Probate Conflict Resolution and the Family Home, with Mediator Lee Jay Berman

0:02 The nature of probate is conflict either there's a petitioner conflicting with siblings or other creditors or the parties in the probate or the conflict of the court to get things done in a quick manner. You can't take out the part with the court once you're into probate, but you can limit or try to mediate your conflicts amongst other parties and when we do that is with the help of a professional mediator. We're excited to have that multiple guest on our program Leejay Berman who is a probate mediator specialist has taught classes to attorneys great depth of experience in the area. I didn't even imagine there was such a thing cuz you see the people in court they want to kill each other, but Lee actually gets in the room with both of them and talks to them. Leejay thank you for joining us again today.

0:50 Bill thank you for having me. It's always so much fun being with you. And I some of these cases I you know, I know that in talking to probate litigators 90% of litigation gets resolved before a hearing date 90% of the time. Which then I wonder well how many of those are with a mediator and how many of those on their own and I can't imagine anybody would back up on their own they're not going to admit they're wrong. So it must happen quite a bit. So talk a bit about what are the what are the circumstances because when I see them is usually beginning of the process and they just want to kill each other. I imagine at some point they get tired of being on each other and spending money and over time they kind of lose that energy. What's the process I know there's a whole range what's the most common process look like where mediation does end up in a settlement?

1:37 Or resolution. Most common is you have good attorneys representing their clients they get into the process just before it starts to get really painful for the clients and the attorneys say how about we take a shot at bringing them to a mediator and see if we can't resolve this short of the rest of the discovery and depositions and all of that we're about to start doing. Good attorneys make my job so much easier because they've prepped their clients before they come in. They've talked to them about what the process is about and it's so different. I know it sounds the same, right? Litigation, arbitration, mediation, they all sound related. They could not be more different. Mediation

2:21 Litigation is not like mediation for sure. Yeah. But mediation is really just about having a conversation amongst the people involved and figuring out what people really want and what's important to them. And some of that means I'm never letting my brother have this because mom, you know, treated him better all the time or gave him money all the way along his life or, you know, what those things. So, we have those conversations and then with the mediator and the attorneys we generally work to try and reach an agreement that everybody can live with to avoid all the expense and the mental anguish of going through the process.

3:00 So, it seems to me that as somebody who obviously I mediate some conflict when I have multiple people selling a property and when one wants this, one wants that. And so, it's a regular part of my job and it and no one surprises me how little people are arguing talk to each other. And more than that, how little they listen to the other party to try to find a solution. The key, it seems to me to solve the problem is you first have to understand what the problem is. Otherwise, you're just going to beat your head against the wall, right? So, how much of it is just sitting there listening and letting them vent. But while you're they're venting, you're paying attention, taking notes, and looking for opportunities.

3:35 That's exactly it. It's not just about the venting. The venting actually gets them all riled up again sometimes. But it's about giving them first the attention of actually really being heard. There's a big difference between hearing somebody and giving them the experience that they've been heard by somebody else.

3:55 Then it's really actually hearing, like you said, all the details of what they're saying. I want to hear the things they're not even conscious that they're saying about what they want and don't want or what somebody did to them along the way. All those sorts of things, those are the things that I listen to and that I help them sort of put the rational pieces together. You said earlier this morning you wanted this. I know this is something that you didn't care much about and you might be willing to give up. What if we structure something like this? And the beautiful thing about mediation, you know, you go to arbitration or more often in probate cases you go to litigation and the judge decides for you. And that's the end of it. In mediation, you get to say I won't do that, but I would be willing to do this. If they would do that, I would do this. And now we have some give and take. We have some conversation that's settlement-focused and resolution-focused rather than I'm going to beat them over the head with this piece of information, which doesn't help us get a case settled.

4:59 It seems like so much in our culture now is everybody is empowered, everybody has everybody's an expert, everybody has a take. You know, to use an example, when I was a kid, sports talk radio was usually some sort of announcer or broadcaster asking questions of a player, a star, or a coach, somebody who had information. And it started being calling in and then the shows became more about people with opinions on what the Dodgers should do who never played baseball in their lives.

5:25 Right. And you see that in debates on health policy, you see that in debates on politics, where people have maybe great experience in one business, know nothing about what they're talking about, but they don't just have an opinion, they're passionate about it. It would seem to me that one of the challenges you have is kind of a overcoming this lack of respect for authority. Not to say that we should just blindly follow authority. But, at least we should respect, I think, education and respect experience. So, how do you That's you got to be a currency, right? If they If they don't respect you or respect your experience or your background, then why they going to listen to you? How do you establish the credibility that people are going to take your opinion as more than just some guy who's trying to get paid?

