Disputes, Litigation and Probate Trials, with David Tate

0:01 If you follow my podcast, when I talk to real estate agents, I try to emphasize there's different types of attorneys that specialize in different phases of the process of probate. Some focus on probate administration, the routine filing and administration. Some avoiding probate or estate planning and related things to that. And another group are litigators who litigate specifically when disputes come up. Most commonly they're referred by other attorneys. We're excited to have today somebody who I met and I will talk about how I met him on the LA County Bar Association listserv. David Tate. David, thank you for joining us today.

0:33 Thank you, Bill. I really appreciate and enjoy being here. It was fun the other day, you know, I read I'm a affiliate member of the LA County Bar as a way to learn about probate and I see questions and answers. And I saw you kind of promoting yourself to other attorneys as a litigator. talk a little bit about your in your I think geographically in Northern California. talk about how you use the tool of the electronic Bar Association listserv in building your business and reputation.

1:02 So, I am primarily located in Northern California, but I actually have contacts throughout the entire state. including not just professional contacts, attorneys, primarily estate planning attorneys that don't do litigation, but also family members and I've lived north and south. So, I'm and you may know the practice of law has changed considerably, particularly over the last 10 years or so, where a lot of litigation is done remotely. In fact, the majority of litigation is done remotely now, where attorneys practice throughout the state. So, I practice both north and south is is the bottom line answer.

1:45 And the LA County Bar is a large Bar Association. The LA County Bar is huge. So, you know, you've got what, 9,000 9 million, 10 million people in the Los Angeles Basin. You got 3 million plus in San Diego. The Bay Area, the extended Bay Area, San Francisco Bay Area, is about 5 or 6 million. So, and then I have family members and contacts in Ventura and Santa Barbara counties also.

2:15 And as a affiliate for me it's a very educational tool because things that might seem rudimentary get asked by new attorneys and the older ones, but I also see some very sophisticated discussions go on there as well. and so I always encourage real estate agents, particularly in LA County, there are local bars in LA County. There's a Beverly Hills Bar, Santa Monica Bar, Century City, Long Beach, but the LA County Bar seems to be the biggest one. It's a great source of information. So in particular I saw you kind of you know offering yourself out there as a litigation attorney, I imagine almost all of your business comes referred by attorneys who don't do litigation. Maybe they do probate administration real well, or they do estate planning real well, but they're not set up as a litigator. Talk about the difference between and then I think you also see attorneys who aren't litigators who attempt to litigate. It's a mistake against somebody like you. Talk a little bit about the importance of specialization and how that how you fit into that that process.

3:14 Right. So, I've done litigation since I first became an attorney. So, I've done it for a long time. And most of my cases are trust, probate, elder abuse, real property, and then business litigation also. Early in my career profession, since I'm a CPA [clears throat] also, I don't practice as a CPA. In fact, in California it's considered inactive. But, people encouraged me to get involved in estate planning. And also people have encouraged me to become a trustee. also, by the way, have a small, practice as a mediator. But, I concluded a long time ago that there is a big distinction between, estate planning, transactional type stuff, and normal or traditional non-litigious administrations and litigation. And so, I decided I don't think somebody It's very difficult to do both. And so, you'll see, for example, and there's nothing wrong with this, you'll see estate planning lawyers who do probates or who do trust administrations that get kind of contentious a little bit. That's very common, between, different families. And that's fine. And it's also fine that they go to court. that's fine, too. I only get involved if the case becomes really litigious. So, we're talking about, depositions, pleadings, allegations, and not just talking about breach of fiduciary duty or things of that nature, but actual pleadings and allegations. And I think that there between the two different areas, estate planning and regular administrations on one hand and litigation on the other, there becomes a dividing point. So, I will never do I don't prepare a trust in estates or trusts and wills, but I certainly know a lot about them. So, there's a dividing that that's kind of I'm being a little long-winded, but

5:17 There's a divide between the two. And often I get phone calls ask me for an attorney and ask what they want, and, you know, if the administration that's, you know, I would refer to somebody, if it's litigation, it's something different. To me, it's kind of like in sports, you know, you can look at somebody, you know, have you played football? I can see the difference in a lineman and a wide receiver, you know, at first glance. And I think the same is true with attorneys in that what makes a great attorney in probate administration or a great attorney in estate planning is a whole different set of characteristics than when what makes one great in detailed you know deep litigious probate litigation. And so I'm sure you see that as well as a litigator, right? You often I'm sure lined up against attorney who should have passed off the baton but for whatever reason is holding on to it.

