The Role of a Mediator in Probate Litigation, with Daniel Spector

0:02 In virtually every litigation, at some point there's sort of a mediation process. On every real estate transaction, there's a box. Do you want to defer to mediation rather than the standard litigation process? So, basically all of us have agreed to participate at some level on this at some point in our career. What is a mediator? What is mediation? How does that help consumers? How does that help anybody? we have on we have on our call today an actual mediator, Dan Spector, that I hope he can answer the question for us. Dan, I know he can't actually. Dan, thanks for joining us today. Thanks for having me. I'm so I'm so pleased to be here. So, now your mediation is it exclusively in the trust and estates and probate? Do you also do mediation in general real estate transactions or other civil litigation? Or where's your where's your practice as far as a mediator? Yeah, my primary practice as a mediator focuses on family disputes involving trust, estates, financial elder abuse, and contested conservatorships. Mhm. However, Bill, I'll tell you that in almost all of those cases, there's always a real estate issue. and so, that's primarily my focus. I have on occasion handled you primarily real estate issues that happen to involve contesting family members or related parties, but really I focus on trust estate and other related disputes arising out of family disputes.

1:25 And that's really where your practice of law came from, right? So, this is your area of expertise and your area of experience where you can speak to attorneys on both sides or parties on both sides. From your experience, what I've seen is this is where you're likely to end up. Let's try to find a mediation that we can all be happy with. That's right. I tell the folks who mediate with me that there's lots in the law that I don't know a lick about. I dare you to ask me a question on intellectual property. Can't answer it. But were you to ask me a question about trust, estate, financial elder abuse, contested conservatorships, I probably can answer that because I've dealt with it over 35 years I've been practicing law in it. It would seem to me there's two parts to this that are important. One is you have to recognize as an expert in order to get the cooperation or agreement from the parties and or attorneys involved. Meaning, if they see you as an expert in bankruptcy law or civil litigation, not trust, probably not going to respect your opinion or your insight as much. And at the same time, your experience probably gives you a shortcut to sharing the law, sharing the procedure, sharing the likely outcome. So, it seems to me there's like a two-way credibility bridge that you have with your experience. I think that that's right. And I would just add a slightly additional nuance to that, which is because I've had so much experience in these disputes in the trenches, I know where the opportunities are to gain the trust of both the lawyers and the clients. And I know the language to use and really the processes to use in the critical moments of the mediation, so that we can leverage the time we have together ultimately to focus on reaching resolution.

3:14 Now, in real estate, mediation is one of those two boxes we check every time. I really shouldn't say it like that, but that's the truth because we've already decided how we're going to answer them. That we recommend to our customers most commonly or exclusively, depending on how you run your business, that if we have a dispute, we'll tend to mediate it. And the other one is arbitration. Describe for us for us non-attorneys, what's the difference between mediation and arbitration? Yeah, so the most critical difference between mediation and arbitration is in arbitration, there's someone else who's in charge of the process, namely the arbitrator, who ultimately makes the decision for the parties. Arbitrations tend to be confidential, so do mediations. But medi- mediations, the parties are in control of the outcome. The parties decide how they want to resolve the case. Again, in arbitration, someone is doing that for them. Someone who doesn't know them, not related to them, doesn't socialize with the lawyers, is simply paid to make the decision for them. Now, theoretically, when you take something to court, there's a set process and procedure that's supposed to be followed almost every single time. in mediation, do you have a specific personal process? Are there common accepted mediation practices and procedures? Or is it pretty much each individual mediator has their own approach and style and systems?

4:42 That's a great question. So, just to kind of put a little more onto that question. In law, of course, the rules regarding the decision-making process that occurs in court are they're set forth in law. They're they're written down, so that everyone knows what the rules are in advance. In mediation, there are no such rules per se for the process itself. And so, it's left to the mediator, and if the mediator's effective, the mediator will tailor his or her process to the particular circumstance, the parties, and the lawyers who are involved in order to maximize the opportunity to get the case resolved. I generally have a variety of processes that I use and tools that I use that I found to be particularly effective with me and my personality, my strengths and weaknesses, and the parties who come to me. and they're all founded on the power of understanding without agreeing, but understanding the other party's perspective, so that we can engage in an engineering process that looks like a negotiation. Yeah, it seems to me I'm not a mediator.

