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Rob Kozloski’s “War Story” – “Expect the Unexpected”
Commercial litigator Robert J. Kozloski, III, shared this "SynerG War Story" about the value of being forewarned by his mentor of the possibility of a strategic (and baseless) objection during his first opening statement just to unsettle him at the start of a trial: Jury trials can be one of the most exciting parts of being a litigator, but they can also be the most contentious and stress-inducing part. When I was about 3 years out of law school, I was representing one of my own clients who I had defended from the outset of his case – a first for me at the time. The dawn of trial arrived, and this was my first “speaking role” at trial as it was my job to handle the opening statement. I had intently studied my outline, reviewed every inch of the file, and felt as though I was more ready than I could ever be. As was the case for every hearing or trial, my boss/mentor called me in the car on the way to the courthouse to go over everything and make sure all of our ducks were in a row for the day. While we went over the detailed logistics of the upcoming day, he warned me of something that could throw me for a loop – something that I would never have thought would happen. He warned me of the chance that opposing counsel would object during my opening statement since I was a young lawyer and could use an objection as a potential tactic to throw me off. He told me no matter what it was to act like it was no big deal and a normal part of the process whether the objection was sustained or overruled and just continue like nothing unusual had just happened. I took the advice not thinking much of it at the time but could not have been happier for it. We arrived at the calendar call and proceeded through voir dire without any event. However, when I was about 10 minutes into my opening statement, low and behold, opposing counsel flew out of his chair and began objecting up and down. I turned around from the jury and was instructed by the judge to approach the bench. When we arrived, opposing counsel explained his objection (that he thought I was about to say something that we stipulated not to discuss) and the judge overruled him allowing me to continue. Having been caught completely off guard, I gathered my thoughts and attempted to recall where I was in my outline with at least 30 people from around the courtroom staring at me – a rather daunting experience for a young lawyer. Fortunate for me having received this advice from my boss/mentor, I expected this, and was able to jump right back into where I was in my opening statement. We ended up winning the trial, but that memory will always stick with me for the rest of my career. Moral of the story is that young lawyers should always listen to their peers and mentors since they have an abundance of knowledge that they have acquired throughout their careers. While law school prepares law students for the practice of law in many ways, there are simply some things that are technique-based that only come with experience. I often wonder what would have happened if I was not warned of a potential strategic objection during my opening statement since we are taught not to object during opening statements unless absolutely necessary and that objections during opening are very rare. Thankfully, I have a good boss/mentor who was able to prepare me in advance and assist me in obtaining an excellent result for our client. Robert J. Kozloski, III, Rob has a boutique complex commercial litigation practice at Graham Legal, LLC, rob@graham.legal www.graham.legal, SynerG Member since August of 2016, https://synerglawcomplex.com/team-members/robert-j-kozloski-iii/
Ellen Malow’s “War Story”: Principles can be very expensive.
A successful trial lawyer for over ten years, Ellen Malow decided over a decade and a half ago to instead use her skill set to help parties create win/win scenarios rather than win/lose results. One of the many lessons Ellen has learned as a seasoned mediator is that principles can be very expensive: By the very nature of the process, each mediation creates a war story. Mediations bring conflicts to the forefront in an effort to obtain resolution. Sometimes it comes from a party who tells their tale. Other times the attorneys create the story through zealous advocacy. Often times there is a war on all fronts. With over 16 years of mediating thousands of cases, there are lots of stories to tell. I have mediated an extensive number of sexual harassment cases and they often have the most salacious facts. Yet, a seemingly benign contract case can turn into something contentious. I recently mediated a case over the purchase of a commercial saw. The saw was rejected by the buyer. It seemed like it would be a simple dispute to settle but by the time of the mediation, the buyer and seller saw the transaction from an emotional standpoint instead of from a business approach. Every demand and offer was hard fought. They argued to the bitter end and when it was resolved, they spent more money on legal fees than the price of the saw. The lesson is that principles can be very expensive. Ellen Malow is an independent mediator and arbitrator and a long-time friend of SynerG Law Complex and often hosts mediations at SynerG’s top-notch facilities. Malow Mediation & Arbitration, Inc. All Sides. One Solution. www.malowmediation.com ellen@malowmediation.com 404-556-0757
Jason Graham’s “War Story”: A tale of two mentors.