6:04 Right. And actually along that theme and going a little further with it [clears throat] I know friends of mine who they used to surprise me a little bit. I would ask them or they would ask me, "Dave, I know you're an attorney. I know you do litigation, but what do you do? I don't know." So cuz a lot of people don't get involved in everyday life, they never see the inside of a courtroom, which thank God for them. But then within litigation, there are different practice areas. So there is So I do, you know, trust, probate court type stuff, elder abuse, plus business litigation plus real estate litigation. There are other practice areas that that I've also done some of also. There's insurance defense, there's intellectual property, there's employment litigation. And so what you find probate courts are particularly interesting, I think, because each county 52 counties I believe it is in California has a probate division of the superior court. The rules, some of them are the same as civil litigation and other ones are different. And so what you what you see in probate and by the way, probate also, you know, these judges in probate, they see contentious cases every single day of the week.

7:31 Yes. And so there's a an attempt to you want to be litigious, you also want to demonstrate to the judge that you're a reasonable person and that your client is a reasonable person. It's different than straight civil litigation. So, an attorney who wants to do probate and trust litigation really needs you can't go to a class to teach you this. It's by experience. You have to go into court and learn and that's the way it is.

7:59 And I know it's in Los Angeles that a probate litigator primarily is in the same courtrooms. Not there's we have nine divisions. Prim- that doesn't mean they don't often go into some other related, but primarily sees some of the same judges over and over again versus general civil litigators in LA County can be any of the local courts. They're never going to see the same judge more than once or twice most likely in their career. And I know that when I sit in court, I see the relationship that the judge has with the attorney that e- either they respect them and they get a little extra, they get a little okay, I'll give you a break, or they don't know who they are and they're going to no know the rules this and I'm not going to help you at all. So, talk about how you curate that as far as your career business goes.

8:41 Yeah, you try to that's an interesting question, too. So, [clears throat] yes, you try to become known to the judge. that isn't always that easy because also judges rotate. Courts will rotate a probate [clears throat] judge. They'll be on the probate bench for a while. Sometimes they can ask to stay on the probate bench, but maybe after 2 years they're rotated off and so you get a new judge. You also have judges so sometimes you'll be in front of a judge that's a long-standing well-known probate judge and they know you. And that doesn't mean you win your case but they at least have some respect for you and they're listening to you more carefully. However, other times and it's not uncommon, you'll be in front of a judge who knows very little about probate. I had a trial up in Yuba County several years ago. We had the It's a small county. There's only one probate judge, and there I think there were only like five four to six judges total, and the regular probate judge had to recuse himself because he had a relationship with one of the attorneys who was involved in the case. So, we had a criminal attorney, or excuse me, a criminal judge who knew nothing about probate. So, you always have to be aware. And by the way, the probate judge doesn't know everything, just like the attorneys don't know everything. So, there's an education process that goes along during the case, also.

10:19 So, let's talk a bit about what causes people to litigate. Obviously, there are you know, as a as a real estate agent, I see these there's disputes all the time, what I call relatively minor, ordinary, common disputes. But, we talk about an actual trial, where actual litigation that's involved, depositions, and interrogatories, and all the process that goes on with that. What are the types of things that generally lead to a case going that deep on litigation versus maybe, you know, a couple punches to the mouth and one of them decides to step aside?

10:52 Right. So, litigation, you know, is I mean, that's what I do for my for a job, for a profession. I've done it for a gazillion years. to the average person on the street, being involved in litigation is not a fun process. I'll tell you that. So, most of my cases come from a couple to me for a couple different reasons. It's generally two different family scenarios. Either there are multiple children, you know, you got Mom and Dad. Mom and Dad do their trust. One of them dies first. The other one takes over, usually still has mental capacity, things of this nature, and you have multiple children from mom and dad. So, just that mom and dad had the children, there were divorces, there weren't mixed families, there wasn't anything like that. So, these children, some of them at least, haven't gotten along for like 20 years. That's a very typical scenario. They just don't get along at all. that needs to be discussed. I don't do again, I don't do estate planning, but that's something that would be discussed between the mom and dad when they're doing their trust or will, their estate planning, and their attorney at that time. How do we How do Our children don't get along.

