Month: January 2024

Monday Morning Answers #291

Michael

Happy Monday! 

Friday’s questions are here. The answers follow today’s Honor Roll.

Honor Roll

ANSWERS

Question 1

Exceptions to this duty include:

  • to respond to allegations in any proceeding concerning the lawyer’s representation of the client;
  • to establish a claim or defense in a controversy between the lawyer and the client; and,
  • to resolve and detect conflicts of interests arising from a lawyer’s change or potential change of employment.

What duty?  CONFIDENTIALITY – V.R.Pr.C. 1.6

Question 2

Attorney contacted me with an inquiry. I listened, then replied: “the rule requires you to keep it in trust until the dispute is resolved.”  Given my response, it’s most likely that:

Question 3

There’s a rule that sets out the conditions under which a conflict of interest can be waived. One condition is when “each affected client gives informed consent, confirmed in writing.”

Fill-in-the-blanks.  Each correct answer is a form of the same word.

A comment to the same rule states:

“Whether REVOKING consent to the client’s own representation precludes the lawyer from continuing to represent other clients depends on the circumstances, including the nature of the conflict, whether the client REVOKED consent because of a material change in circumstances, the reasonable expectations of the other client and whether material detriment to the other clients or lawyer would result.”

V.R.P.C. 1.7, Cmt. [20]

Question 4

Lawyer works at Firm.  Lawyer and Firm have entered into a written employment agreement that requires Lawyer to pay Firm $1000 for every client that follows Lawyer if Lawyer leaves to work somewhere else.  Which is most accurate? 

  • A.  There is no Vermont Rule of Professional Conduct that addresses this issue.
  • B.  The Vermont Rules of Professional Conduct specifically allow this type of agreement, as long as Lawyer’s payment to Firm does not increase the fee charged to a client who follows Lawyer.
  • C.   Whether the agreement is enforceable will likely turn on an analysis of the Vermont Rule of Professional Conduct that prohibits lawyers from making agreements that restrict their right to practice law.  See, this blog post.
  • D.  Whether the agreement is enforceable will likely turn on an analysis of the rules that govern conflicts of interest.

Question 5

Competence? Threatening criminal prosecution?

In a fictional work published in 1600, Portia was not a lawyer.  However, during a trial central to the plot, she pretended to be both a man and a lawyer.  She “represented” Antonio in a contractual dispute with Shylock.  Shylock had loaned money to Antonio.  When Antonio did not repay the money, Shylock sought the remedy specified in the contract.

Portia asked Shylock to accept recompense other than as stated in the contract – first suggesting that he show mercy to Antonio, next offering to pay Shylock 3 times what Antonio owed.  Still, Shylock refused, insisting that he receive the contractual remedy.

In the end, Portia prevailed, pointing out that the while the contract provided a specific remedy, it did not give Shylock the right to take even a drop of Antonio’s blood. Indeed, the evidence suggests that Portia threatened Shylock with criminal prosecution in order to gain an advantage in the civil matter.

What’s the well-known phrase that, per the contract, was Shylock’s remedy for Antonio’s failure to repay the loan?  POUND OF FLESH

Bonus: what’s the title of the fictional work?  THE MERCHANT OF VENICE

Five for Friday #291

Michael 4 Comments

Welcome to Friday and the 291st legal ethics quiz!

Back in the early days of the quiz, I was more creative than I am now. More often than not, I’d find a clever way to tie the intro to the quiz number.  When that wasn’t possible, I’d figure out how to relate the intro to the date.  It’s been ages since I’ve done either. It’s time for that to change.

Alas, not this week.

Onto the quiz!

Rules

  • None.  Open book, open search engine, text-a-friend.
  • Exception:  Question 5.  We try to play that one honestly.
  • Unless stated otherwise, the Vermont Rules of Professional Conduct apply.
  • Please do not post answers as a “comment” to this post.
  • E-mail answers to michael.kennedy@vermont.gov
  • Team entries welcome, creative team names even more welcome.
  • I’ll post the answers & Honor Roll on Monday,
  • Please consider sharing the quiz with friends & colleagues.
  • Share on social media.  Hashtag it – #fiveforfriday.

Question 1

Exceptions to this duty include:

  • to respond to allegations in any proceeding concerning the lawyer’s representation of the client;
  • to establish a claim or defense in a controversy between the lawyer and the client; and,
  • to resolve and detect conflicts of interests arising from a lawyer’s change or potential change of employment.

