AHLA's Speaking of Health Law
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AHLA's Speaking of Health Law
Strategic Litigation in Health Care Disputes: Practical Tips for Navigating Litigation
Amanda Hayes-Kibreab, Partner, King & Spalding LLP, and DeAngelo Norris, Senior Associate General Counsel, Grady Health System, discuss best practices for litigating health care disputes. They cover in-house and outside counsel collaboration, handling the pre-dispute process, using contracts to manage disputes, going to trial/arbitration, identifying and working with expert witnesses, and engaging in mediation. Amanda and DeAngelo spoke about this topic at AHLA’s 2025 In-House Counsel Program in San Diego, CA.
Watch this episode: https://www.youtube.com/watch?v=Wt2nft_h3C4
Learn more about the AHLA 2025 In-House Counsel Program that took place in San Diego, CA: https://www.americanhealthlaw.org/inhousecounsel
Learn more about AHLA’s 2025 In-House Counsel eProgram: https://educate.americanhealthlaw.org/local/catalog/view/product.php?productid=1471
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SPEAKER_03:Hello. Good morning, good afternoon, depending on when you're when you're logging in. Thank you to AHLA for having D'Angelo and I here today. We're going to talk about strategic litigation and healthcare disputes. This session is based on our presentation at the 2025 In-house Council program in San Diego. So it's a follow-on to that. And we're excited to be here today to continue this conversation with you. I'm going to toss it over to D'Angelo Norris, who is Senior Associate General Counsel at Grady Memorial Hospital in Atlanta, to introduce himself and tell you a little bit about himself as we get started. D'Angelo?
SPEAKER_00:Sure. Hi, Emma. It's great to see you again, by the way. So as Amanda mentioned, I work at Grady Hospital in Atlanta, which is one of the largest trauma hospitals in the Southeast. And uh here we have uh plethora of legal issues, everything from um medical malpractice, premise liability to um guardianships. So I've been at Grady for 18 years. It's been a spin a ride. I really have enjoyed it. And I really enjoyed our session that we had in San Diego. And um I can't wait to get into some of the conversation.
SPEAKER_03:Thank you. Um yeah, great to see you again too. Um that way, it was a nice um discussion we had in person in San Diego. I'll just introduce myself briefly and and then we'll kind of dive into some of uh some some questions and some follow-up. Um I'm a uh healthcare partner at King and Spaulding in the the Los Angeles office of of King and Spaulding. My um healthcare practice focuses on representing uh providers, including hospitals, hospital systems, uh medical groups, other types of facilities, ASCs, laboratories, um, any type of provider in in disputes and primarily disputes over reimbursement issues with health plans. Um I've been with King and Spaulding since 2018. Um before that, I was at uh an I was also practicing healthcare law um at a at a VT firm. So um lots lots of lots of fun in healthcare. Um just to kind of get us started, D'Angelo, can you tell us uh what kind of litigation matters, what kind of cases uh do you manage uh in your role?
SPEAKER_00:Sure. So yeah, I kind of touched on a little bit in my introduction, um, but I think that when you and I spoke in San Diego, it was unique to see that you're outside counsel, I'm inside counsel, so it's kind of a balancing act. But some of the things that I deal with is giving advice and counsel to our executives, our C-suite, um, managing the uh employment issues that we have here, uh, whether it's um EEOC or alleged wrongful terminations or um mass terminations, we also deal with uh a lot of premise liability, and we also manage outside counsel when it comes to our major medical malpractice lawsuits. We work with a team of outside attorneys to plan our defense strategies and to coordinate the uh legal operations, and we work um closely with our risk management team, which is a part of legal affairs umbrella here at the hospital, as well as compliance and internal audit. That's the entire team that falls under the uh legal affairs division.
SPEAKER_03:Wow, really the gamut. A lot, a lot of different things. Um a lot of different topics can end up on your desk. Um, and in your role as as as in-house counsel um in dealing with outside counsel, what are some of the the best practices you've seen from outside counsel in terms of you know managing your your high-stakes litigation?