12:13 What should we do? So, that's one scenario. Not a mixed And the money doesn't solve the problem, as it turns out. no, money doesn't. And I've also had [laughter] litigation over dad's computer equipment, or the guns, or the tool kits, or whatever. The other scenario that I see is a mixed family where there have been divorces or and remarriages, and so there are kids from two different families. And of course, they don't get along, either. So, those are the two typical scenarios. I'll add one more comment that I'm seeing a lot more. that I didn't used to focus on so much, but now I focus on it in every case. And it's personalities. the personalities and this is important for trying to settle a case, too. Again, I have a smaller practice as a mediator. But what are the personalities of the of the competing or warring factions? And sometimes, you know, you can't do anything about their personalities. They are so far afield that you're probably going to go to trial. You're probably not going to settle the case. But often, you can find some things about personality, [clears throat] what makes the party tick, and then try to resolve it short of trial, you know.

13:35 Right. You know, it seems to me well, let me back up. Often times people say to me, well, estate planning will avoid a probate litigation. And I said, well, not really cuz most cases in trial had something a will or even a trust. That's what's being litigated. And so, I imagine that just having the estate plan isn't enough, though it's an important step. what would you know, you mentioned the issue of children and mixed families, personality disorder. So, it sounds to me like you're saying these things need to be factored in the estate planning stage in order to equip the estate in the post estate administration phase.

14:20 So, what can you do [laughter] during the estate planning process with the estate planning lawyer. And people should go see a lawyer. I have had cases where they didn't go see a lawyer. I had a case couple years back, 16 days of trial, and it was over a an online will or trust service that that they used. That that that doesn't mean that using that that kind of a service is a recipe for litigation. It just means that there's more risk there. So, if you have a couple things that first of all, you can't stop litigation. I've told clients for years, one of the easiest things that anybody can do is to go file a complaint, or in probate it's a petition, but file a petition or complaint in court, pay your filing fee, $465 or so, it changes from court to court and at different times. But, that is one of And frankly, you can prepare as a layperson, I don't recommend this either, you can prepare a complaint or petition yourself. You don't have to I mean, you should go see a lawyer. there are, you know, there are so many rules to lawyering, to litigation, that if you're representing yourself, the old adage, you have you have a fool for a client. That's basically really true. But, so, you And anybody can file a lawsuit. That's an easy thing to do. If somebody really wants to do it, they're going to do it.

16:00 But, estate planning lawyers can look at a few things. There's what's called a no contest clause. they are

16:09 [clears throat] over the years in California, the law has changed I won't go into the history of it. It has changed back and forth, back and forth, back and forth. Sometimes the legislature wants to more enforcement of no contest clauses. Sometimes they don't want to, but basically a no contest clause says the current statutes, if you file a pleading, which in probate would be a petition, and if you allege that the will or trust is invalid for a couple of different enumerated reasons, and if you lose your lawsuit, you're disinherited. And so, that's a no contest clause in a very simple form. So, what do you do? I think no contest clauses are worth putting in. They're not mandatory. It's not required. It's not a breach of duty if it isn't in there. but And frankly, a lot of people don't want to Some people don't want to Mom or Dad don't want to put them in. Because, well, no, that's punitive against my child. I don't I don't want to do that. And that's fine. But, anyway, so, you can put in a no contest clause. If you do that, make sure if there's a particular one of your children who you think is more litigious and is likely to sue, then give that child some assets, some significant assets, so they know if they file a contest of your will or trust. Again, this is mom's or dad's will or trust or maybe sometimes both of them. But if they file a contest of it like for undue influence, lack of mental capacity, fraud, deceit, those types of things.

17:44 And if they lose, they're going to be disinherited. So give them a reason to not file the lawsuit. The other thing I'll mention quickly is

17:54 [clears throat] give consideration to who you select as trustee. and most trustees in most circumstances, it's a family member, it's one of the children. we can have a separate discussion sometime on co-trustees or two or three trustees or whatever, but we'll just say it's usually one of the children. you want somebody who has the correct attitude and approach to be a trustee. And then also consider in some scenarios, consider maybe naming an alternative private professional fiduciary or even a bank that has a trust department. So there's some things you can do, but you can't stop people from filing a lawsuit.

18:44 My father who was an attorney used to say, "Anybody can file a lawsuit against anybody for anything." Right. I That is my belief. Yes.