What duty?

Question 2

Attorney contacted me with an inquiry. I listened, then replied: “the rule requires you to keep it in trust until the dispute is resolved.”  Given my response, it’s most likely that:

  • A.  A client whose advance payment Attorney had yet to earn filed a disciplinary complaint against Attorney.
  • B.   Attorney was duped by a trust account scam.
  • C.   Attorney was selected for a trust account audit.
  • D.   Someone other than Attorney’s client had asserted an interest in funds Attorney is holding for client.

Question 3

There’s a rule that sets out the conditions under which a conflict of interest can be waived. One condition is when “each affected client gives informed consent, confirmed in writing.”

Fill-in-the-blanks.  Each correct answer is a form of the same word.

A comment to the same rule states:

“Whether ________ consent to the client’s own representation precludes the lawyer from continuing to represent other clients depends on the circumstances, including the nature of the conflict, whether the client ______ consent because of a material change in circumstances, the reasonable expectations of the other client and whether material detriment to the other clients or lawyer would result.”

Question 4

Lawyer works at Firm.  Lawyer and Firm have entered into a written employment agreement that requires Lawyer to pay Firm $1000 for every client that follows Lawyer if Lawyer leaves to work somewhere else.  Which is most accurate? 

  • A.  There is no Vermont Rule of Professional Conduct that addresses this issue.
  • B.  The Vermont Rules of Professional Conduct specifically allow this type of agreement, as long as Lawyer’s payment to Firm does not increase the fee charged to a client who follows Lawyer.
  • C.   Whether the agreement is enforceable will likely turn on an analysis of the Vermont Rule of Professional Conduct that prohibits lawyers from making agreements that restrict their right to practice law.
  • D.  Whether the agreement is enforceable will likely turn on an analysis of the rules that govern conflicts of interest.

Question 5

Competence? Threatening criminal prosecution?

In a fictional work published in 1600, Portia was not a lawyer.  However, during a trial central to the plot, she pretended to be both a man and a lawyer.  She “represented” Antonio in a contractual dispute with Shylock.  Shylock had loaned money to Antonio.  When Antonio did not repay the money, Shylock sought the remedy specified in the contract.

Portia asked Shylock to accept recompense other than as stated in the contract – first suggesting that he show mercy to Antonio, next offering to pay Shylock 3 times what Antonio owed.  Still, Shylock refused, insisting that he receive the contractual remedy.

In the end, Portia prevailed, pointing out that the while the contract provided a specific remedy, it did not give Shylock the right to take even a drop of Antonio’s blood.

Portia provided competent representation!

But wait, the evidence suggests that Portia threatened Shylock with criminal prosecution in order to gain an advantage in the civil matter.

Portia violated the rules!

Anyhow, what’s the well-known phrase that, per the contract, was Shylock’s remedy for Antonio’s failure to repay the loan?

Bonus: what’s the title of the fictional work?

Do employment agreements that require a departing lawyer to compensate the firm for clients that follow the lawyer violate the Rules of Professional Conduct?

Michael 1 Comment

Here’s today’s issue:

  • Can a law firm ethically require a departing lawyer to compensate the firm for clients that go with the departing lawyer?

It’s an issue I’d never considered until yesterday, when a regular reader alerted me that the Colorado Supreme Court had recently addressed it.  The tip led me to finding this opinion, as well as the ABA Journal’s article about the opinion.

Here’s what happened.

Per the opinion, in 2019, and while employed at Firm, Lawyer

  • “signed a ‘Reimbursement Agreement’ that required him ‘to reimburse [Firm] for marketing expenses related to any client, case or active matter’ that left the firm and followed him. Recognizing that ‘actual expenses may be difficult to determine,’ the agreement provided that ‘historic costs directly related to marketing expenses’ for each client of the Denver office were $1,052. Thus, for each client who chose to continue being represented by [Lawyer] the agreement required him to pay [Firm] $1,052, whether or not there was evidence that [Firm] had expended marketing funds on that client. If [Lawyer] did not pay the total amount owed under the agreement within thirty days of departing the firm, he would owe interest accruing at a rate of 1.5% per month (18% per year) on any unpaid amounts.”