SPEAKER_00:Sure. So I think one of the things that I can think of that comes to mind is a communication piece, which is making sure that whoever you have on the outside is communicating effectively with you about filings, about progresses in the case, about the barriers that they may have dealing with people at the organization. Sometimes outside counsel will run into barriers and they'll just stop and not necessarily pick up the phone and call. So communication is key. And um, sometimes we've had, I think, issues where there's a new person assigned to the case by outside counsel, but they're not appropriately introduced to the inside council. Um and sometimes that can be irritating or it can be something an area of improvement. Um I think the best, the best outside councils that I've seen over my 18 years are the ones that understand our mission. We're a public hospital, we're a teaching hospital, which is very, very unique. It means that our staff, the majority of our staff, they learn and they go out into the world, and we have you know new residents coming in all the time, that they understand that part, and that our ultimate mission is to provide health care, regardless of a person's ability to pay. Um, and that has to match up with our litigation strategies and our goals overall.
SPEAKER_03:Yeah, that that makes sense.
SPEAKER_00:You know, to kind of throw it back at you a little, Amanda, what what do you think you would like to see from inside counsel sometimes that you don't see from outside counsel? What would be some best practices or areas that inside counsel could probably benefit from if they knew about?
SPEAKER_03:That's a that's a great question. It's a and it's a hard question because as outside counsel, you know, that that that's your boss, right? Yeah, your your in-house counsel is is your boss, and your um, you know, you you report to them, and your job is really because obviously your your boss, your insight counsel, um, who's managing um the litigation also has someone that they report to. So I I think of, you know, my job is to make them look good and to um help help them accomplish their goals um for the organization um and within the organization. But, you know, I would I just wholeheartedly agree the communication is key. I mean, that that's kind of the the cornerstone um of a good in-house and outside counsel relationship, um, keeping each other informed. Of course, the outside council, um important part of their role is to keep in-house counsel and the and the business folks and through ever whatever channels the organization prefers abreast of what's happening with the litigation. Um, but that communication also goes both ways. So learning new things about what is happening uh within the organization. And you know, I I can an example comes to mind um a dispute. Um I'm managing um against a payer on behalf of a client. Um, I I didn't find out until it was done and dusted that uh the client and the payer who we were in litigation with um were working on and signed and completed a contract. Um it would have been really great. It's pretty important. The terms of that contract had impact on the case. And and we found out about it after after it was already done. So things like that, I think, are you know, it all kind of goes back to communication and keeping those lines of communication open.
SPEAKER_00:If I could supplement my answer just a little bit, something I thought of when you were talking is I love when we have an outside council and it may send us some advanced sheets or something that we're working on. They know that we have a problem in a particular area. Like right now, we're looking at a lot of AI and thinking around AI. So we have councils that will know, hey, Grady is looking to form a new AI. Send me an article or send me some conference information. Even though we may not thank them every time they send it, it's very important. And we use that information, you know, inside to say, hey, Amanda's thinking about us, she's sending us about our issues, and it goes a long way. So I think it works both ways.
SPEAKER_03:Yeah. That's that's really good to hear because sometimes you feel like you're sending stuff to to clients and you don't know if it's useful to them or not because they don't necessarily respond back either. But it is good to know that it is often being used, even if there's not a you know a reply.
SPEAKER_00:Yeah.
SPEAKER_03:Um of the things that we talked about um in San Diego, and um I I I always you know find is an important part of um kind of setting the table for for litigation is the pre-dispute practices. And we talked a little bit about this. Um what strategies have you found effective in managing disputes, um, particularly on the front end and the when you're in the pre-dispute posture that can help you be successful as the dispute goes on, or or maybe even get it resolved before it actually goes to court.
SPEAKER_00:Well, one of the things I've learned over time is um to meet with your stakeholders internally first, like to kind of get a layer of the land because sometimes there are unrealistic expectations or that maybe just misinterpretations of what's happening in the dispute. So try to figure out number one, who are the parties involved internally before we even reach out to outside counsel or before we reach out to the opposing party or the, you know, first figure out who's involved. And the second thing I try to do is to uh figure out the expectations. I mean, what are we trying to do? What are we trying to accomplish, you know, like any good attorney should do, is sit down and talk through those things before uh reaching out and to see obviously if we have anything in common. Have we been working together before in other relationships? Are there other synergies we can work off of to help to resolve this dispute? And we also have an internal that's in legal affairs, an internal risk management team. And a lot of times they have information in their systems, in their tracking systems about trends, about other things that may be relevant to helping you to come to a resolution. It could be a similar dispute that has already been settled uh with someone else or in another situation. I always try to get that information up front before and kind of have a game plan before I reach out. Um, and also one other thing I add before I close is that sometimes knowing who to approach in the on the other side or who has kind of pushed this dispute to the point of we're going to court, we're gonna fight this, we're gonna sue you guys, and there may be some soft spots in that area where you can make progress that someone else hasn't really um is fertile ground for resolution sometimes.