6:07 So, A, you're absolutely right. As a sports fan, the two weeks I hate most of the entire year are the weeks between the final playoff game in the NFL and

6:18 Super Bowl. Because all we do Yeah, for 2 weeks we listen to everybody tell us what they think is going to happen. I'm like, play the game already. It's like In litigation, you don't want to say go play the game already. You want to say, how can we work to find a solution so we don't have to go do that battle. And everything else that isn't resolution focused is more of that just a pine and, you know, lots of people like to opine on what the judge will do and opine on, you know, what evidence is going to get in. That's important. It's important for people to hear that it their position isn't as certain as they think it is. But, you know, we're also in an era and you touched on this, Bill. Everybody knows everything because they have, you know, Claude or Chat GPT in their pocket and think that they can find out anything. The thing that none of those devices and none of those prognostications can do is actually take into account the temperament of the people at the table, the willingness, the pressures on them that they're looking to alleviate. You know, so often it if it's brother and sister, it's the wife of the brother putting pressure on the brother. That doesn't come into any legal formulation, but if his marriage is going to survive, his wife wants him to be done with this sooner rather than later. Those are the intangibles and the human elements of this that really make the difference when you come to a mediator as much as the evidence and everything else obviously drives the day.

7:54 You know, I was I'm in a probate where there's a civil litigation aspect to it also and the procedure is so different. Now, you know, you've been involved with litigation for years for me it's relatively newer and at least in this court the judge issues like a preliminary decision basically saying unless you convince me otherwise on the hearing day, here's my here's my ruling and here's why and it seemed to me so refreshing because the judge was putting his opinion out there and explaining why he was going to go that way which means if you're going to argue with him you need to argue on this and it was fascinating me the attorney had other arguments. It was like and the judge would say, well, that wasn't in my decision. But the attorney was so right that he

8:37 Was being wronged and he wasn't paying attention to and then here I recollect that the judge had given him the road map. So, I think even attorneys are subject to our culture which I think again is everybody's an expert, everybody has an opinion, everybody knows they're wrong, everybody's a victim, we all grew up as victim but so part of your challenge is I'm sure the litigants or you know, petitioner respondent in a probate case but I imagine part of the problem also is the attorney who's not only has maybe a misread but in some cases they're convincing their client of something that you might which you how do you handle that situation cuz it's got to be delicate. You can't tell an attorney they're wrong. They don't want to hear it.

9:16 So, you're right and you heard that at the top of the show I said good attorneys make my job easier. Yes, of course. Of course, you like all your business to be great attorneys but that's just not how life works. I'm sorry. I don't know if you know that but you don't I only I list property for good attorneys and bad ones. That's just the way it goes.

9:33 Yeah, and so good attorneys are focused on the clients. They want the client to have a good outcome. They want the client to be fully informed on what the legal probabilities are and what their rights and remedies are and you know, what could happen and what could go wrong and you know, all that sort of thing because they've had enough cases that they've had absolute slam dunks they should have won that they didn't and they've had ones they never should have had a snowball's chance of winning and they did. So good attorneys have that experience and know that the machine is unpredictable and that the best we can do is try and put our best case forward and see how that's going to play out. Some cases are better than others. Then there are the other attorneys who just want it to go on as long as it can. I literally had an attorney come to me one time and a younger associate and he pulled me aside and he said, "Lee J, I can't settle this case yet. The file's not thick enough. You know what I mean?" And I was like, "Yes, I know what you mean and now I need to go vomit because it was just so unethical and it wasn't at all about the clients." So there are all kinds of attorneys out there. That's the first piece. And the second is you're right, we have to work with all of them. So you know, for me, if I have good attorneys on both sides, my life is so easy because there's rational thought involved and the motives are clear and above board and on the table and they're trying to do for their clients.