Five months after signing the agreement, Lawyer left Firm.  18 clients went with Lawyer.  Firm demanded payment pursuant to the Reimbursement Agreement.  According to the opinion, “[w]hen [Lawyer] refused to pay, the firm sued for breach of contract. At trial, both parties asked the court to determine whether the agreement was enforceable under Rule 5.6(a).”

A few paragraphs ago, you might have been asking yourself “Self, is there a rule on that?”  Now you’re probably asking “Self, what’s Rule 5.6?” 

Fear not! I’m here to help.

But for the title, Colorado Rule of Professional Conduct 5.6 is identical to Vermont’s.[1]  Here, V.R.Pr.C. 5.6 is titled “Restrictions on Right to Practice.”  It prohibits a lawyer from participating “in offering or making

“(a) a partnership, shareholders, operating, employment, or other similar type of agreement that restricts the right of a lawyer to practice after termination of the relationship, except an agreement concerning benefits upon retirement; or

(b) an agreement in which a restriction on the lawyer’s right to practice is part of the settlement of a client controversy.”

Ater a trial and an intermediate level appeal, the Colorado Supreme Court “granted certiorari to determine whether (1) a firm may ever contractually require a departing lawyer to pay a per-client fee for each client the lawyer takes with them and (2) if so, how to determine the reasonableness of such an agreement.”

The Court began its analysis by noting a jurisdictional split in opinion. 

First, the Court stated that “[t]he majority view . . . holds that any contractually imposed financial burden on an attorney’s professional autonomy violates the rule.”[2] (emphasis in the original). 

Next, the Court explained that “[t]he minority view

  • “does not treat financial disincentives to departure and competition as per se violations of Rule 5.6(a). Instead, these cases evaluate agreements for whether they represent a reasonable balance between client choice and attorney autonomy on the one hand and a firm’s interest in financial and practice stability on the other.”[3]

In the end, the Colorado Supreme Court adopted the minority view.  More specifically, the Court held “that the reasonableness inquiry is the appropriate approach to assessing whether a particular financial disincentive imposed on a departing lawyer constitutes a restriction on the right to practice.” The Court went on to conclude “that an undifferentiated fee assessed for each client who chooses to follow a departing lawyer violates Rule 5.6(a).”

I understand that block quotes can be a pain to read and, at times, reflect a lazy blogger.  However, here, I think the Colorado Supreme Court’s reasoning is important.  The Court wrote:

  • “An agreement that requires a lawyer to pay a former firm such an undifferentiated fee is fundamentally at odds with the twin policy goals of Rule 5.6(a): to protect lawyers’ professional autonomy and to ensure that clients have the freedom to choose an attorney. As the Ethics Advisory Committee of the Arizona Supreme Court recognized when considering a similar agreement, it ‘acts as a substantial disincentive for the departing lawyer to agree to continue representing a client who wants to continue working with that lawyer.’ Of particular concern, such a fee forces attorneys to make individualized determinations of whether a client is ‘worth’ retaining and incentivizes them to retain clients in high-fee cases and to jettison clients with less lucrative claims. This direct intrusion on the attorney-client relationship is quite different from financial disincentives that might indirectly affect client choice by making it more costly for an attorney to leave a firm. No reasonableness analysis is needed to determine that per-client fees of the sort at issue here violate Rule 5.6(a).” (citations omitted).

Nevertheless, the Court went on to note that:

  • “there could be circumstances that justify a firm seeking reimbursement of particular costs that it incurred for or expended on a client. If, for example, the firm had advanced litigation costs for a client or expended unusual funds to attract a particular client, it might be reasonable and consistent with Rule 5.6(a) to expect the exiting lawyer to reimburse those costs.”

However,

  • “[b]ecause we are not presented here with any client-specific cost scenario, we need not (and do not) decide the questions such a scenario might present. What we do conclude is that a fee of the type imposed here—one based not on specific spending for a client but imposed without any individualized assessment of every client who wishes to maintain an attorney-client relationship with a departing attorney—violates Rule 5.6(a).” [4]

Again, until yesterday, I’d never thought about the ethics of contractual provision like the one at issue in the Colorado case. However, forced to do so, I’d guess that such provisions might exist in agreements between Vermont law firms & lawyers.