SPEAKER_03:Yeah, and and you probably won't be able to find that out unless you are connecting with your internal stakeholders because those are the people who know who the people are likely on the other side, right? That they may be in the best position to know who's kind of driving um the the um the dispute from a party perspective on the other side. So that might give you an opportunity to reach out and see if there's some way to resolve it before it goes goes to the next step.
SPEAKER_00:Um yeah, it's it's kind of like you know, what you learned in law school, you know, the meaning of the mind. So at some point in this relationship, we had a mutually beneficial relationship. We thought that we were great partners, you know, you were the fit and we were working things out appropriately, and now something's come up, and sometimes it's not what you think it is. It may not be as simple as a legal answer, it may be something softer or something that's more personal that you have to kind of weed out and figure out how to reconnect these partners that were partners for a very long time. Whether it's, hey, we need to get rid of this person and get a new person or maybe some hard conversations, but sometimes those things have to happen to progress to the next stage.
SPEAKER_03:Yeah, I I often find that um that that's exactly right. There are are you know, the business is run by people and um there are personalities always involved at at different levels of a dispute. And so kind of figuring out who's who whose motivations are where, what you know, what people care about and what what people um what's kind of driving their decision making can help you potentially find a resolution. Um we talked about contracting when it comes to disputes, and we talked about this in San Diego as well, and how to effectively use contracts um to help um manage disputes on the front end. What what are your thoughts about you know approaching contracting to and and how that interplays with dispute management?
SPEAKER_00:So a couple of things that I think about when I think about this area is one I feel that if you have a lot of terms and contracts that are just really hyper-specific, it can sometimes cause problems that are not anticipated when you write the contract. So I think that contracts, all contracts need to have room to breathe, although it doesn't necessarily have to be just an open contract, so anything can happen. I've found that determining where those areas where the parties can agree to be flexible are important up front, one, two, we've used uh terms and contracts that have been very effective in the past, terms such as requiring the leaders of both organizations to meet prior to any type of even arbitration, mediation, or lawsuits being filed to have them sit down. And that has surprisingly, well probably not surprisingly, still allowed the speech, you know, just the CEOs of both companies talking and figuring out whether it's mutual uh understanding. We've even used in some agreements, contracts, agreements where we can't decide on the uh choice of law, we've used the term that it will be in the state of the non-moving party. So if I sued you, Amanda, I have to come to your home turf. And if you sued me, you have to come to Georgia. So that kind of puts a little puts a little rope up, if it's not a serious, serious thing that needs to go to court. So those have been effective. Uh, what about from outside counsel? Um, how do you view when you look at contracts that are in dispute, how do you view um those as far as resolution and and and ways to get to a resolution easier?
SPEAKER_03:Yeah, you know what something that you said really resonated with me about how if there are too many um too many very complicated pre-dispute procedures, it can actually get in the way um or make things, you know, present a kind of unanticipated um challenges, but at the same time, you know, requiring things like you know, a meeting of the stakeholders of you know, high-level executives at the company actually meeting to discuss the dispute, because sometimes when those people get in a room, they can figure out a resolution that maybe the the rest of their teams were did not, you know, um did not take advantage of. Um but I but you know, I I often do um feel like the dispute resolution provisions are they're not um they're not the focus of the business people when they're making these contracts. They're focused on the business terms, they're focused on, you know, the the the money um within the contract, but these dispute resolution provisions can actually have a really big impact on the litigation itself in you know a few different ways, sort of just at the outset. Do they require arbitration or do they allow the parties to go to court? That can have a big impact because sometimes, um, depending on the nature of the dispute, one party or the other may really not want the publicity. And they would really rather it be an arbitration. So they're not, you know, necessarily going to be getting news coverage over that dispute. That works on both sides because the one side that may know that the other side doesn't want the publicity has that leverage now to say, you know, I can take this to open court, there's no arbitration provision, and that and that can actually have a have a significant impact.
SPEAKER_00:Um I've also found, Amanda, that sometimes the disputes that I've dealt with in contracts, it comes down to the person that's trying to sell this business to the hospital saying one thing, and maybe the legal team or the team that wrote the contract is not really as involved in that conversation because obviously the person that's here wants to make a sale. That motivation is a little different than the people that really wrote the contract and they understand the legal um barriers to what the business person is trying to do. So you have to figure that part out first. Even sometimes we get contracts, and the legal team to edit the contract is not even on the you know the document. You know, we have to find out who's your legal team. We don't want to talk to the person who sold this contract, we want to talk to the person who wrote the contract, who's gonna be responsible for the legal terms of the contract.