10:57 But I mean, I don't mean to be argumentative but I imagine good attorneys on both sides are a minority share of the overall business. Now, you might be successful in getting business from those cases more than most but the reality by definition, a bad attorney on one side is going to is going to gum up the whole works and it's going to force litigation and make I think settlement harder. And so, you know, what do you do when attorneys is unreasonable? Like I how do you how do you handle these things he says

11:28 It's a good It's a good question and it depends on whether their client is following them blindly or not. But if you've got a troublesome attorney who just wants to stretch the process out, all I can do as mediator is put enough

11:43 We want to weigh the package before we sell it. Yes. Yes. I you know, for me, all I need to do is put a package on the table that's appealing enough to the client and give them all the rational reasons why taking that today is a better choice than going forward with the you know, the client they want to punish the sibling or whoever to you know, take the deposition and do all that stuff. And you know, I look at them and I say, "Why would you want to spend $10,000 for that? It's not actually going to give you the satisfaction you think it is. Cuz what will happen is you go into that deposition, that person will say things that you think aren't true, you'll lose sleep for another three nights in a row after that. Like think about landing the plane and think about and sometimes I have to take people literally through a visualization cuz they're so caught up in the fight. All they see is 3 in front of their nose, the fight that they're in the middle of. And sometimes I have to say to them, "Think Pardon me. Think about next week. Think about what your life's going to look like when we're able to put this to bed, we're able to sign a settlement agreement, the court approves it, and you don't have to be in this fight anymore. What's your life going to look like at that point? What's it going to feel like when you put your head on the pillow at night or when you wake and have a good cup of coffee in the morning and don't have to think about this war anymore?

13:08 And people don't see that. They forget that there's a life after cuz they're so busy in survival mode at war. So, when I can get them to visualize that and think about it, suddenly they're more receptive to the idea of making an offer or counteroffer or something to get it settled because there's always a good reason to close the door on it and get beyond it provided it's fair and reasonable. So, we just have to figure out what fair and reasonable is, but that's the discussion. That's what we're coming together to do.

13:43 It seems like the process is also so misunderstood. I know that I used to clerk and take being in depositions with attorneys and I've also been involved in litigation and been in depositions, deposed, and otherwise and you know, in the in the dramatic TV shows or movies, you know, they ask a question of the person being deposed and the person says something and the other person says, "You're a liar!" and they start screaming at each other and I said I said to a client, "That doesn't happen in real life. You don't get to talk during a deposition." they're being deposed and time is money and you're going to be paying for having an argument and you're going to say things you don't want while you're under oath and being recorded. That doesn't happen that way. I think that somehow sometimes that again, clients have this mistaken sense of the drama being like drama TV. Well, that's why it's drama TV or movie. It's not realistic. So, let's talk a bit about your process and I know different mediators have different ways of operating. What does that look like? Are you meeting with them all together? Are you meeting with them separately? Are they meeting in different rooms in the same building? Are you going back and forth? Or what does that look like physically?

14:48 So, first of all, I have to tell you this is why I love being on the show with you because you took the word drama and addicted to the drama right out of my mouth. That's exactly what happens. But in terms of process, I love the way you teed up the question. You said different mediators have different ways of doing things. You know, one does it this way, another one does it this way. Personally, I'm allergic to the idea of a mediator saying, "This is how I do it." and having like one cookie-cutter mold that they do every mediation the same way. I call my mediation style adaptive because really what I'm doing is I'm looking at who's in front of me and what's going on with them and what they need to get it done. And sometimes it means they're in separate rooms all day cuz the hate is too high or there's been enough, you know, litigation violence done and people are angry and upset and offended. Other times, they really just want to talk to each other and maybe the lawyers won't let them or maybe the lawyers are encouraging them to talk to each other and they're hesitant. But I every day I've got a different chemistry in front of me. I have a different case. I have different people and personalities and their lives together since childhood if that's been the case and everybody needs something different from me and from the process in that moment. So, what I think I do differently and I like to hope better than the average mediator is seeing what's happening in front of me.

16:10 Like you talked about earlier, listening to the venting and all of that and helping to figure out what they need to get through it. I'll never forget one case where I sat with a an uncle and a niece and nephew. This was a civil case where they had gone into business together. The uncle, when his sister passed away, took the kids, who were then teenagers, into his business and taught them the business. Now they're having a dissolution because each was allegedly funneling clients off to their side businesses and, you know, all that sort of thing and it was falling apart. I remember getting the three of them in the room with the attorney's permission cuz I could just see it in their faces. I just saw what they needed and I went to both attorneys and I said, "I'm not going to talk settlement. I'm not going to talk facts of the case. I need to have a family discussion with just the three of them. Can I borrow them and bring them into a room with just me? Are you okay with that?" And both attorneys said, "We trust you, L.J." And I got them in the room and I remember saying to them, "I never met your mother, your sister, but I can imagine if she were here, she would tell you, her kids, how proud she is of you. And I went on with them about what I thought she might say to them. And then I turned to the brother, and I said, "And I imagine she would say to you, thank you for taking my kids in when they were young, for teaching them