If so, to the extent that Vermont might adopt the majority view, such provisions should give pause. On the flip side, if you are a lawyer who has signed such an agreement, don’t count on it being unenforceable. The possibility remains that Vermont adopts the minority view and enforces agreements that strike a reasonable balance “between client choice and attorney autonomy on the one hand and a firm’s interest in financial and practice stability on the other.”

As always, let’s be careful out there.

[1] To be clear, this post is educational and should be taken in that vein.  I am not offering guidance or a prediction on how Disciplinary Counsel, a hearing panel, or the Vermont Supreme Court would interpret Rule 5.6’s applicability to a Vermont agreement similar to the agreement at issue in the Colorado opinion.

[2] According to the opinion, the majority view is followed in [at least] New Jersey, Nebraska, Connecticut, Virginia, Tennessee, Iowa, and New York.

[3] According to the opinion, California and Arizona employ the minority view.

[4] The Court went on to hold that, as a matter of public policy, an agreement that violates the Rules of Professional Conduct is not enforceable.

Related Posts

Other Resources

Wellness Wednesday: Practicing Gratitude Can Improve Your Well-Being

Michael 1 Comment

In last Friday’s post, I shared my resolution to express gratitude more often in 2024. I included a link on how to do so that is not directly related to the legal profession. Today, I write to follow-up with a message from a lawyer regarding Friday’s column, as well as to share a link to a blog post on practicing gratitude by two attorneys who are among the leading voices on lawyer well-being.

Practicing gratitude can be difficult. Both as lawyers and in our personal lives, we often find ourselves in situations where it is hard to discern anything for which to be thankful.

But remember – you can do hard things 

Indeed, one Vermont lawyer is practicing what I preached. Here’s the lawyer’s response to the thoughts I shared last week on gratitude:

  • “I love the reminder about gratitude! I’ve been thinking about that topic myself. Lately, when I’m complaining about something in my head and notice I’m doing it, I stop complaining and think, ‘Thank you.’ I don’t yet know what I’m thankful for – I just say it. Then something pops into my head, usually a reverse of whatever I’ve been complaining about in my head. For example, I was grumpy about going to work recently, and I was thinking, ‘I don’t want to go deal with other people’s problems.’ I noticed the grumbling and then thought, ‘Thank you.’ Then, after I thought thank you, this popped into my head: ‘Thank you that I have a job that matters. Thank you that I can help people with things they really need. Thank you I get to serve my community.’ It sounds hokey, but it’s often quite effective.”

I love it!  And it is NOT hokey! Indeed, when it comes to employing strategies to improve well-being, NOTHING that is effective is hokey. 

Rebecca Howlett and Cynthia Sharp are lawyers who together founded The Legal Burnout Solution.  Their website is a fantastic resource for material related to well-being in the legal profession. (Full disclosure: last September, Becky and Cindy had me as a guest on their podcast. It’s here.)

In December of 2022, the ABA Journal published The Legal Burnout Solution: How to Improve Well-Being Through Gratitude. In the article, Becky and Cindy provide an overview of the “several realms in which scientists have shown the correlation between a gratitude practice and positive outcomes on our physical and mental health.” They go on to provide tips on “cultivating gratitude.”  I recommend reading the post and considering whether to take up (or maybe add to those you already employ) even one of the suggested practices. As Becky and Cindy conclude:

  • “As you do these gratitude practices, notice how your body and mind feel and focus on feelings of appreciation and thankfulness for all the blessings and abundance in your life. Strive to take this feeling and state of being with you as you go on with your day or drift off to sleep. Even instituting one of these practices on a consistent basis can lead to significant, positive effects on your overall health and well-being.”

Might it be hard?  Yes.  But again, you can do hard things.

As always, let’s be careful out there.

PS:  We’re almost up to 50 legal professionals who have taken The Well-Being Pledge.  To join them, all you have to do is email me!

Related Posts:

Five for Friday #290

Michael 4 Comments

Happy First Friday of 2024!

Don’t worry – on the occasion of the 290th quiz, I’m not going to list 290 New Year’s resolutions.  Honestly, I’ve never been much for resolutions, no matter the time of year they’re made. That said, one has been on my mind this week.

Researching a potential wellness post, I learned that many experts suggest resolving to show more gratitude in 2024.  This post from Mindful not only shares tips on how to do so, it highlights the benefits of the practice. 

With that in mind, thank you! I am grateful for every person who has reached out to me since my diagnosis. Each and every card, text, email, phone call matters, with every single message adding to the inspiration to fight.