SPEAKER_03:Right. That may that makes a lot of sense. And then also, you know, depending on the contract, some contracts don't say anything in the dispute resolution terms about discovery. And then other contracts are very prescriptive about exactly what discovery can be done and what can't be done. Um, some will just refer to if, you know, if if if it's going to be a triple A arbitration, the AAA rules or or um Jams rules, something like that. Um but I find that's that often the the contracts with very prescriptive discovery rules can can cause challenges in the litigation if your discovery needs are different from from what may have been contemplated at the time that the contract was entered into.
SPEAKER_00:And also we're we have a we're against a lot of um the evergreen terms because a lot of times people change and the organization changes. So if you have these contracts that just continue on into perpetuity, you don't really have a chance. Even if you're gonna go back with the same contract, it still is a good idea to put some kind of a provision that allows it to be renegotiated in terms to be updated. Um I think it makes it clearer as opposed to doing these one-page amendments to continue a contract for 15 and 20 years without looking at regulations and compliance, things that have changed over the course of those 15 years.
SPEAKER_03:So sometimes we see some really old paper, right? Really old paper that's just been evergreened and and you know, tinkered with from time to time, but but really out of date uh dispute resolution um provisions. And then an another, I would say another piece that often trips people up and they're because they're not thinking about it, um, necessarily being in the dispute resolution provision, but time bar terms.
SPEAKER_01:That's right.
SPEAKER_03:Um those as opposed to just you know state law applying, if the parties can um contract for specific time bar provisions. And sometimes I've seen them be really, really short and the and no one's expecting it. And you know, the client comes to us with like, hey, we have this this dispute, um, great, and then we get into the dispute resolution terms and there's a six-month time bar. That's a problem. Um, yeah. So and and sometimes the client just doesn't look there for that type of provision and doesn't necessarily know know that that's that that's there. So there's sneaky things in dispute resolution provisions, and and it's it's really um one of the first places I look in a contract as I get a contract from a client and start analyzing it. It's one of the first places I go because I'm like, okay, what's the rules of the road here that we're dealing with so that I can advise the client on kind of process um and and what our options are.
SPEAKER_00:That's good. That's good practice.
SPEAKER_03:Um yeah, go ahead.
SPEAKER_00:I was gonna say, so to transition uh a little bit about um going to trial. You want to talk a little bit about that, maybe?
SPEAKER_03:Yeah. Um yeah, if you've made it all the way through discovery and and and maybe uh a mediation and things still haven't gotten worked out, um you're you're going to trial or going to arbitration. Um you know when when and actually our our team um goes to trial and arbitration a fair amount. I'll be in a jury trial all of November and um and then I then I'm off to another state for uh arbitration most of December. So um we actually go a fair amount, but a lot of clients don't go um very often. And so I think it's important to spend a lot of time um leading up to trial with with your in-house counsel, of course, but a lot of time with your witnesses, particularly if your witnesses are coming from inside the organization, because you know, as you spoke at the top to your mission, um hospitals are mission-driven organizations and and employees are focused on delivering that mission, delivering health care to their communities. And a trial is very distracting, is it's not what they want to be doing. So, you know, I I the the the care and and handling of the witnesses, particularly if people are gonna need to be coming from the hospital to to testify, it's really important to kind of warm people up to it's okay, it's not the end of the world, it's not that scary. These are just, you know, arbitrators or jurors and and they want to know what you have to say. And spending a lot of time preparing everyone goes a long way, I think, to to kind of these nerves.
SPEAKER_00:Right, I agree with that. And with the witness prep, we try to have our witness prep here at the hospital so it doesn't um it's not too inconvenient for the providers to come down to our office to do the witness prep and to actually be there for them because you're right, they panic. I mean, you know, as a teaching hospital, people are gone maybe in the two years when something comes up and they're calling back. I have filling out a new application, you know, at a new hospital, and they're asking me about being in lawsuits. Have I been sued? You know, what's happening? What should I put on this as a response? So they're really nervous. You know, the providers are very nervous about being named. But what we try to explain to them is very rarely is it one person that did one thing that caused any bad result? Um, and sometimes we have to sit down and have your piece to appropriately defend you and the other parties involved. Um, and let sit down and pull out your piece, parse out what you did or what you didn't do, and talk about it and let us know, you know, why you did what you did.
