story to the judge, everything you say has to be part of the story. That leads to the problem, that leads to the result. O that's very easy to say. It's very hard to do in terms of how to do that successfully. I'm a big fan of diagrams on the court will allow them. I also think a lot of the problems come from lawyers not doing enough discovery or interrogation of their own clients evidence. Very often you'll get a story that OK, seems plausible. But when you start to kind of pick it below the surface. Well, there's this e-mail that your client never told you about and this conversation that the other side is raising an oh, they have a recording of it. And then what you very often end up with is 2 competing narratives and not to get very complicated because the plaintiff is essentially saying story A, the defendant history saying story B. And not only did these stories disagree with each other in a lot of the time they're discussing completely different events. So I think what's really important is when you first get on a file, you go through your own clients evidence, you go through your own client story with a pretty fine toothed comb. And you picked out all the things that you think are going to be problems and you figure out how you're going to address them and how you're going to simplify them. The second question you asked was how do you figure out kind of what the the issue is, what the key legal issue is? And the way I like to approach it is to start by saying, OK, if everything that the defendant or if everything that the other side is saying is correct factually, if every factual allegation that the other side is making is true, why does my client still win? What is the legal argument that means my client still wins and if I have one, great, I'm off to the race. There's motion to strike, summary judgment motion, whatever, because the facts at that point, see smack. Second part of that is OK, on the facts, as the other side presents them, my client can. So what is the easiest to prove fact or easiest to disprove fact, which would change that so that my client wouldn't. So they're saying there was no contract. Well, there was no contract. My client can't possibly sue for breach of contract. So what's is there an easy simple way for me to prove that there was a contract? Oh yes, because I have one that's signed here. So it's starting from what would in theory be the easiest case to win, which is everything the other side says is true. I still win because the laws on my side to the slightly harder case, which is I need to prove one key fact. And if I prove that key fact, I win. And then when he's as you add in additional facts that need to be proven, you've got a more and more complicated case. But if you can start just by saying, OK, I don't need to prove every allegation my client is making. I don't need to disprove every allegation the other side is making. I don't need to turn this into a, you know, three years of discovery, three months of trial, arguing over this issue, because at the end of the day, the only thing that really matters is question X. So if you can get to that question very early on, it's great. And you know, how do identify that first legal question is to do something which a lot of Canadian lawyers don't do, at least in practice, which is diagram out the actual elements of each cause of action. So, you know, go to your textbook, go to your casebook, go find the leading case on, you know, I'm just enrichment or whatever cause of action you're dealing with. It has re elements. So, you know, a benefit to the defendant, A corresponding loss by the plaintiff and the absence of juristic reason, right? Those would be the three elements for an adjustment claim. Dove through the facts and be like, OK, what facts support each element of this? Oh, they haven't needed a corresponding deprivation. They're just saying I've got something, but they didn't lose anything. OK, that's not unjust enrichment or hey, absence of a juristic reason. While a lot of people make the mistake of pleading unjust enrichment while they're in a contract dispute, they're saying you guys breached the contract that caused any loss and if it didn't cause any loss, you were unjustly enriched. The problem is that once there's a contract that provides for the benefit you can't possibly have and Justin Richmond claim here's some completely different universe great there you have a motion to strike and I'm just wondering when you can take it off the table. So negligence same thing Why is there a duty of care What's their proximity was there this was there that what was the standard of care that's being alleged Why are they alleging it shortfall really do a very thorough clinical approach and say this is what you have to prove to win. You haven't pleaded the right facts or you've misstated the law or you're not seeing some key defence or tissue that can let my side win and then narrow in on focusing on the narrowest point of disagreement. You want to get to the thing that's going to be easiest for you to tip over into the line, which is going to change the outcome of the case. Because that's what lets you write a 15 page factum that has a linear, very clearly understood statement of the facts, raises 1-2 or at most three legal issues for the judge, and then clearly applies those issues. If you're going to be arguing about an entire case and you're going to be arguing every single point of the case, every single fact, every single element of the cause of action, there's no way to do that well in 40 pages. There's no way to do that well in an hour. At that point, you're talking about a trial. And what you're telling the judge is every fact