Commercial litigator and member, founder, Chief Executive Officer, and Chief Operating Officer of the SynerG Law Complex, Jason W. Graham shared this "SynerG War Story" about two of his mentors who passed within a few days of each other – seven years apart – and shares some of their war stories that shaped his practice, professional development, and life in general: I, like many other lawyers, am blessed to have to credit David Flint to a significant degree with "how I turned out" as a lawyer. He was absolutely brilliant and could talk to anyone from the homeless guy on the street to the Governor or a Supreme Court Justice. He was an "old school" lawyer who would not put up with a lack of professionalism or courtesy despite being a zealous advocate and seasoned litigator. I still tell "David Flint stories” to my own associates as "teaching moments" to this day. His loss is a loss to our entire profession. You can see his obituary here. I remember just a few months into practicing law being called by opposing counsel and being asked for a two week extension to respond to interrogatories, document requests, and requests for admissions that I had worked hard on and sent out 29 days before. Two weeks seemed like a lot back then. I said I wasn’t so sure and would have to talk to my boss. When I asked David if I should grant this huge favor to the enemy counsel of gifting him a two week extension to respond to written discovery, he at first looked aghast, and then he smiled and looked at me and said something to the effect of the following: “Graham, don’t ever ask me a stupid question like that again. You’re a lawyer not a minion. You don’t have to come running to me on these kinds of issues. But more importantly, If someone asks you if they can have an extension, you just say yes, how much time do you need? And then you say okay unless it is more than a month unless they have a good reason. You don’t have to ask me – or the client – it is a matter of professional courtesy. And you will be in the same boat asking for extensions many times, trust me. But never trade days. Never condition your extension on anything. Don’t say I’ll give you two weeks if you do X. And if someone does that to you, just say no thank you and stay up all night and get it done. We don’t allow the taking of hostages in matters of professional courtesy.” I’ve probably re-told the above story to a dozen mentees over the years (always giving credit to David of course). He was an example of how to be a zealous advocate professionally. He passed seven years and just a few days after another great mentor of mine, Dean Booth. Dean’s telling me of “war stories” is what inspired this blog. Like his good friend David, he taught through war stories. So I thought I would post the remembrance of a few of those teaching moments from Dean (that I know he shared with David) that was published in the Fulton County Daily Report seven years ago today CLICK HERE FOR ARTICLE. (btw, here is the original) I have been blessed to have amazing mentors. I actually presented a CLE at the State Bar on the art of mentorship in 2019 and a lot of my material was drawn from what I learned from Dean and David. It was great to relive some of those war stories with some younger lawyers who hadn't heard them yet! Jason W. Graham, Jason has a boutique complex commercial litigation practice at Graham Legal, LLC, jason@graham.legal www.graham.legal, SynerG Member since August of 2016, https://synerglawcomplex.com/team-members/jason-graham/
Vinnie Lauria’s “War Story”: Truth is often stranger than fiction
Plaintiffs’ personal injury attorney and SynerG member Vincent a/k/a “Vinnie” Lauria shared this “SynerG War Story” about what he learned about sometimes just letting witnesses be themselves and giving them plenty of rope to hang themselves: About 15 years ago, Bob, an old high school friend, called me about a criminal matter. It seems that his son Tony, and a fellow fraternity brother (hereinafter "Bro") volunteered to serve as designated "sober-ees" for an on-campus fraternity party at Georgia Tech. Their job was to make sure nothing crazy happened and prevent anyone not on the guest list from entering the party. Everything was fine until about 11:00 pm when a couple of obviously drunk guys approached, wanting to join the party. They were not on the guest list and were asked to leave. Words were exchanged which led to a confrontation and then fisticuffs. Tony quickly dispatched the first inebriant, scoring nicely with a series of hook/uppercut combos, while Bro made short work of the other one with some "Kung Fu" maneuver. The police were summoned and, fortunately, arrived none too soon as a drunk fraternity member had come charging out of the house with a baseball bat looking to get in on the action. The police calmed things down and after a lot of yapping, everyone went home. Tony and Bro’s heroics did not go unrewarded, as a few days later the "beat-ees" filed assault charges against Tony, Bro and the fraternity. At Bob’s request I went down for the preliminary hearing which quickly (and appropriately) took on a "My Cousin Vinny" atmosphere. We called about 4 or 5 witnesses, including Tony and Bro, who waived the Fifth, and also provided the court with the guest list. Opposing counsel got quite animated in his argument, but could not get over the hurdle of his clients being both wasted and belligerent. After about an hour, the court realized that convictions were not likely and dismissed the case. Bob and his wife, Irene, seated a few rows back, let out an audible "whoop" after the court’s ruling. Tony was a senior getting ready to enter the real world and learn how to punch a time-clock. Obviously, a criminal record would require some "splaining" to a prospective employer. (In case you are wondering, no, I did not show up in a burnt orange tuxedo with a ruffled shirt, nor did I refer to Tony and Bro as the "two yutes," although it did cross my mind. To my dismay, the judge did not ask me where I went to law school.) Bob and I talk every so often and this case always comes up in the conversation. Tony is now married, gainfully employed and has a couple of kids. Bro is apparently in the wind – his whereabouts are unknown. By the way, did I mention that Bob is a dentist and I have not had to pay for a teeth cleaning since? Vinnie Lauria has a general plaintiffs’ personal injury practice. His email is vrlauria@hotmail.com.