18:53 And [clears throat] if you keep that in mind, then you have to treat people differently, devoid them doing what they can do, not just what they're going to win. When I get phone calls from people who ask me about litigation, and I've and you know I've interviewed several other litigation specialists like yourself. You know, none of them want to give me an actual answer, but you know, I'm a business person. I'm not an attorney. I'm not giving legal advice, but I'm trying to advise somebody what to do business-wise. As a general rule, I tell them that you're probably not going to get an attorney to seriously consider your case unless there's unless you can come up with at least $100,000 in costs and fees up front, or there's at least a million dollars of assets that could be on a contingency basis to you, not a million dollars split 50/50, but a million dollars on your share, maybe $2 million estate. but just because even though you don't start spending $100,000, it's like once that train leaves the station, it's hard to get it back in, and you don't know, and yet you prepared to go a certain level. Is that advice reasonable, fair? And granted I'm in Los Angeles, I'm sure it's more expensive here than in some remote counties. is that is that advice reasonable, or am I being too aggressive on the numbers, or you're not comfortable commenting on it?

20:10 No, I'm I'm fine commenting on it. And so and by the way, different counties have different personalities of lawyers. So, there is a difference between generally between how a Los Ange- typical Los Angeles law firm handles litigation, trust and estate litigation, and generally how a San Francisco Bay Area law firm handles trust and estate litigation. Los Angeles lawyers are known for being significantly more aggressive. and but that, frankly, none of my cases are nice cases. They I look at a case from the get-go, and I advise the client on trial, not trial, filing the lawsuit, not filing the lawsuit. So, getting to your question, lawyers will also somebody who's going to hire a lawyer for trust probate litigation. there are several options as far as paying the lawyer. There's straight hourly. There are firms that work solely on a contingency. And then there are firms that do what I call hybrid, which is a greatly reduced hourly rate but a contingency kicker. So all of all of those and frankly I look at cases from all three perspectives to try to come up with a scenario that that works for my client. But so

21:48 [clears throat] if so here diving a little deeper. if a law firm is on a contingency straight contingency yes if there isn't at least a million dollars involved it probably is not worth their while to get in it might not be worth their while to get involved in a contingency. Whereas an hourly pay attorney or a hybrid reduced hourly pay attorney might be interested in it. Then there are what you're referring to you mentioned $100,000. I think you were referring to out of pocket costs. So there besides the attorney's fees in litigation there are costs. Those are paying the paying the court fees. In particular when you take a deposition you have a deposition reporter or court reporter. They tend to get pretty expensive. Sometimes you have a hearing reporter. And then you get into expert witnesses. So the 100,000 is is a good it could be less could be more but for out of pocket costs that's a good number to keep in mind. And then finally you said once the train's out of the station, essentially, well,

23:07 [clears throat] you actually can settle cases. sometimes, if it depends on the personalities, depends on the person on the other side. There actually are reasonable family members who do, on both sides, who want to get out of litigation. And then there are unreasonable ones. And so, it depends, as far as getting out of the case, I always work to try to settle a case. The courts and the judges will assign you to mandatory settlement conferences. They want you to settle the case. Everybody wants to settle the case, but sometimes not.

23:38 Yeah, when I when I mentioned the train leaving the station, I just meant that once you start, the initial cost is more than you would imagine, and then you try to settle. In fact, I find I don't know if there's a phenomenon of this in your industry, but I find that everybody's gung-ho to write the first check to the attorney. You know, they're going to kill the other person, they're going to win, they're going to fight for liberty and freedom. When it comes time to writing another check, it's usually when the mediation makes a lot more sense, because

24:04 Right. There are, again, I think it comes down to personalities. And so, when I'm [clears throat] I advise clients on the strengths or weaknesses of their case, the strengths or weaknesses of the other party's case. And I'm I'm honest. I don't I don't I want to have a happy client. Chances are they might not be happy at the end of the day, because nobody's happy being involved in litigation, but there are typically, you know, I don't There You might have a You might very well have a winning argument on certain issues. On other issues, I might tell you I'd rather have the other side than your side. They have a stronger side. So, there are reasons to settle these cases, and certainly the costs involved are one of the reasons.