in this case matters. I need to prove all of these facts or disprove all of those facts to win. And this is a super complicated issue. Sometimes that's true. There are cases I've seen where there's no way to kind of get to the end without going through that fact finding process. But I find that a lot of lawyers are so afraid of giving up ground that even on something like a Rule 21 motion, they're not willing to put any of their arguments to one side. They're not willing to concede that there is a universe where the other side might be right about anything. So I might say something like, hey, you know, since they've pleaded that there was a contract, they can't really argue on Justin Richmond. And the lawyer on one advising here would say something like, well, but there's no contract. There's no contract. And they're dead wrong about this. There's no contract. There's no contract. We can prove there's no contract. And it can be difficult to make the point to them, which is, yeah, but it doesn't matter whether you can prove there's a contract or not. They've said two things that are mutually incompatible. So why don't we just force them to swallow it so? I say that's kind of the approach I like to take you. You start from the simplest possible version of your case and then get as complicated as you need to be, but no more complicated. Amazing, As you were bringing that up and giving an example of I guess a more regular litigation with two parties. I can see how those principles will apply to constitutional litigation to to a very big extent, especially on finding the issue of law and then basically attacking that very specific point at 1st and, and as you said, going as deep as you need to, but not not much more than that. It does that make sense? Is that, is that what you're experienced as well when it comes to constitutional litigation? I don't know if Charter litigation was also something that you've got. Work on, but have done both. I'll say in the US, in my experience, constitutional litigation almost always ends up being an interpretive exercise. So it's about interpreting the constitution or interpreting A statute that someone is arguing is unconstitutional, which means while there will be a factual record, it's usually not front and sent. Everyone typically will kind of agree what the basic facts are. Brandeis briefs might go in which are like, oh, here's what the social impact will be. But there's not as much argument about factually what is happening with the consequences of a government decision are because it's a little more abstract than odds. Is this something that governments allowed to do? I tried to port that over to charge with litigation when I first moved here and fired off some like very, very abstract Charter applications be like, Oh yeah, this is unconstitutional for XYZ reasons and I got nowhere because the Canadian approach to constitutional law is far more fact specific. You have trials that are about Charter violations. I don't mean oh, there was a Charter violation in the trial in the criminal context. I mean you get litigation going 357 years about whether or not a law is constitutional. Do you want to look at things like the Bedford Challenge prostitution That was an application on a trial, but like the original trial decision in that case was several 100 interests. It was extremely, extremely fact about if you go and look at the BC LA cases about assisted suicide, those one of ways involved told me like the amount that photocopies that they had was as much as my clients have spent on entire pieces of litigation. It is a very fact specific process, may be more akin to an inquiry or a coroner's inquest. Then you know what passes for constitutional litigation at the trial level in the US, where it's basically just the equivalent of a motion or an application in front of the judge. You don't have big, in my experience, weighty fact down trials that are changing the law. Very interesting point. And Gabriel, you've described yourself online as a lawyer that clients call when negotiations have failed. So I also wanted to ask you, when do you decide that it's worth fighting for something in court rather than just pushing for settlement? So I don't, which is great. That's not my job. I am not the person who decides whether to settle. And I actually think this is a very important point that a lot of lawyers miss, You know, is anyone ever worked against is listening to this? My apologies. But if you ever came to me on the phone or in the hallway and said something like, come on, Gabe, your client is being unreasonable. It's your job to talk them into accepting the settlement offer. You blew whatever respect I had for you in that moment. That is not a lawyer's job. We don't tell clients to settle. We don't tell clients to go to court. My job is to lay out the legal strengths and weaknesses of my client's case, tell them what I think the predictable likely range of outcomes might be at trial from, you know, if you lose, what's the likelihood of that? What would be, you know, average costs or against you be like blah blah blah to hey, here's what you will get if everything goes. Exactly. It is not my job to tell my client to settle. It is not my job to tell my client that they should go to mediation. It's not my job to tell them they should listen to what the mediator is saying. All I can do responsibly is advise them on litigation risk and what their legal rights and responsibilities look like to me. I should probably rewrite whatever it is that you read. I'd say it's fair to say that the cases I like are the ones where the client isn't going to settle because I'm not a huge fan of negotiation as an