17:33 [cough] about the business and about business in general, about life, and helping them grow into the successful, mature young adults they are today. And I know she'd be proud of you, and she'd be grateful for the experience that you've had to this point." And just being able to have that conversation with them, that case settled in about 45 minutes from that point. Well, before that, it was all-out war. They'd been through almost a year of litigation, forensic accountants, the whole nine yards. Everybody I don't do that every day. I've done it once. But everybody needs something different. Sometimes people need the law read to them, and they need to understand that it's not going to work the way they think it's going to work. So it Every case is different, and my approach in every case, who I meet with, in which configurations, who's in separate rooms, who I bring together in the same room, it all just depends on what they need in order to get to where they need to get to get it resolved.

18:33 You know, I'm involved in case where it's clear to me that one of the parties, who's a bit of a bully, he's he treated the staff where he used to work, I think in bullying manner. Would to me, I think, you know, and I'm pretty I'm pretty unemotional. So I control about I think he knows that I see him that way, but trying to bully me which just isn't really going to work, but I'll take note of it. And I know therefore he's picked an attorney that he can manipulate or bully as well, right? The nature of those people is they're picking an attorney based on he's going to do what I tell him to do cuz I know more than him, right? He may know a lot about that law stuff. But and so it seems that there's nobody who's been able to speak to him to say, "You're wrong." And just stop for a second. Let's look at the pieces of the puzzle. And they're not going to mediation. They had, you know, there's I think free mediation offered by the court and if I remember correctly, but that you know, free is what you pay is worth often times what you pay for it or less. You count your time in on both of it. So, at some point, I guess you become the first person maybe in this whole, you know, drama that says, "No. Maybe your attorney didn't say this to you, but you know, this the fact of life."

19:54 Yeah. And I find that once people get that's that begins the possibility of something, but until they get told that, Yes. It's like I'm right and you're wrong. So, why would I ever give up if I believe I'm right? Like I have a moral mission in life to fight to the end of this point until somebody says to me, "Well, A, you're it's not that you're not right or B, it's not that you're right or wrong. It's that this a gray area and you're going to roll the dice."

20:18 So, you're absolutely right. Bullies do just that. They hire people they can bully. They don't hire me. Their attorneys hire me. So, that good attorney who maybe is really nice and really professional and a really good attorney can't get a word in edgewise that the bully's going to hear cuz the bully's just too busy talking all the time.

20:38 Right. So, they bring them to me and my job is to make the bully hear what they don't want to hear. I don't necessarily walk away with them liking me a lot after some of these cases with bullies like that. But it's my job to make sure that I get them into a space where I can remind them, "Look, you're paying me a lot of money to do this to help you. Don't you want to hear what I have to say?"

21:03 Cuz the lawyer can't really say that to them the same way. Right. So, part of my job is to diagnose the relationship between the attorney and the client. If the attorney is trying to tell the client it's not as you think it is and needs me to help echo that, I have to see that. If the attorney is the one who thinks that the client's going to, you know, squash everybody else and walk away with all the jewels and all of that, then it's the attorney that I have to work on along with the client who's listening and believing that. So, with bullies, I do a lot of work with like you do with bullies, with celebrities. I mean, you know, we're in Los Angeles and so we see a lot of very important people and we see some big egos and all that sort of thing. And it's become one of the things that I get tapped to do a lot. I've been fortunate to mediate probate and real estate disputes and everything else with people who in the rest of their lives are quite well-known and celebrities, but in this they're they get dirt under their nails like everybody else because they're still fighting with somebody and over something that means a lot to them. So, it's interesting to watch, you know, the Hall of Fame NFL quarterback who obviously got there by being competitive say, "If they don't agree to this, I'm going to squash them in litigation." You know, all that sort of thing. And you know, that you see these people in, you know, the gold jackets and standing at midfield and taking the applause and now here they are just like threatening somebody.

22:36 The It's interesting to watch who people turn into when they're real human beings and that's the part of them that I have to connect to when I'm mediating with them. You know, I can't treat them like they're standing on a pedestal. I've got to deal with the real people in the room and their lawyers and all of that and that's what I enjoy.