24:54 One of my first real estate coaches said, "You can be right or you can be rich, but you probably can't be both. And that's you know, that's a kind of a callous way of looking at life, I think sometimes, but being right should be the goal. The goal should be being effective or productive and sometimes you're right, sometimes you have to admit you're wrong or at least plead that you're wrong and move forward. One of the areas that I get involved with as a real estate broker and I see problems is when you have a party administering the state, whether be a probate administrator or executor or trust is the kind of lack of trust in the person administering the trust the often. And you know, I find that on one hand, everybody underestimates the work involved. It's a job. I've done it as a fiduciary. It's a job that people get paid to do and it's probably the collection of the things nobody else wants to do. And I also find that attorneys no offense to personally, we haven't talked about this, but aren't as effective at describing what they don't do as what they do. And so the customer assumes, oh, the attorney's going to do everything for me. No, the attorney's going to do all the legal stuff for you, but they may advise you what to do on the administration side. And so there's both an unrealistic expectation on the administrator trustee. At the same time, people doing that job haven't had it before are likely to make mistakes, not handle professional way.

26:16 What are the most common things and yet often there's no grounds for litigation. Where does the inaction or impropriety of the trustee or administrator cross the line from gee, they still know what they're doing, they're struggling to get this done. Where does it cross the line to where there's litigation to actually warranting them removed?

26:36 Yeah, [clears throat] and that'll depend on a case-by-case basis and also on the personalities involved because yes, [clears throat] I have cases where there's just going to be litigation. So I you know, I represented in one case I was working with an estate administrator regular non-litigious estate administration attorney and he was handling the typical estate administration, the tax issues, the accounting issues, things of that nature. But the other side had the nephews had a litigation attorney as their primary attorney. So, we went through the entire administration, everything was closed up, we completed it. It was pretty darn contentious while we were going through the administration, which took about a year and a half to 2 years. That's not uncommon. And then after everything was distributed, the nephews turned around and sued my client because they were always had that in mind that they would sue my client. So, there are I what I do is when I when we talk about litigation, I also do what I call contentious administrations. Those are administrations where it's not just family you know, it's very common that family members will your mom or dad died. your you had the children had different relationships with mom or dad growing up. They have and mom and mom and dad appointed or nominated one of the children to be the executor or the trustee.

28:16 Most people that become executor or trustee have never done it before. a lot of people who go through a trust or probate administration say they never want to do it again.

28:29 Yes. It's hard. It's a hard job. And yet they're they're trying to do their best. When does a it's important, hopefully, for the beneficiaries on the other side, there's somebody who can explain to them that a an administration takes a while. And it And it just does. I'm going to throw out a year and a half as perhaps a guideline. And there are a lot of things that happen during that time period. Marshalling the assets, determining who the assets go to, doing accountings, which you give to the other beneficiaries. If you're in a probate, you're in court. The court has a typical courts these days in probate have backlogs. It can take 2 months, 3 months to get a hearing date. And that'll just be an initial hearing date. That won't That won't wrap things up. So, what point does it cross the line? There's no bright-line test, but I you know, generally, I mean, I would say if the trustee and executor and their attorney, they really should be represented by an attorney. If they're sharing information, if they're giving if they're sounding helpful, they're not hiding things, they're going to provide an accounting eventually, you're fine even though it's contentious. But it's when people start doing stuff sort of like on their own, not sharing information, not telling beneficiaries what's going on, then it can be litigious, and then a beneficiary needs to Let me put it this way. A beneficiary should probably go and hire counsel themselves.

30:11 And then the attorneys will talk back and forth and try to get a feel for is this is this going along fine or isn't it? So, you know, sometimes attorneys can make cases more difficult, depending on the personalities of the attorneys. Sometimes attorneys help, and sometimes it's good to have attorneys talking to each other.

30:34 That's right. And if those listening were real estate agents like me, I think this is where I try to play a little bit of the of the oil in the gears to smooth things, because attorneys can't talk to other parties, but we as realtors often can. And so, I try to make an effort to call the other beneficiaries to say, "Hey, we are trying to get top dollar. We're not selling it to the administrator's friend. We're not, you know, we are on the market. You know, here's the Here's the comparative market analysis I did. Here's the list of other offers we've received." We do our best to try to say, "We're doing the best we can." And I think, you know, like most things in business, everything only takes longer than you'd expect. It only costs more than you expect. And you only get less than you expect at the end of the day. Making that work is what a professional has to do to get things done. So,

31:18 And by the way, just on that note, I mean, you mentioned some of what of what [clears throat] you do. It is very helpful in a case if real property is going to be sold and there are many [clears throat] different issues that can pop up before that real property can be sold, but it is very helpful to have somebody like you with your experience level. So, you've seen the cases. You've seen the disputes and the contentiousness between the parties. You've seen how the court handles it because if it's a probate, you might need to have court approval. There are a whole bunch of things. So, your experience level is invaluable.