6:01 Now, I will say I'm married for almost 40 years. That kind of counts as a mediator cuz I'm alive still. my wife can't hear that. but it seems to me that that whenever there's a dispute at any level, personal or business, that if you don't listen to the other side and really understand what they're talking about, you're just kind of beating on each other. And so, my I guess my question for you as a mediator is how much of it is just listening and letting both sides A, feel listened to, and B, at least exploring some solution because the two of them have just been yelling at each other and nobody's really been paying attention to maybe possible solutions or possible compromises. No, it's a really insightful question and it and it's one that that has a lot of connection to the way I do things. So, just kind of personal description, I've always viewed myself and my strengths first as a listener and second as a speaker. I can speak. I'm a litigator. I've I spent my career in court speaking for people, but my even my advocacy is really founded on effective strategic listening. And I so, that's one of the reasons that I chose to be a mediator is because I'm a really good listener.

7:18 And as a good listener, one of the things that I have to do as a mediator is make the people who are speaking, the parties themselves and the lawyers, feel like they're being heard. Right. So, I employ a variety of strategies to not only draw them out and allow them to speak to me and communicate to me what their experience is, but that I can communicate back to them that I'm hearing them. Because part of my role, part of part of my most the critical function as a mediator is in effect to translate the perspective of these of these warring family members from one person to another. They've been saying the words at each other for a long time, but they're not understanding each other, they're not hearing each other. And part of my role is to get them to break through the dissonance and find a way for them to at least understand what their perspective is and why they're taking the positions that they're taking. It seems to me and again, I think as a real estate broker, oftentimes I end up being a mediator sorts between multiple heirs, multiple parties, buyer, seller, buyer agent. And it seems to me there was a great book on marriage. Again, not that I live it, but I know about it. Called Men Are from Mars, Women Are from Venus. And the idea of the book is that men by their nature tend to speak differently, communicate differently than women do by their nature. It's not always true, but as a general rule. And I think if you like, you know, read the book or listen to the lecture Dr. Joyce Brothers, [unclear], a lot of truth in that book. But it also seems to apply in business disputes.

9:00 That it's not that they're not speaking English most of the time, cuz there's also that sometimes, but it's that one person says something that either inflames the other party or it says it in a way that's accusatory rather than just asking for what they want. And it just seems that really part of your job is just, like you say, not just listening, but also maybe pulling out a dictionary to understand what the person's saying ultimately or try to break down, well, what are they really after? They're not really after that. they don't want to cut their nose off to spite their face. They say they do. What can we get to? So, talk a little bit about kind of that soft skill of listening to people and then going a little level deeper, which is to understand what they're talking about. Yeah, so a couple of things. First off, keep in mind that most mediations, or at least my mediations, generally last a day. I've chosen to make my living for the last 35 years in the context of family disputes. There are all there all kinds of other ways, easier ways, to make a living as a lawyer, but I've chosen to do that. The reason in part is because I'm fascinated by the family dynamic. I say that because I could listen to someone talk about their story, their perspective for days, all day. And I'm not bored. It makes it I'm I'm a little odd that way, which is fine. However, I would be doing a disservice if I let people just kind of ramble on about their perspective. And so I have tools in place that I use to allow people to tell me their perspective, but do so within a within a framed context so that we get through that process and into the negotiations or the discussion of what is it that you need today out of this to move past this. and so that that is an art and some people it takes it I have to be more gentle and more kind of give them a little more time, a little more grace, frankly, to let them speak their perspective. Others, it doesn't take as much time. It really varies. It depends on obviously the nature of the dispute, the history of the dispute. but eventually we get through that and we move on to the second part of

11:08 Them their communication to me, which is what is it that you need and why do you need it? So that I can then take that information and share that with their sibling step parent related cousin business partner, whoever that is. So it seemed to me that one would never lose at mediation. It just would be that the mediation process did not resolve a matter that already was being litigated. And maybe it didn't solve it or didn't resolve it completely. but it's not about winning or losing. It's really about an attempt to try to find some middle ground and see if is there's room for settlement before going to trial. Entirely correct. The winning and losing are terms that belong to litigation or arbitration. There are winners, there are losers. I would argue frankly that there are no winner the real winners because it's such an inefficient process to establish winners and losers. The real winners in litigation or arbitration are the lawyers. In mediation

12:10 [clears throat] we're not talking about winning and losing. The parties themselves are working collaboratively together through me and with me to engineer a resolution. They have to agree on the on the elements of that resolution, whether it's a real estate deal or some related division of assets, but we're working on it together. Not everyone's going to get everything that they want in that kind of engineered process. It's a collaboration. It's a compromise. But that's that's that's the nature of what we're doing. I've been in a few mediations as a witness. I've never been in one as a party, but have been had no numerous clients go through mediation in probate. And what I've noticed is that almost always, I don't know the numbers. I guess I can't be scientific about it from memory. They walk out saying well the mediation didn't resolve matters. But the next step is litigation which at some point somebody's going to write some big checks or do a lot of work. And in preparing for that, perhaps the mediation helped them reassess the facts or the likelihood of success or somehow narrowed the issues to where And so while the mediation didn't work, but we don't want to go to litigation.