Jim Ford’s “War Story”: You just never know what the jury is thinking……
Business litigation and personal injury attorney and SynerG member Jim Ford shared this “SynerG War Story” about what he learned about researching your expert witness and judging your jurors during a trial: Several years ago, my college roommate, Dennis Cathey, a lawyer in Cornelia, and I tried a case against a pathology laboratory in Greenville, South Carolina for having allegedly failed to properly screen a Pap smear, resulting in the death of our client’s 32 year old wife from cervical cancer. We had already reached a settlement with the wife’s obstetrician in North Georgia. We fortunately had the assistance of two of the world’s foremost obstetrical pathologists from Duke University as our expert witnesses. They had prepared a visual explanation of why any abnormal Pap smear had to be reexamined by a pathologist regardless of the abnormality. The wife’s Pap smear had been screened by a technician and was classified as negative when it actually showed precancerous lesions. The laboratory did not have a pathologist review the smear. Had the smear been properly screened, there was a 90% plus probability that the lesions could have been eradicated. The defense expert was an obstetrical pathologist from the Medical College of South Carolina in Charleston. The defense expert testified that the smear was actually positive for precancerous lesions but that did not matter because the lesions were glandular in nature and not indicative of cancer. Fortunately, I had done some research on this expert and had discovered a letter that he had written to the American Medical Association in which he exclaimed that any abnormal Pap smear had to be reviewed by a qualified pathologist no matter what the abnormality. The letter had been published in the AMA Journal, and I had it blown up the size of your front door with the relevant statement highlighted. When I put the letter in front of the doctor and the jury on an easel, you could hear a pin drop. I asked the pathologist to please explain his testimony in view of his letter to the AMA. Over strenuous objection, the trial judge directed the expert to answer the question. He responded, “there is not really anything that I can say.” I looked around at our local counsel, Mike Parham, and he drug his finger across his throat. I sat down. Greenville, and for that matter, South Carolina, was then and still is a very conservative jurisdiction. We had two older women as jurors who sat next to one another on the front row of the jury, all the way down next to the jury door, which caused us concern. We found out after the jury had been seated that one of them attended church with defense counsel. South Carolina does not allow wide open voir dire. The defense had offered $150,000.00 in settlement, and that was only made as we were walking into the courthouse to start the trial. The jury came back with a verdict of $3.5 million in the survival part of the case and $1.1 million in the wrongful death part of the case. The trial judge credited the defendant with the $500,000.00 settlement we had made with the Georgia physician. The defense appealed. The South Carolina Court of Appeals affirmed the verdict and added the $500,000.00 back to it because the measure of damages for wrongful death in South Carolina is not the full value of the life of the decedent as in Georgia. After the jury had returned its verdict, I was standing outside the Greenville County Courthouse trying to catch my breath. One of the women on the front row of the jury drove up in her brand-new Buick Riviera, got out of her car and asked me if it was all right if we spoke. I told her sure, the case was over. She then told me that she wanted to give me some advice. “The next time you try a case against that pathology laboratory, ask the jury to require it to post a billboard out on I-85 that says having a Pap smear read there can be dangerous to a woman’s health!” You just never know. At the time, this was the second or third highest verdict in South Carolina for medical malpractice. The other two had also been secured by Georgia lawyers. Jim Ford has a general business litigation and personal injury practice. His email is jlf@jlfordlaw.com.