31:58 Thanks. And that's why we do this. I try I think to learn. I appreciate your sharing this information with us. You know, I think that that one of the things also I you know, appreciate about you and respect that I wish more attorneys took was kind of the career decision to specialize in your case in litigation versus being a generalist. I think that oftentimes I you know, I have a client who opens a probate. We all know where it's headed. We discover there's another heir. We discover they hired an attorney. Now, you know, it's like a hockey match. The gloves are off and they're killing each other. And I feel like, "Ugh, we had the wrong attorney or he needs to get a litigator involved in this. At least advise him on how to avoid problems down the road. but I'm sure at some point that must have been a courageous decision your part to make the decision to go that way. Litigation, I think, you're getting paid later, you know, longer, maybe more per hour eventually. But as a business decision, that must have been a challenge for you to go down that road. What was it like when you made the decision to go from kind of more generalist attorney or more types more well-rounded cases to specializing in litigation?

33:04 Right. Well, and with me, the story is a little longer, but I we won't we're not sitting down having a lunch or coffee, but since I was a undergraduate was in finance, then I got a master's in tax. Then I went to work for the CPA firm. So, I had all that background before I went to law school. And so, I had several options including litigation and non-litigation. But skipping to So, I started out with A lot of what happens to a lawyer sometimes is just happenstance, you know, who do you know, who do you meet? And with me, I took a job with a litigation firm. Well, actually, it was a it was a full-service business, real estate, and litigation firm and estate planning in San Francisco on California Street. And it just and I was doing straight civil litigation, employment, breach of contract, investment stuff. And that's very common. It was a great firm to work for. I was in court the second week I was there. That's very unusual these days. The attorney that I worked for was actually somebody who many people didn't like working for.

34:22 I will tell you that what I learned from him was invaluable. But long story short, during the course of being with that firm, managing partner did estate planning and he needed somebody to sometimes to go into court in his cases and so I started doing probate types of cases and I liked it from the get-go and so I started in addition to civil litigation I started doing probate litigation and court work very early in my career and it was just it was just happenstance but I at one point I was with a firm that closed and I sat down and I said to myself, well Dave, what do you like to do? I looked at it, what do you like to do? And I said, well, absolutely one of those areas is is probate work, trust and probate litigation and so I basically done it almost my entire career.

35:20 Wow. You know, I appreciate that especially here we're recording this now at the beginning of the year. People often do [clears throat] business plans and need to re- reassess their business and at some point to find something you really like to do. I know for me in real estate I jumped into probate six years ago and all my lead generation, all of my you know, education, all of my discussion with new business is related to probate because I just enjoy it. I feel like I learned David Tate, I feel like I learned so much from you as a specialist in litigation specifically probate and trust related. I'm a little over time here so mindful of that. I'll I'm going to wrap up a little bit. If someone wants to get a hold of you, we're going to put your contact info below. phone number [phone number shown on screen] and it's tateattorney.com is the website and anybody who's in real estate in probate want to learn more about it, really recommend you check out his website which is a blog and a series of blog posts that really go to detail. You know, I sent him a list of questions and I kind of got fascinated by the blog posts and made some notes and we didn't even cover a tenth of what some of these fascinating details you talk about. You really are a wealth of knowledge. Thank you so much for sharing your information online and thank you for sharing today with us here on Probate Weekly. I really appreciate your time today.

36:28 Thank you, Bill. Again, I really appreciate being on your show. It's It's a great opportunity for me and I love your show.

36:36 Thank you. Thanks so much and we'll do it again sometime soon. And this is Bill Gross, Probate Weekly, we issue new episode every week often with attorneys or other the probate administration, probate avoidance or estate planning or probate litigation as well as vendors and practitioners to be better at our practice. The goal here is to learn how to better serve our customers. If I can help any way, I'm at Bill Gross Probate on social media. If you like this, please like, subscribe, share, email me any questions and as always, make today your best day ever. Thank you so much.