13:29 And I would think that that's maybe your success kind of after the effect or not knowing that you were successful, but that happens. I and I imagine that must be part of the process as you walk away frustrated that you couldn't resolve it because you probably want to resolve it on the spot, but my guess is that really happens in the room. You're able to hammer out an agreement or grounds for agreement. Is that a fair assessment? I think it's a very fair assessment. I will say that I would more than nine out of 10 of my mediations resolve at mediation. More than nine 10 resolve at mediation? Yes, correct. In the in the same in the single day. Oh, wow. and we can talk about why that is in a moment, but it's a very small number of my mediations don't don't settle. Oh, wow. At mediation. For those that don't settle at mediation, I do think it's fair. I think it's a good insight frankly by you that at least coming through that process, the parties are clearer on what on what their strengths and weaknesses are and what the other side's strengths and weaknesses are and what the risk assessment is for each of them on a go forward basis, which helps them you know, on perhaps move forward and it's not uncommon for those for those one in 10 cases that don't resolve initially, they come back or we get the case resolved later after more information is gathered and or the risk assessment has in fact been validated through more work.

14:57 Well, I'm stunned that nine 10 resolve in the room. I would think that would be an industry leading type statistic cuz that's certainly not my Again, I don't have any mathematics to support it or data. I just my experience is that's not the case. So is is that true? Is that stand out success? I guess feel free to pat yourself on the back and if it's true. And then why is it that you have that kind of a success record? What do you think the key differences are in your process or experience than other mediators? I would say that my rate is high for success, but it's not it's it's not a complete aberration. I think that there are other experienced effective mediators particularly in the trust estate space who have somewhat similar rates. What I'll tell you is when you hire me, I view our mediation in some ways like a construction project or frankly like my trial prep, which is I spend a lot of time before we ever get to mediation preparing for the mediation, thinking about the mediation, organizing my thoughts and working with counsel to make sure that they're in a place where they're properly viewing this opportunity not as litigation but as resolution. We're taking a timeout from the litigation and I'm working with their with them and their clients to make sure that the clients themselves, the parties, understand that this is not litigation.

16:25 I'm not a judge. I'm not an arbitrator. I'm not going to be deciding anything. That's not my role. My role is going to be to facilitate a resolution that the parties themselves, with the aid of their counsel, will help engineer. And I find that you know, by investing that time into the process, we have a high degree of success. Can you share like what's the cost of mediation? Is it a standard fee or something you disclose? I mean if it's not disclosed, that's fine, too, but No, it's fine. I mean I just imagine it's expensive. I'm just curious. Of course litigation is ridiculously expensive. So Yeah, let's So let's start here. Most of the time what in the well, if I'm handling a piece of litigation over a real estate issue that cost the legal fees are running somewhere in six figures or above six figures. Sure. Usually, okay?

17:18 That's the I would say today minimum probate litigation correct with real estate involved minimum is going to be $100,000 minimum. Correct, okay? That same issue to mediate is going to cost you somewhere between you know, between 12 and $20,000. Okay. My one day for mediation usually currently is running about 15,000 bucks. Not all of that is in that day. A chunk of that is prior to the day when I'm preparing for it and working with the parties. But the all-in cost on mediation for the for the mediation itself, not what they're paying their lawyers, is about $15,000. They're paying their lawyers a day plus prep work and all that stuff, but it's a it's a it's an incredibly efficient way to resolve the same dispute that you can spend 10 times that amount in litigation. Well, I mean if 90% are signing onto a solution, by definition it's cost effective. Even if you did even if it was $100,000 they would spend otherwise cuz they're going to save all the time and trouble and heartache of going to trial. Now, I imagine though for you to be effective in mediation the litigation has started, right? There's petitions filed, there's some documents filed, maybe not all the depositions or maybe not all the discoveries done yet. What stage on a probate litigation matter are you coming in of that litigation process?