22:55 Well, and the skill set that got them to success in pro football or entertainment or business is not necessarily the same skill set that helps them effectively communicate with their own family members or

23:06 Exactly. Other people that they have to negotiate with, right? It's one thing when you If you negotiate as a general manager of a football team, that's different than negotiating with your child or your sibling because you don't have the leverage that you're used to using and so it makes it that the same skills just don't work anymore.

23:21 Plus you have, you know, that sibling or whoever who wants to win because you always were the one who won and, you know, they've got all this identity tied up in it and all this emotion tied up. It's so many layers and it's so complex in addition to the facts and the law and the money and, you know, the will and everything else. It's that's what I love about my work cuz I'm dealing with people's logic and I'm dealing with their emotions and I'm dealing with the relationships with each other and with their attorneys. So there's a lot of complexity to it if you're going to do it well. And that's how we get, you know, 95% of them, 94, 95% resolved through this process is by having a mediator who really sees and understands all those things because it's not always obvious.

24:13 You know, if you just use the math, if you have a 94% success ratio of mediating a conflict, at a minimum, you're avoiding the additional costs of whatever the rest of the process looks like. Maybe it's a hearing, maybe it's a trial, right? And that's going to cost more, I imagine, than the mediator fee, even though your mediator fee is going to be a lot of money, a big chunk. It would be less than we have to pay your own attorney to go to court for a week trial or two-week trial, something like that. Not to mention the trial prep and everything else that's left.

24:44 Yep, when I talk to lawyers about, depending on where they are in their case, about how much more the client's going to spend between now and the end of trial, you know, assuming no appeals and all of that, I mean, sometimes it's 75 to 100,000, sometimes it's more than that depending on what's at stake.

25:03 Right. So, yes, it's always much more expensive, but it's not just the money. You know, wealthy families think, "Oh, that's not a lot of money to us." or whatever. It's not just the money. It's literally sitting in and making copies of or ordering from the bank all your past bank statements beyond when they're still available online, and it's pulling up all the credit card statements and everything everybody has spent and received and transferred and you know, all of that takes time and aggravation. And then the whole process, like none of us actually likes being in conflict. When you put your head on the pillow at night, if what you're doing is having an argument in your head with somebody else when they're not there, I love Buddy Hackett, the old comedian, used to say, "Don't hold a grudge. While you're busy holding the grudge, the other guy's out dancing."

25:49 Right. That's not untrue, right? You know, your sister may be sleeping soundly on her pillow, and you're lying there having an argument in your head with her. Every night the same argument in your head. It's time to come to a mediator, fix the problem, get it resolved, and move on cuz it's the mental anguish and the stress. It's what it does to other people's relationships, like we talked about earlier. And it's the money, and it's the time, and it's just the Imagine if you had all the time that you were going to spend in the next, you know, 6 months before this goes to trial. Imagine you could start a business, you could do all kinds of things with that time that are so much more productive than, you know, leading or defending a lawsuit.

26:32 Well, I think it's so easy to go to attorney, lay out your arguments, lay out your reasons why you're entitled to something. The attorney can take notes, you give him a few pieces of paper, create a petition, files it. That's pretty easy. When the responding attorney sends you interrogatories to fill out, you have to answer the same stupid question eight different ways,

26:51 Right. That's when the rubber hits the road. Yeah. And you're paying for this and then they turn around and take that scan the document, send it out, charge you for sending it out, verify it's received, charge you for verifying it's received, a couple of phone calls, 15-minute billing cycles. All of a sudden, there's like a reality like, "Whoa. I thought we had a good case, we filed a petition, and they would roll over and play dead."

27:12 Yeah. That's not how it works. No. And you're absolutely right. The attorneys tell me all the time, you know, the client walks in, "I've got this great case." Gives him a couple of pieces of paper, or tells him the story, and they say, "Okay, we'll represent you. Let's go get this thing." And then once they start doing all that discovery and the interrogatories and pulling out the disco- the you know, the documents in support of the interrogatory answers and all of that stuff, suddenly the case isn't exactly as the client said when they walked in the lawyer's office. And that's where clients can sometimes say, "My attorney wasn't very good, and they billed me all this money." And I'm like, "Yes, because what you told them when you walked in their office a year and a half ago didn't bear out when all the evidence came forward, and it wasn't quite like you remembered it. And don't you wish we were having this conversation a year and a half ago instead of now after you know, you're this far down the road."

28:03 Yeah, you accomplish you remember things a certain way and then you pull up the email and read it and go, "Ooh, it wasn't like quite that emotional I thought it was." Yeah.