Alan I. Seitman’s “War Story”: You just never know what a witness will say……
Bankruptcy attorney and SynerG member Alan Seitman shared this “SynerG War Story” about what he learned about witness preparation, listening, and assumptions when he was “less experienced”: Over 30 years ago, as a young attorney, I had the opportunity to represent an entrepreneur who had incurred significant debt in connection with a failed start-up business. Immediately after I filed his Chapter 7 case, a major New York creditor retained a large downtown Atlanta law firm to challenge the bankruptcy. The creditor’s theory was that my client had provided false financial statements when completing his loan application. My client’s deposition and the creditor representative’s deposition were scheduled back-to-back in the Atlanta firm’s office. And, of course, the large firm appeared with a senior partner, an associate and a paralegal. The partner conducted my client’s deposition first. Unfortunately, my client’s testimony revealed some potential errors and misstatements in his financial statements. The partner immediately walked out of the conference room after conducting the deposition…leaving the associate and paralegal to handle the case. The partner either assumed that he had substantially proven his case and/or there was very little a young attorney could accomplish in his absence. I proceeded to conduct the creditor representative’s deposition. And, I asked him a very basic question about the financial statements: “What specific information did the creditor rely upon in extending credit?” To my amazement, the representative testified that he couldn’t answer the question because his primary attorney (the partner) had just left the room, and ultimately, that attorney would make that decision. This testimony basically doomed the creditor’s case because the Atlanta law firm obviously had no part in the loan process and “reasonable reliance” was a key element of their cause of action. The paralegal then left the room, returning about five minutes later with the partner. When I finished my examination, the partner questioned his client on the record and attempted to “clean up” his testimony. Again, to my amazement, the representative repeated his previous testimony and the two of them actually engaged in a rather heated argument…with each other! The objection to the bankruptcy was withdrawn two days later. Morals of the story:
- Always prepare your witness before a deposition or a trial;
- Sometimes simple questions in a deposition reveal surprising answers; and
- Most importantly…don’t underestimate a young attorney.
Jason Graham’s “War Story”: Stand by your man
Commercial litigator and SynerG member, founder, and Chief Executive Officer, and Chief Operating Officer Jason W. Graham shared this "SynerG War Story" about beating a motion to disqualify him and the lessons he learned from it: I have done a fair bit of construction law in my career. A number of years ago, I had a long-time client who was a general contractor who had been stiffed by a property owner. Although he could not afford to pay me to litigate the matter at that time, I had represented him for many years (at a profit) and had developed a strong friendship and loyalty to him. We filed suit and the owner took a number of aggressive, tactical, and absurd positions to delay payment of the amount due under the contract. The owner filed a motion to disqualify me as counsel based upon an alleged conflict of interest because the principals of the corporate defendant had once been in a few meetings where I was representing their ex-partners on a completely unrelated matter. Knowing that my client could not retain other counsel (who would not work on the basis of loyalty and friendship), I called the State Bar to confirm my own ethical compass (and they did) and I vigorously contested the motion to disqualify. DeKalb State Court Judge Wayne Purdom held an evidentiary hearing in which I was the chief witness and he denied the motion from the bench. To me, this case was significant because I took a stand for what I knew was right, followed my ethical instincts, took the risk of public humiliation if I had been disqualified for an unethical conflict, and I prevailed. Ironically, the attorney who frivolously moved to disqualify me now holds public office…..go figure? I learned to always follow my own moral compass – but also to cross check it with the map in the glove box – and to not be afraid to explain the facts to the judge and let the judge decide who was right and who was full of it. Jason W. Graham, Jason has a boutique complex commercial litigation practice at Graham Legal, LLC, jason@graham.legal www.graham.legal, SynerG Member since August of 2016, https://synerglawcomplex.com/team-members/jason-graham/
Bill Bassett’s “War Story”: It ain’t over ’til it’s over!
General transactional lawyer and SynerG member Bill Bassett shared this “SynerG War Story” about learning the difference between "recess" and "adjournment" the hard way back in his litigation days: Back in 1973, as a sole practitioner, I had just started representing the Atlanta Regional Commission, a newly created governmental planning agency, charged with enforcing the Metropolitan River Protection Act. The Act prohibited building new structures within the Chattahoochee River corridor. A property owner had applied to Fulton County for a permit to build a tennis court within the prohibited area. Fulton County intended to issue the permit in spite of the restriction. ARC brought suit to enforce the Act and applied for a temporary restraining order prohibiting the county from issuing the permit. The hearing was before an old school Superior Court Judge, a known curmudgeon, who had been on the bench for many years. He had a history of issuing irregular judicial orders, and was very unpredictable. The County's defense was that the Act was unconstitutional, as being violative of private property rights.