18:48 Yeah, great question. I actually get hired on all phases including pre-litigation. I have a I have a I'm a pretty popular person to mediate pre-litigation disputes in part because of my experience so I can help forecast, "Listen, this is based on the information you've got, this is how this is going to roll out. this is likely what you're going to find or not find, etc. through trial and you know, what onto appeal. I've I've mediated cases that have you know, been tried and are on appeal and or back on remittitur. So you know, it's all the whole life span of litigation. I will say as you kind of put your finger on, the most common time that the best time for people to mediate frankly is first when they're ready. When they're ready to resolve the case, okay? But everyone has to be ready. And sometimes early on in the fight before they've actually framed the pleadings, made their allegations, done some discovery, even maybe taken a deposition or two of the parties they're not quite ready. They still only believe they're only willing to hear what they want to hear, what they what they think is true. Fine. It So, usually or most commonly, I get hired after the pleadings have been filed, when we're in that second phase of litigation. Three phases of litigation, right? Pleading, discovery, adjudication. We're in that second phase, discovery phase, where some initial the medical documents have been obtained, the legal documents [snorts] have been filed, the financial advisors files have been obtained, or if it's a real estate case, the escrow, you know, the escrow documents have been obtained, the title officers maybe depositions been taken, and now we're ready to go to mediation.

20:32 I think it's like a hockey match. You got to let the guys throw the gloves and throw a few punches before you break it up. Otherwise, they're going to fight against some other time, so you might as well let them get all the energy out. I think

20:41 Sometimes that's true, but I'm telling you there I can I can help you before you have to before you actually square off and throw off the gloves. So, I imagine the mediation in Well, let me let me back up and just ask the question. How does a mediation case get assigned to you? Does one attorney recommend you? Is the Is the process where judges assign mediators? I know that in LA County Probate Court, there is like a pro bono San Gabriel Valley mediation process, and then there's like a retired judge, but he's limited. but I don't My guess is that's not you. You're a more professional mediator, like third party. But how does that happen? Because if one attorney likes you, the other one's going to hate you almost by definition, no? not necessarily.

21:27 Don't take it personal. Don't take it personal. I'm just saying. It's a it's a it's a totally valid question. You asked two questions. Let me let me answer the first one first, which is how do courts Do courts get involved in appointing mediators? And the answer is most of the time, no. There are There are some counties, and this is not This is by county by county. It's not a law, but certain counties have mediation panels. They have lists of mediators who have been qualified so that they can be assigned or they can be appointed cases. but that's rare. There was a case that came down in '21 that was completely groundbreaking in called the Breslin case that allows trial probate court judges to order private parties to private mediation. It's the only place in the law in California where judge a judge has that power. Everywhere else, private mediation, judges do not have the right to direct private parties to mediation. But in trust disputes, that's what that case stands for, that the judges have the power. They still, however, the case was silent on whether or not the judge has the power to assign a particular mediator. And so, usually, the way it works is people in trust disputes or related probate or estate disputes will agree, the lawyers usually, will agree on using a mediator to mediate their case.

23:00 How does that happen? In family disputes, in trust and estate disputes, frankly, the lawyers agree on someone who they can trust, who they know will do a good job, who understands the law, will treat their clients with respect, and set up a process that is designed to work. More times than not, that's why I get paid. So, that means that one or both attorneys probably know you and have done some business with you, and as a result, respect your process. And I have to know you're mediator. That's a whole 'nother angle to this, right? Because I can see you in court, you know, regularly on litigation matters, and maybe don't know you're a mediator. And so, but I would imagine if one, you know, knows you really well, the other one doesn't know who you are, there's a little bit of hesitancy. Do you end up talking to the other side, introducing yourself? What How does that go down? That That That does happen from time to time, where someone has had some experience with me, they recommend me, and the other lawyer says, "I don't I've never met him. I'd like to meet him." In which case, that person will call me and say, "Look, you know, you've been you've been identified as a potential mediator. I don't know you. Do you mind if we speak about your process and who you are?" I'm always happy to do that. Wow. talk a little bit here as we kind of wrap up a little bit from the business development side, because in some regards, like real estate agents and other vendors in this space, and I guess also attorneys, you know, we can be the world's best, but if nobody knows who we are, we're not going to get any business. I appreciate you being on my podcast, which is the most effective marketing you can do. But besides the podcast, what is it you do? I mean, I know that you're not at a stage of your life where you're starting out your business, but I know you like what you do, and you want to serve people. What activities do you do to generate your interest in you as a mediator and perhaps some business as a result?