SPEAKER_03:Yeah. From from an inside counsel perspective, what are yeah, you know, what are your expectations of outside counsel um when you're going to trial?
SPEAKER_00:I expect um the outside counsel to first of all, um, if they're going to be reaching out to witnesses or talking to someone at the hospital, to at least have an inside attorney involved in that first conversation with that person so that we can make sure they're comfortable speaking with you and they know that you're an appropriate party to speak with, um, to kind of set to tee it up and it sets the tone for the relationship. That's the first thing I would say. I also expect outside counsel to we have um occurrence analysis or updates that we need on the case prior to the you know trial, prior to mediation, prior arbitration. I expect those to be updated. So the posture of the of the trial if it's changed any as far as our likelihood of success, we need to know that. Um if if something is you know hasn't been discovered yet, but it may turn the case, it may be just positive of what the issue is. I want to know that too. Um, and it's important that outside counsel realizes that we um obviously are here for our um defense of our position, but we also are here to protect our uh witnesses who are employees. So, you know, in depositions we don't like to see our employees getting beat up or treated unfairly. We expect you to advocate for them as well as the hospital, but to not throw out people to the wall and to understand that, like you said previously, that we are a hospital, and our main thing is to make sure people have uh patient care, health care, um, and it's appropriate and it's not in the world or the the field of litigation or lawsuits as far into a lot of people. You know.
SPEAKER_03:Yeah. Yeah, all all of that um really resonates um with me. And I I I find, you know, as you mentioned, um if you're communicating with outside counsel, communicating with a witness, for example, making sure to go through in-house counsel at least at the beginning, um that's that's really important because you know, if you're talking to a nurse or a doctor or anyone else, someone who works in finance or managed care, they need to know from their internal people that this is I can talk to this attorney and this is this is okay, and I'm not, you know, stepping out of line here or in or in trouble or anything like that, because sometimes um it's scary to hear from an attorney if you're you know just someone doing your job and um it it's it it goes a long way to have that warm connection between the in-house counsel and outside counsel and the and maybe a potential witness or or something like that. I completely, completely agree with that. Um in terms of um experts, how do you typically like to handle expert witnesses? We talked a little bit about this um before, um, and your expert needs maybe in in the kinds of cases you manage, maybe a little bit different from the kinds of experts that that I use in in my cases, but you know, how do you how do you approach working with outside counsel to identify experts?
SPEAKER_00:So most times when we have the cases to kind of narrow down to medical malpractice cases, we will have our outside councils to give us an a range of experts, or sometimes we'll even look at experts we've used before that have been uh successful for us or we feel successful. And we'll normally choose based upon the CD or based upon the reputation of the expert with the outside counsel, but we normally allow our outside counsel to present us with that first list, and as we were talking. Them before at the hospital, the type of hospital I work at, we do have people that are experts in the field, but we we never use them in our own cases. But we do go over some of the details of cases so that we can get some of the blind spots that even the experts that we hire might have missed. Um, to kind of give the attorneys outside of attorneys a um we present before the board in a legal uh forum and this confidential meeting where the attorneys love it because they can get feedback from all these people that deal with the exact same types of issues every day, and they can point out things that you know even our attorneys haven't thought about before because they deal with those things. So there's kind of an internal expert review that helps to shore up the case.
SPEAKER_03:Yeah, that that's that's that's great. That sort of connection and and working between outside and in-house counsel really closely and selecting the experts, I I find um is also sort of a best practice because sometimes you're at from an outside counsel's perspective, your your in-house folks, your in-house contacts, they often have um, you know, either they may have, you know, a really good idea in terms of an expert, or um, if you have a good idea in terms of of an expert that you want them to consider, there may still need to be some internal betting of that person and you know, kind of discussions um before proceeding.
SPEAKER_00:Um also amazingly effective when we do those um those meetings to identify trends. I mean, a lot of times we kind of bring cases that are similarly situated, if it's all uh EMS cases or maybe a lot of mother baby cases or whatever type of cases, then we can see, oh, I see what's happening that, or the experts in the room can identify some of the deficiencies to help us to give a better product out. You know, maybe there's another form we need to do, maybe there's another step in the process.
SPEAKER_01:Right.
SPEAKER_00:That, or maybe that's this is a trend overall, you know, that this is happening everywhere, and they would know that more than we would, and they um share that information. It helps a lot with the cases.
SPEAKER_03:Yeah.