28:11 It's just one of those things that I think, again, if you can find a way to solve the problem ahead of time or avoid the trial, I think you're always better off. And then it's not you're better off It's not you're better off paying for the mediation than you are not paying for mediation. It's that you're better off paying for mediation than going to trial because that's where things get out of control. That's where they get expensive. You know, can you give me a general sense of what, you know, for an attorney watching this who has a conflict, maybe hasn't used a mediator to date, meets you, it sounds like a great concept. Yeah, why not save my client all that heartache and resolve this thing? What's the general cost to get started? Or is that is there a consult and then you give them a quote, or what does it look like to go from I'm interested in attorney, I have this case, I'd love to get it mediated to actually getting the process started.

28:58 So, great question. Every mediator structures their I'm so sorry. Their practice and their billing differently. The way I do it is an all-inclusive rate that is all the phone calls up front, phone calls with both counsel together to get on the same page, make sure when the mediation comes we're going to have the right people in the room, and that they know everything they need to know information-wise in order to make a good decision on that day. And then my fee covers that day all the way until midnight if God forbid we're, you know, we're still going at 8:00, 9:00 at night. I don't want somebody thinking that I'm stretching that process out so that I can make more money by the hour. So, I have kind of a flat fee for the whole the whole shebang to that point. Having said that, mediation is too often seen as a date, an appointment. You know, let's do September 13th. Okay, we're all going to come together on September 13th and do that thing. That's all well and good, but often we get together on the 13th and despite our best efforts to plan and front-load and all of that, people still need to go find more information, look at some documents, talk to a family member, all these sorts of things. And sometimes it goes beyond the 13th, and we come back for half a day, or I follow up on the phone back and forth to nail down an agreement or something like that. So, my advice to the attorneys watching this is bring it to mediation early and often. And I'm not saying that so mediators can earn more money. What I'm saying is early in a case, we want to sit down and see if we can't get it resolved and save make the clients happy with their attorney by doing that.

30:48 And if they say, "Well, we can't settle until we have this deposition or we need to see those documents before we could agree." Then we can case manage the case outside of the judge and the court and we can

31:02 Say, "All right, how long's it going to take you to get that deposition done? How long's it going to take you to get those documents to you and you to review them and, you know, send them off to your forensic accountant to review or whatever? 45 days it's going to take? And they tell me 45 days, I say, "Let's open our meet our calendars and let's look if we're in the middle of, you know, this month today. Let's go 6 weeks out. How does everybody look at that point to come back and finish this?" And we're narrowing the discovery to a real laser beam focus on just what they need in order to make a decision they're confident in about resolution, not how to go overturn every stone and find every piece of paper like they'd have to do for litigation. So, coming to a mediator early can also help refine the process and laser focus it so that we can get to the resolution faster and easier without doing all the shotgun approach of discovery that sort of can look like, "Let's see if there's something out there that we should find, you know."

32:04 Or you have to have a shotgun so you don't miss, you're not blindsided by something, right? Cuz the other side's not going to tell you all the facts. They're going to hope you miss a few things and so it forces attorneys to do a much more exhaustive process, I.e. A more expensive process versus a laser beam if you're getting on that. Well, look, that's great insight. Obviously, these are very complex and also very customized cases and the way you approach that is obviously for each of the cust- each individual customer. Lee Jay Berman, if you want more information, the mediation offices of Lee Jay Berman, [phone number] and it's a mediationtools.com is the website and there you'll see a picture of him and he's got a bunch of certifications, classes, all kinds of good content and information and I know your website's also being updated. So, Lee, just thank you so much today, I think, for helping us understand the process. I think demystifying it. I think making it more accessible and hopefully it'll more people at least explore the possibility of mediating a solution earlier that everybody gets a little better solution is more less money spent on attorneys and needless fees and effort and more for the parties to be happy. So, thank you so much for spending time with us again today. I really appreciate it.

33:11 Always enjoy talking about it, Bill. Thanks again for having me. And for those of you, this is Probate Weekly. We get together every week, a new episode with probate attorneys, litigators, in this case a mediator to learn about how we can be more effective with our customers, how we can be more get better outcomes overall. Hope you find it interesting. I know I did. I always learn when I talk to Lee Jay about this process because I see clients go to mediation and wonder what happens and how we can prepare them to do well. Let me get your comments, your feedback. I'm at Bill Gross Probate on social media. If I can help in any way, and as always, make today your best day ever. Thanks so much.