24:46 That's a great question. So, part of it is that, you know, I've been working as a trust litigator at the at kind of the top end of that practice for a long time. People know me. and so, at the at the higher end of the of the practice, there's not a lot, you know, in California, there's probably now less than 200 people who are full-time trust and estate litigators. When I started doing it, you know, 30-plus years ago, that number was at least half. I mean, it was maybe 100 people. and we all come across each other, you know, because if you're good at what you do, people find you because they, you know, they want the right person to handle their case. So, I've been I've been I'm a known entity, and I think I think I'd like to think that part of the reason that I get referrals as a mediator is because people my peers respect me as an honest broker, as someone who treats other people respectfully even when I disagree with you. and so, you know, it was it was about 10 years ago that I started doing mediations because I felt like I had something to add to the marketplace. But I'll be honest, Bill, I wasn't sure the marketplace would respond. And lo and behold, the marketplace has responded really well. and so, I don't do a lot of like marketing other than I appear on podcasts like this. Obviously, no podcast nearly as prominent as yours, yet. but so, I'm happy to be here. but also, you know, I do I write articles, and I have I speak in, you know, certain places. and I just Frankly, my best marketing is doing the best job I can for the clients that I have, and hope that they'll continue to use me and speak about me to other people.

26:32 You know, I think in probate litigation, there's seems like there's two tracks. There is ones that they start off thinking there's not going to be litigation, and it falls into that area if there's something that's happened. And there's other ones that are inevitable. You have multiple heirs who hate each other, you know, they're just going to go grab the guns, throw the throw the gloves off in the hockey match, and start throwing punches. but the ones that could be avoided, what are some of our What are one or two things you would advise a probate attorney, whether it be an administrator or litigator or trying to avoid litigation? What are one or two mistakes that you've seen or things they could do to help avoid having to go into litigation and having to have a mediator? Now, again, going back to you, a lot of it's about communication. I imagine, you know, they didn't talk to their customer, or they didn't talk to the other attorney early enough to let things get out of control. But what are one or two things that you see regularly that are areas that attorneys can improve on or learn from? Well, so you I you anticipated the punchline. I If I understand your question, the question would be, "How do people practitioners, lawyers who are working on trust and estate issues before they're blossom into litigation, how do they serve their clients in ways that maybe avoid litigation down the road?" Is that what I'm hearing? Or are

27:50 Not to not to put business aside for a table here, but, you know, generally, people Well, how can they better serve their clients and avoid litigation by being more effective? Yeah. So, this really is about communication, but it's not just communication with your client, but it starts there. So, lawyers, I think, would be well served to having pushing themselves to ask not only ask the question questions to find out if there's conflict, but to follow up with those questions as if they're litigators. And I know that's hard. As a estate planner, I work with estate planners. I oversee estate planners in my firm. and they're They are different people. They have different personalities. They're They're They're not litigators. Thank God, you know? We litigators are a different breed. And thank goodness the world doesn't operate like we see the world all the time. you know, in the through the prism of conflict. So, but if you're an estate planner, or you're a financial advisor, or you're a real estate advisor, and you hear about facts that may that may trigger your own thinking about, you know, well, maybe there's maybe there's some conflict. Maybe I should ask additional questions. That's the time to do it. And to encourage your client then, if you do find that there's conflict, can you empower your client? Can you work with your client to try to have the communication while they still can with their own family to address and describe what it is they're doing and why they're doing it.

29:26 They would be saving themselves from the let from likely a legacy of fighting down the road. What causes conflict, what causes litigation down the road is an absence of communication. Absence of communication or miscommunication in prior times will open the space to allow people to make their own to fill that space with their own dark description of what happened and why. Right. And it's usually self-serving. Right. It's usually where they're the hero and everyone else or the victim and then everyone else is the wrongdoer. Right. And when this when the person who made the plan, the client, the settlor, is now gone, they can't speak up and say, "No, that's not right. That's not what I intended. That's that's you have that wrong." Like the famous line of Woody Allen movie where he's laying line up for movie and he quotes Marshall McLuhan who was a famous author. And Marshall McLuhan shows up in the movie right behind him and says, "No, I didn't mean that at all. You quoted me completely wrong."