activity. It's not that I'm afraid of compromise or anything like that. It's just, it's a completely different skill set from what I want it to law school for and what I trained for. And it's, you know, I think Ioffer great value and effective service and advocacy. Don't know if litigation is the same deal there. Sorry, don't know negotiation is the same deal there. And it's yeah, like I got out of employment law because I hated the mediations. The mediations were just ungodly repetitive. No one was really trying to solve the other person's problem. They were just arguing about a number and what was probably the least efficient way of doing that. So I'd say a lot of the times I have a conversation with my client up front and I say, hey, what are you looking for here? Do you know you need to go to court because this is precedent setting for you. Like I had client who said, I have so many employees, I need the court order saying that my employment agreement has a valid termination clause. So I need this like I, I can't settle with this guy. I have to go to court. And I have done, it was like, great, I'll do that because that means we're not going to mediation, We're not going to this, we're not going to that. I do a lot of work consulting on things like summary judgments or motions to strike. And then I'm very upfront with people and I say, look like if this goes to trial, I'm not your guy. I'm not going to sit here and watch this case for 3-4 years and then do a multi with trial. I will help you argue this motion. I'll put this together. And as part of that, as it usually happens, the case might settle. A lot of cases settle on the way to summary judgment because you get cross examination, you can get to look at each other's fact and as a result of that, people get closer together. People start to see the weaknesses in their own case and that's where something comes from. But I hate the grind of that. I don't think a lawyer's job is to, I don't think the plaintiffs lawyer and the defendants lawyer are supposed to get together, beat up on their clients, kind of force people into a settlement. I want to get to court quickly. I want to get a determination of my clients rights and that's what I advertise. That's when I saw people fantastic and. Also, another point here is that many of our listeners are in law school are starting their first jobs. So I'm curious to hear from you. What are some of the habits of skills that you believe that lost students or early career professionals should be working on developing as early as possible if they want to succeed in a palette work or in a more motion heavy? Practice. Yeah. I can't say if this is a habit or a skill. I guess maybe it's a practice. You should go and watch court cases. Like the courts are open. That doesn't just mean that like, the public gets to go in. Our media can send reporters to report on cases. Like you're allowed to walk into basically any courtroom in Ontario as a little sign on the door saying, hey, this courtroom is being ordered closed and you can sit and listen. So pre COVID, I used to spend a lot of time in Osgood Hall just watching appeals. And I would go and, you know, I'd walk across the commercials and I'd watch motions and I'd watch CPC and be like, OK, this is how lawyers are working. This is how people are advocating. And this is the types of questions images are asking is great. Now post COVID, you don't even have to leave your apartment. You can just get on Zoom and watch a lot of these. And you know, if you can't do it during the day because you're at work, there are a ton of Supreme Court cases that have been recorded. So you can listen to those on different websites. And then in the US, there's a website calledoyaoyez.org Ascent and it has audio recordings and transcripts for basically every SCOTUS hearing going back to the 50s or 60s. So hundreds and hundreds and hundreds of cases argued by some of the top advocates of their time. And maybe at any time the law might be different. You know, we don't have a Second Amendment in Canada. We don't have a direct equivalent of the 1st, but if what you're trying to pick up is the skill set of oral advocacy and particularly the skill set of appellate advocacy, you really just have to watch people do it. So yeah, I'd say go find these cases, find the materials, read them, think about what type of arguments you would make or how you would have handled submissions and then watch the actual argument. I've also, I found early on, if there was an appeal I was interested in, I would just e-mail the lawyers and say, hey, can I get the the appeal record? Can I get your factions? Can I talk to you for 10 minutes about the case because I'm going to come and watch it. And in Toronto, I say one thing about our bar. We are super generous. I said some disparaging things about Ontario lawyers early on, but by and large, we are incredibly friendly, we're incredibly giving, we're incredibly supportive. Even, you know, lawyers who aren't participating in formal mentorship programs, in my experience, have jumped at the chance to be helpful and passed things down to like, I'm not going to name names. But when I just showed up here knowing no one, knowing no job, no one was like sitting over my shoulder telling me how to do things. I go on candy. I'd find a case that was kind of like mine. I'd look for the lawyer who did it. And I sent him an e-mail saying, hey, I look at a question about how you approached it on this. And some of the people I've met through that 7-8 years ago I'm still friends with and they've been incredibly helpful in guiding. So if you don't ask, you don't get Lawyers love, love talking about their own careers