At about 6:30, after arguing all afternoon, I pointed out that Georgia law requires that if a litigant maintains a statute is unconstitutional, the attorney general has to be notified, and allowed to intervene and defend the statute. As an aside, in this particular judge’s courtroom, the judge's bench extended all the way across the courtroom, from one wall to the other. He could move his chair behind the bench from one side of the room to the other, and often did. During counsel's arguments, when he leaned back in his chair, he often disappeared, and you found yourself addressing him at one end of the bench, while he reappeared at the other.
After raising the issue about notifying the attorney general, the judge disappeared behind the bench. We waited and waited, and finally the judge's clerk let us know the judge was in his chambers researching the law. Finally the judge reappeared. He stated that he had studied the law, and it appeared that the attorney general may have to be notified. We discussed the method of notification and other issues. He said he would study it some more and make a final decision in the morning. Then he promptly left the bench.
Bob Young, who was the county attorney, and a good guy, and I just looked at each other. We both assumed we were through for the day.
My client and I decided we would get some libations at the Kimball House Saloon, a prominent drinking establishment on Decatur Street near the courthouse, and make our plans for the next day. Before leaving, I called my office and was told that a bench warrant had been issued for my arrest! The Fulton County sheriff (court bailiff) had called and said the judge had come back on the bench after we left, found we were not there, and had handwritten (on a yellow pad) a bench warrant for my arrest, ordering the sheriff to find me and bring me back to the courtroom. Apparently, the judge had not adjourned for the night after all. I called the sheriff's office, confirmed it, and said I would be right there.
But since I had had the libations, I decided I had best find some breath mints, before making my appearance. I chewed the entire pack. When I got to the courthouse the bailiff advised that my best defense would be to plead ignorance.
Bob was there by then, so we went to the courtroom with the bailiff. It was about 8 PM by then. I followed the bailiff’s advice and profusely apologized to the judge for leaving before being dismissed. Surprisingly, the judge had mellowed by then. He said he had reconvened court in order to ask counsel if either of them had any financial interest in the case. We said no. He then explained the difference between "recess" and "adjournment", and then promptly "adjourned" court.
The lesson I learned is "it ain't over 'til it's over"!
William R. Bassett, Bill has a general civil practice limited to transactional matters.
bill@wbassettlaw.com, SynerG Member since July of 2018, https://synerglawcomplex.com/team-members/bill-bassett/
Kim Rockwood’s “War Story”: What I learned from a bully of an opposing counsel
Estate planner, construction litigator, and SynerG member Kim Knight Rockwood shared this "SynerG War Story" about her final straw with bullying opposing attorneys and the lessons she learned from it: When I was a young lawyer trying construction cases on my own, I was immensely intimidated by opposing counsel who were older, seemingly wiser attorneys who had been practicing law for decades. Not surprisingly, every single one of them was a man (there weren’t as many female first-chair attorneys back then as there are now, thankfully things have changed). Occasionally, I’d go up against an opposing counsel who seemed to relish having a young female as an adversary, almost like a rabid bulldog, drool dripping to the ground. But no one relished it more than one attorney I’ll never forget. From the get-go, he was an incessant bully. On the day I took his client’s deposition - even though we agreed to save our objections until trial - he objected all day long, to distract and scare me. And I admit that it worked. When we wrapped up at the end of the day, we confirmed that the next day’s deposition would be at my office. Then he stepped out of the room, leaving his client sitting at the table. The court reporter was still in the room packing up, my client and I were packing up, and the attorney’s secretary was there, clearing the table of the drink glasses we’d accumulated. His client then asked me for my office address. I told him, but not before the attorney stormed back in the room and accused me of intimidating his client by speaking to him without his being present. He demanded that the court reporter pull all her equipment out and set it up again so he could get it on the record. “It’s 5:10 pm and I want it noted for the record that opposing counsel was speaking to my client outside of my presence!” he practically shouted, staring me down. “Yes, that’s correct,” I responded, not losing eye contact. “His client asked me for the address to my office for depositions tomorrow and I gave it to him. Also present in the room when this happened was the court reporter, my client, and your secretary,” I stated with a little shake in my voice, completely stunned by his accusation. On my way home, I doubted myself. DID I do something wrong? The code of professional conduct says you aren’t supposed to speak to a represented client without his attorney present. Should I have kept my mouth shut, ignored his client’s request, and walked out of the room? When I calmed down, I