30:33 [laughter] Like we all wish we had that occasion where the statement that were is being misquoted, the person would correct them, but in estate planning, that's not going to happen at least not today with today's technology, I don't think. So talk a little bit on the same kind of topic, you're involved in a lot of litigation involves real estate. And what are some of the best practices you've seen real estate agents who want to you know practice in the space and be an asset to their clients as well as the attorneys they work with? What are one or two best practices that they do to help avoid litigation or help resolve matters or what are two mistakes you see them making that they need to avoid? Well, so I think let's let's let's take two let's let's take the same fact pattern but a different sets of times. So the first set would be where a real estate agent knows we're going to call the settlor. That's the person who's alive who's making the plan, but they're aging and that you know they're planning for their for their own the disposition of their assets after they die. What happens to their assets after they die? If they've got a piece of real estate and they know they want to sell it and they're simply questioning maybe for reasons the market's not right. They're worried about the timing of the sale for this particular property. The question for the real estate agent or the real estate professional's going to be to evaluate the timing also in the context through the prism of what's happening in the family.

32:01 Is now the time now that you have the control, you settlor, to guide this sale. Yes, you may pay more taxes now. Yes, there may be you know it may be slightly different transaction. Maybe the market's not as ripe as it may be down the road, but you're saving yourself potential problems if you don't take control of the sale now and you leave it to the next generation who you know are not going to agree on what to do with this property whereby the opportunity in that right market gets lost. Right. Okay, so that's that's one that's Now let's say the same hypothetical happens. The settlor didn't sell the property during her life and she's gone and now the there's let's just say there's three kids. Two of them agree on what to do with the property. One does not. One's probably living in the property. For free. He cared for mom and the other two, you know, have left town. They've made lives of their own somewhere else and lo and behold even though the house is supposed to be sold and divided in three equal shares after mom dies, the one who lived with mom now says, "Well, mom told me I can live here as long as I need to after she dies. You know, until I find a new place. And you know what? It's comfortable here. I like it here. Yeah. I'm not moving and you can't sell it. Right.

33:23 What does the real estate agent do knowing that the you know the real estate agent's been hired by one of the other siblings who's the trustee to sell the property? And in that in that instance, I counsel the real estate agent A to be to be patient and B see if you can get your trustee to think about getting to mediation because if you try to do this through an unlawful detainer action, you're looking at you know somewhere between 60 and 90 days and maybe longer depending

33:52 Longer today, many cases longer. I wish I wish it was 90 days. I really do. Yeah, I mean if you know it's it's going to be a long process. It's going to be an expensive process whereas if we go to mediation and they let's say they come to me, right? We can talk about what is it that that that sibling needs who's living in the house? Well, what they're really looking they're there because they're comfortable. Well, how can we make you comfortable in another place? Or do you want to buy the place? You want to you there's plenty of assets. You want to buy this place? Let's have it appraised. We'll get it sold and you know to you. You can take it as part of your inheritance. We move on. No, you don't want that? Fine. We're going to sell it and we're going to give the list to the real estate professional. You're going to have 30 or 60 days to find a new place. We'll lend you the money for a down and the agent can represent you in trying to find a new place and you know and we can then we can deal with the stuff that's in the house cuz I assure you the another part of the story is that mom also told me that I get everything in the house. Really? Okay. And you know [laughter] so Does that answer your question? Perfectly. No, I think you're right. I think the goal here is to be part of a holistic solution and I think bring the issue to an attorney, bring the issue to a mediator early or an attorney who is a mediator and try to help resolve the matter and I think that that's great advice for all of us.

35:13 That's why That's why I was That's why I feel privileged to have you on the call today. I think that again you know, we all want to avoid litigation where we can. those of us who get involved in litigation regularly watch the mediation process and I think it's great to know somebody who is experienced, has a great track record of success and I think today we also learned a lot about the process. So Dan, I want to thank you again for being on the call. For anybody who's interested in his service, Daniel Spector is a mediator as well as a trust and estate litigator. He's with Hanson Bridgett and the website hansonbridgett.com. if you want more information there with all those contact info and his phone number and all that kind of stuff, all the social media. I just want to say again thank you so much for being on our call today and helping us learn more about mediation and how we can be more effective with our customers in that regard. Bill, thank you so much for having me. It's been a pleasure. Yeah, always. And again, that was For those of you watching again, we typically have attorneys, litigators, but in this case I think a mediator which is almost always in the process with litigation and probate. I hope you learned as much as I did today. If I can help, let me know. If you like this, please send me comments. Put it in the description as well. Reach out to me at Bill Gross Probate on social media. We have new episode every week. And as always, make today your best day ever. Thank you so much.