in their own work, which I guess is a podcast host you've kind of figured out out because here I am doing just that. But yeah, I think ask people about their cases, actually read the cases, read the factions, read the transcripts or listen to the submissions and then read the decisions and kind of see how it all works together. And then the other book side of that is, you know, studies all well and good, but you need to practice. So get on your feet. There are some changes coming to the rules of Civil Procedure, which I really, really love. There are some that are being discussed which I think are going to have the unfortunate effect of limiting opportunities for younger lawyers to get practical experience. So, you know, they're talking about eliminating oral discovery. Oral discovery is the safest place for a young lawyer to practice asking questions. That's going to go away. So is a senior lawyer now gonna give a junior opportunities on cross examination where a mistake could actually be detrimental to the client? Maybe, maybe not. If we get rid of motions courts, if we get rid of easy access to pleadings motions where the stakes might be lower, how are junior council going to get their hands on things? Right? So the Court of Appeal has been very good and they are public about this and they encourage council to give juniors an opportunity. They say come on in, split your arguments if 3 council are listed on the fact. And we'd love to hear from all three council. And the kind of wink, wink, nudge, nudge is we're not going to punish you or your clients if you're associate messes up. So I have a lot of respect for lawyers who give their associates an opportunity to speak anytime in court. And as juniors, I think you guys should have not an expectation that you'll speak because you're not entitled to it. You're not Oded. But if you get through or if you're working for a barrister and you get through your entire article in term and you haven't had a chance to make any kinds of submissions, she's not doing with favor. And I do say she there because my, in my experience, female principals are much better about getting their juniors up there. So yeah, you're, you're not a slave. You're not a paperwork Monday. You are there to be taught. You know, part of teaching is giving you opportunities to get on your feet. So get on your feet early, get on your feet often, even if it's not your exact practice area, even if it's not a big sexy issue, if it's a $5000 small claims case that you could do for your, you know, aunts, neighbor's son and your firm will let you do it. And we'll give you a chance to practice and hard skills. Do it. Great advice. So to wrap up today's episode, I wanted to ask you, you've mentioned that you have a very interesting hobby and that is wood turning. And I wanted you to hear a little bit about that. I wanted to hear specifically if you think that having a hobby outside of your career entirely, if that plays a role in, you know, keeping you motivated and and keeping you healthy and all of that. And if betting anyway has shaped your career or or is that something that you highly recommend of young lawyers to to keep in mind? OK, yeah, a lot to unpack there. Feel free to hit the buzzer if we actually run out of time. The first thing I'll say is the reason to have a hobby and invest in it is because you enjoy it. There's no other. That's why they're called hobbies. They're not chores. So yeah, I I wouldn't turn because I absolutely love it. Like it's meditation for me. Having a Bobby outside of law can be beneficial for a few different reasons. The first, I'd say is the dinner party scenario, though sometimes you don't want to be talking about your work as a litigator or sometimes your spouse doesn't want you to be talking about your work as a litigator. So sometimes it's great that when you meet someone for the first time and they say, hey, what do you do? You don't be like, well, I'm a commercial litigator who specializes in shareholder disputes. You can say I do a lot, but you know what I was doing this afternoon? I was woodturning A vase. That's gonna be a gift for a friend. And I'm doing all these cool different techniques on it. So it gives you an excuse sometimes to talk about something other than your career, which is lawyers is valuable. More than that, it gives you or forces you to spend time with non lawyers and talk about non lawyer things with what I'll call real people. Because if you spend all day every day only talking to other lawyers and especially only other litigators, you might just go insane. We are not normal people. We don't approach life in a way that would be recognizable to 99% of the population. We walk around and we're like, that store needs to move that extension cable or someone's going to trip and they're going to get suited. And how would the the owners occupiers insurance respond to that? And is the city property Like who's responsible? Oh my God, Oh my God, Oh my God. Every insult is defamation, everything just you jump to a legal conclusion first. Normal people just like, oh, they should probably move that. They should move that extension cord. Maybe I'll move it forward them so no one gets hurt. And As for the effect on your career, I have gotten some of my most interesting cases from people I met through my hobbies. I think especially young lawyers, there's kind of an unhealthy, unrealistic version of legal marketing and how clients hire lawyers, which is you have to be the best. You have to be known for being aggressive and fighting for this and fighting for that and you have to get all these chambers awards and whatever the truth is, lawyers care about that stuff. Why