Moreover, they’re working.

A few weeks ago, I had my first scan since chemo started.  The tumor is smaller and far less involved with a key artery than it used to be.  My surgical oncologist is super optimistic and believes that Whipple Surgery will be possible after three more cycles of chemo and 5 weeks of radiation.  

Earlier this week I met with a radiation oncologist. It was a bit more sobering than the post-scan visit with the surgeon. But only because the RO’s job includes doing what I so often urge lawyers to do: provide straightforward legal advice even if it might be unpalatable to the client. On the positive side, even after having to give me an honest accounting of the statistics related to my diagnosis, the RO remains cautiously optimistic that radiation will (1) provide the surgeon with the buffer needed to safely remove the tumor without nicking the key artery, and (2) kill any cells that may have started to migrate to other areas of my body. (Although, to date, there is no evidence of metastasis.)

I’m a firm believer in the power of prayer and positive vibes. So many people who read this blog have sent either or both. You have no idea how much you’ve helped me.  As positive as I try to keep my approach, there are moments of doubt. In those moments, you’ve propped me up. And for that, I am forever grateful.

I wish I could express my gratitude in a manner more befitting of the scope of the support you’ve provided. I can’t.

Still, thank you. It means the world to me.

Here’s to a healthy 2024!

Onto the quiz!

ps: know the signs, get checked.

Rules

  • None.  Open book, open search engine, text-a-friend.
  • Exception:  Question 5.  We try to play that one honestly.
  • Unless stated otherwise, the Vermont Rules of Professional Conduct apply.
  • Please do not post answers as a “comment” to this post.
  • E-mail answers to michael.kennedy@vermont.gov
  • Team entries welcome, creative team names even more welcome.
  • I’ll post the answers & Honor Roll on Monday,
  • Please consider sharing the quiz with friends & colleagues.
  • Share on social media.  Hashtag it – #fiveforfriday.

Question 1

Lawyer called me with an inquiry. In my response, I urged the Lawyer to consider “3-way reconciliation.”  It’s most likely that Lawyer called to discuss:

  • A.  A conflict that arose between an insurance company and the insured.
  • B.  A conflict that arose when representing both spouses in a collaborative divorce.
  • C.  A conflict that arose when representing both buyer & seller in the same transaction.
  • D.  Trust account management.

Question 2

Client files a disciplinary complaint against Lawyer. The complaint is screened and referred to Disciplinary Counsel for an investigation. Lawyer calls me and asks whether it would be okay to refund Client’s fee in exchange for Client’s agreement to withdraw the complaint. Most likely, my reply will be:

  • A. Good idea, as long as you advise Client to seek independent legal advice about the proposal.
  • B. Good idea, as long as you give Client a chance to discuss the proposal with disciplinary counsel.
  • C. Bad idea.
  • D.  It depends. What does Client’s complaint allege that you did?

Question 3

Do the Vermont Rules of Professional Conduct specifically prohibit a lawyer from asking a client to waive a conflict that might arise in the future?

  • A.  Yes. And a comment to the rule indicates that “it is not possible for a client to give informed consent to waive a conflict that has not yet arisen.”
  • B.  No.  And a comment to the rule indicates that “the effectiveness of such waivers is generally determined by the extent to which the client reasonably understands the material risks that the waiver entails.”

Question 4

Attorney represents Client.  Attorney knows that Opposing Party is represented by counsel. Client informs Attorney that Client intends to discuss resolution of the matter directly with Opposing Party.  Client asks for advice on framing the discussion.

May Attorney provide the advice?

  • A.  Yes, without limitation.
  • B.  Yes, but only after informing Opposing Party’s lawyer that Client intends to communicate directly with Opposing Party.
  • C.  Yes, but most bar counsel types believe that Attorney should not “script” the conversation or advise Client “to parrot” Attorney’s words.
  • D.  No.

Question 5

In September, I presented a CLE for a group of Intellectual Property lawyers. The practice area is probably the one in which I feel most incompetent to present.  

That said, IP law often intrigues & entertains me.  For example, here’s my post on Taco Bell’s petition to cancel  another restaurant’s “Taco Tuesday” mark.  More recently, the ABA Journal has this article about the law firm that filed a motion to dismiss on behalf of a client, copyrighted the motion, and then sued the firm that represents a co-defendant for copyright infringement.  The first firm alleges that the second filed a motion to dismiss that has a “striking resemblance” to and repeats “nearly verbatim” the copyrighted motion. 