SPEAKER_00:Yeah.
SPEAKER_03:Um last topic um that I thought it'd be interesting to get your perspective on. Um, and this is something that can happen sort of at any point in the life of uh of a litigation matter, is is mediation, trying to reach a resolution. It can happen before you file. Um I've even resolved cases while the jury is out, you know, that's pretty late. Or sometimes even after you get a jury verdict, there can be, you know, settlement discussions and even mediation because there's a broader context in which this one dispute sits. Um, but from an in-house perspective, how do you approach mediation?
SPEAKER_00:So uh normally with mediation, I would go down and speak with the general counsel. Uh sometimes the nurse, the risk manager nurse that's assigned to the case will come as well and we'll give some authority for settlement based upon um you know our reserves or what we think the case, the value of the case is. And uh sometimes we don't normally share our um number with our outside counsel or with anyone. Um, but normally they kind of know if they've dealt with us before, they kind of know the range of what we're looking to sell the cases for, and we are always present. And one thing that we've started doing probably the last five or six years is making sure, particularly in medical malpractice cases, is making sure the family is being heard and they understand that we did not anticipate the outcome. We apologize for the outcome. We did not want your loved one. Whatever happened, it wasn't anticipated. Um but sometimes there are unanticipated outcomes which are not necessarily below the standard of care. So to just hear that person and to make sure they realize that we're a real hospital and you know, we do a lot of great things here. That's a part that we've started to put in our mediation, you know, statements and our through outside counseling. For if I go or if uh my general counsel goes or risk manager for us to all introduce ourselves and kind of go around the room and let them know that, you know, I know we're on opposite sides of this issue, but this is not what we want to happen to your loved one, kind of thing. And that goes a long way. And sometimes with mediation, it gets us closer. We may not resolve it that day, but we kind of know the range. And, you know, a couple of months later or maybe a couple of weeks later, it's kind of softened up things, and we can go and take another bite and sometimes those go to resolution.
SPEAKER_03:Yeah, that's an interesting point. Um, also that you just made at the end. In the kind of cases that I um that I manage, we we do often have mediations. Um, but I I find that they are often a step in the process, and even a case that might ultimately get resolved, maybe, you know, in um shortly before trial. Um the fact that we went through mediation before, even though it didn't resolve during the mediation, actually laid important groundwork um between the parties to getting to an ultimate resolution. Um and you know, sometimes I find mediators, they really wanna they want to put a notch on their belt. I resolved this one. But that's not always what we're you know looking for. Of course we're looking to resolve the dispute, but we're also realistic going into the day. And um, if there's movement, if there's, you know, if there's meaningful movement between the parties, sometimes that's as much of a victory as you're gonna get that day. And then you kind of, you know, everybody kind of goes back to um their corners, as it were, and continue on with discovery or or preparation for trial. And it's just, you know, it's it'll happen on a different day.
SPEAKER_00:And to kind of tie it up, it's kind of goes back to what we originally started talking about, which is pre-mediation. You know, in a couple of mediation cases, I've seen where there's one in particular that stands out in my mind that the physicians were very communic, uh communicative with the family. They spoke to them every day, and then when an unanticipated outcome happened, they stopped speaking to the family, avoid the family. And the family just basically wanted to know what happened, why you're not talking to me. And sometimes you don't know. And we tell our providers, sometimes you have to say, we don't know what happened, but we're looking at it and we're gonna figure it out, we're gonna come back to you. But that avoidance really caused us some problems later on down the road because the providers behave differently to the family and they could kind of feel something was wrong. And and that pre-I guess not pre-litigation, but before the dispute even happened, if things had gone differently, I'm pretty sure the family might not have even pursued it if the doctor had sat down and talked with them.
SPEAKER_03:Because they would have felt differently about it.
SPEAKER_00:Heard, right, exactly.
SPEAKER_03:Yeah. Well, this has been a great conversation. Um, really interesting to kind of hear the different approaches. So thank you.
SPEAKER_00:Well, I will I see you uh in New York next year. That's where the meeting is, right?
SPEAKER_03:I plan to be there um at the in-house program in New York for 2026. How about you? Will you be there?
SPEAKER_00:Uh if if my general counsel allows it, I'll be there. I think he will though. He always encourages a great program.
SPEAKER_03:Very good. Well, I will see you there. Hope uh the folks in the audience uh get to go as well. Thanks so much.
SPEAKER_00:Take care.
SPEAKER_03:You as well. Bye-bye.
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