I'm saying my experience do not clients are going to pick a lawyer who they know or who their friends know and who they kind of trust, don't hate spending time with. They're going to assume you are competent. That's one of the best things about being a lawyer is your client based until proven otherwise, it's just going to assume that you know what you're doing. So you don't need to convince them of that. Every single lawyer is assumed to know what they're doing. Don't argue about your competence. Don't argue about what a great job you're going to do. Show them the other ways that you're going to add value and you're going to help them make them like you. So I have clients now who really, I never spoke to them about what I did. They knew it was a lawyer. They knew I was a litigator. All of our conversations were about shared interests and hobbies. And I didn't know what they did. And then they might come to me after a year of knowing them and say something like, hey, Gabe, I don't know if I've mentioned this before, but I own this company and we just got absolutely shafted. I have vendor. This is what you do, right? You're this time a lawyer. And that wouldn't have happened if I'd walked up to them and said, hi, I'm Gabe. I hope I can help you with any of your your legal issues. Let's not talk about our hobby. Let's talk about how you can be useful to me and how you can become my client and give me money. Anything that broadens your network. Yeah. The end of the day that might improve your practice. The last thing I want to say though, is we live in a very interesting time where people, especially younger people, are being bombarded with messages about what they're life should look like and a work life balance. And you look on your friends and you see them taking all these vacations on Instagram. And everyone you look at is not just a lawyer, but a 1 Turner, an Olympic fencer or a classically trained cellist or some super chess prodigy person who goes and plays against the robots. And he's like, well, all I'm doing is holding down my job and that's all I can do. And that's OK. Not everyone has the time or interest in a hobby. And work can be your hobby. TV can be your hobby, books can be your hobby. You don't have to have some special other thing that you're great at. Like I'm not great at wintering. I just enjoy it and that's OK. You don't have to be good at something to enjoy it. And it doesn't have to be something that's going to turn into a side hustle. It doesn't have to be something that your clients are going to be super impressed by. And for a lot of people, I'd say, especially in their late 20s and 30s, your hobby might be your family. I don't have children, so I have lots of time to go do other interesting things that I enjoyed. But if you have kids, you know, I, I know a guy who spent basically a decade getting up at 7, getting back from work at 6:00 PM. He'd spend 3 hours with his kids, maybe spend an hour with his wife and he'd go to bed and get up and do it all over again. And once every three or four months, he'd have a free day on a weekend that I also had a free day and we'd get together and have lunch and I'd be super grateful for his time. Because you know, when you have young kids, they're going to come first. So the message of you got to have a career that you love and you're really successful at and you have to have a family and on top of that, you have to have a hobby. I think that's pretty harmful messaging for a lot of people. A hobby shouldn't be something that's, you know, obligation or something that you dread or something that you're doing because people have told you you should do it. It would be something that generally you enjoy and makes your life better. And I'll single out one hobby or joggers. No one likes jogging. If you're a marathon runner or something like that, cool. But if you're a hobby, is that a jog for 45 minutes a day? That's not a hobby. That's an exercise your team. That's cool. But like, that's not a hobby. And you shouldn't make jogging that your entire personality because it's incredibly annoying. But exercise is important. Sleep is important. Too many lawyers sacrifice that. And when you're starting out, it's easy because you're used to pulling all nighters in college. By the time you're 10 years out, you will be able to look at your peers and tell very easily which ones are regularly functioning on less than six hours of sleep a night and which ones only get exercised when they're walking from the elevator to their desks. And you don't want that to beat you because it catches up really, really quick. So hobbies are great. If the hobby can be something that gives you exercise, even better. But the mentality of you have to have some super cool, interesting, fulfilling hobby outside of work, we have to kill them. Wow, that was so good. I think it's, it's always amazing when the, when we have truth, truthful encouragement, which is not just encouraging people to do something for the sake of it. But I just really love the reasoning you put behind that. Maybe that comes from you being a really good litigator, but that, that point was just one that, that I, that I really appreciate. It's hard to feel guilt for not doing something that you don't even know if you enjoy. So I really like that, that you brought that up. And I hope that will inspire some people as well as they choose their priorities and, and go forward in their, their career. Well, thank you so much for taking the time to chat today, Deborah, and putting up all of these, these thoughts together from, you know, appellate litigation to hobbies and day-to-day life. Really appreciate you taking the time. My pleasure.