realized that I did nothing wrong, that HE was wrong by acting so unprofessionally. It was then that I decided I wouldn’t let an older, more experienced attorney intimidate me again. The next morning, he wandered around my office on his own, peeking into my colleague’s offices. When I noticed him, I told him firmly to wait in the lobby. Surprisingly, he complied. He was amicable the rest of the day. But his behavior before that motivated me to work even harder on my client’s case. Even though I’m older and wiser now, I’ll never forget how that lawyer made me feel. He made me doubt my knowledge. He made me doubt my worth and value to my client, and he even made me doubt my career choice. But I’m grateful for him now. I became gritty. I gained self-confidence, even when I was up against a more experienced lawyer. And I never again doubted my ability to practice law and to do it well. And I am happy to report that I ended up winning a summary judgment motion against that attorney and never heard from him again. Kim Knight Rockwood, Kim practices estate planning, small business representation, and construction litigation at Kim Rockwood Law. SynerG Member since March 2019, https://synerglawcomplex.com/team-members/kim-rockwood-esq/
William Dreyfoos’ “War Story”: How a “Chaos Theory” Call Taught Me to Always Take Notes
Senior law practitioner and SynerG member Bill Dreyfoos shared this "SynerG War Story" about an unusual and fascinating phone call early in his legal career that he failed to take any notes about and the lessons he learned from the experience: At the beginning of my career, in the 1980’s, I was an environmental attorney in private practice in Charleston. In addition to handling local concerns involving environmentally sensitive lands and water quality, I was involved in a variety of matters on the national level, such as the early considerations of climate change – so I would get a variety of inquiries from unknown callers, from unexpected places. Late one Friday afternoon, I received the call of my practice, and while I can remember the outlines of it, the call lasted for 20 minutes, and I long ago forgot most of the details. I don’t know who the caller was. He was concerned about climate change, and in particular, the melting of the glaciers in Antarctica. He was not from Charleston, but he called me because I was an environmental attorney there, and he wanted to make sure someone in Charleston knew the story he would tell. I guess so I could help save the Antarctic glaciers. What followed was a convoluted tale that spanned many subjects, connecting them in unexpected ways, touching on climate change, the inter-connectedness of the environment, glaciers, and civic responsibility – none of which I remember. But the upshot came at the end: the reason the glaciers in Antarctica were melting was the ringing of the church bells in St. Michael’s Church in the center of downtown Charleston! Who knew? For those unfamiliar with Charleston, St. Michael’s is one of the buildings at the Four Corners of Law, at the intersection of Broad Street and Meeting Street, built in the 18th and 19th centuries in the very center of historic Charleston. St. Michael’s is the tallest church in the old part of the city, with a white steeple from which the bells ring, and is the oldest and most prestigious church in historic Charleston. It anchors one of the Four Corners – and is said to embody God’s law. The buildings flanking St. Michael’s, on the other 3 corners, are City Hall (city law), the old County Court House (state law), and the Post Office (federal law). The bells of St. Michael’s ring throughout the day, and have measured out the pace of life in downtown Charleston for centuries. Never before had I been aware of any connection between them and the glaciers of Antarctica. But as I sat in my office in downtown Charleston on a Friday afternoon, my caller set out a gift before me. It was the revelation of my entire environmental law practice, and the confirmation of what the people of Charleston have always known: that what happens in Charleston really does control what happens throughout the world! I was amazed. I was amused. And I missed most of it – because I didn’t write it down. Nowadays, there are options for the prudent practitioner: you can record your telephone conversations, you can put the caller on the speaker and free up your hands to type on the computer, or you can use old-fashioned note-taking, either during the conversation, or immediately following it. You don’t have to rely solely on your memory. Unfortunately, that’s what I did. And as the years have fallen away, so has my recollection of the details of the wild ride that starts with the ringing of the bells of St. Michael’s and, through a convoluted sequence of causes and effects, ends with the melting of the glaciers in Antarctica. The bells of St. Michael’s still ring each day. The glaciers in Antarctica continue to melt. And now I know why. But like the Wizard of Oz, I don’t know how it works. So sadly, I have been unable to use the wisdom imparted to me in that call long ago, and my chance to save the Antarctic glaciers was lost. All because I didn’t take notes. And that’s how I became a sadder but wiser practitioner of the law. William W. Dreyfoos, Bill's practice at the Senior Law Services of Georgia, LLC includes a wide range of legal matters confronting aging seniors and their families. SynerG Member since May 2018, www.seniorlawgeorgia.com, https://synerglawcomplex.com/team-members/william-dreyfoos/