Yes – you read that correctly. A law firm copyrighted a motion that it filed.

Anyhow, over the years, I’ve managed to pick up some of IP Law’s basic terms. One is “public domain.”  Generally, material that isn’t protected by copyright, mark, or patent is in the “public domain” and free for anyone to use.

This week, a gigantic corporation’s copyright expired.  The copyright was to a famous character who was introduced in a short film that debuted in 1928. As a result, the character (at least as depicted in the short film) is now in the “public domain.”  According to one report, since the copyright expired, a trailer for a horror movie featuring the character has been released and “digital creators” have edited the short film to make it appear as if the character is swearing.

Name the character and the short film in which the character was introduced.

DC advisory opinion offers guidance on advising a client on direct communications between the client and a represented adversary.

Michael 1 Comment

Today I write to share the DC Bar’s Ethics Opinion 385: Advising Clients About Communications With Represented Opponents.[1]  While not an issue that comes up a lot, I received a handful of inquiries on the topic last year.  I suppose such inquiries will continue to be made as more & more litigants go without representation.

Disclaimer: I’m not ducking the question. However, this post should not be construed as me adopting the DC Bar’s conclusion and suggesting that Vermont’s version of the no-contact rule will be interpreted the same way.  That’s not my proper role.  Further, no matter what I think, my opinion is not binding on Disciplinary Counsel, the PRB’s hearing panels, or the ultimate arbiter of the scope of the Rules of Professional Conduct, the Vermont Supreme Court.

No, today I post to highlight three aspects of the DC opinion with which I agree 100%.  But first, some background.

Rule 4.2 is the so-called “no contact” rule.  It states:

  • “In representing a client, a lawyer shall not communicate about the subject of the representation with a person the lawyer knows to be represented by another lawyer in the matter, unless the lawyer has the consent of the other lawyer or is authorized to do so by law or a court order.”

In Vermont, Comment [4] includes this sentence:

  • “Parties to a matter may communicate directly with each, other and a lawyer is not prohibited from advising a client concerning a communication that the client is legally entitled to make.”

At CLEs and in response to inquiries, I’ve been clear.  In my opinion, while the comment allows a lawyer to advise a client on a communication that the lawyer knows the client will make to a represented person, the lawyer should avoid “scripting” the communication or advising the client “to parrot” the lawyer’s words. I’ve not gone further than that.

Back to the DC opinion. As mentioned, it includes three aspects with which I completely agree.

The first relates to competence.  As has been stated often in this space, a lawyer is required to provide competent representation to a client.  The DC opinion reminds lawyers that there are situations in which competence necessarily includes not only advising the client to communicate directly with a represented adversary, but also advising the client about the nature and content of the communication. 

Further, having often cautioned against “scripting” and “parroting,” I was pleased to find the following paragraph in the DC opinion:

  • “The lawyer may not, however, attempt to script the communication or coach the client to handle the communications as the lawyer would. The point of encouraging the parties to speak directly to one another is to use the dynamics between them, and their own voices, to find common ground. When the lawyer’s level of assistance in preparing for these communications turns the client into the lawyer’s surrogate, it has gone too far.”

Related, I’m also a fan of the DC Bar’s conclusion that:

  • “Participation in party-to-party communications is limited to the parties themselves unless counsel for one party has sought and received the opposing counsel’s consent to attend. This means that it is not permissible for a lawyer to provide advice or commentary to [the} client while a communication is being conducted – even though technology would permit real-time monitoring and correspondence via email, text, chat, or any other means between the lawyer and the client. This bar on participation includes a bar on silent attendance or observation, in-person, telephonically, virtually, or remotely. Even if a lawyer plans to remain silent, and not communicate with either party, [the lawyer] should not attend a party-to-party communication.”

I’ll stop.

While I’ve made clear that I agree with the aspects of the opinion I mentioned above, the failure to mention other aspects of the opinion should not be construed as disagreeing with them. Rather, on this particular topic, I encourage anyone interested to refer directly to the DC opinion or to contact me to discuss a specific situation you might be facing.

As always, let’s be careful out there.

RELATED POSTS

[1] I also write because I’m fairly confident I’ll post a quiz tomorrow. The quizzes are great but should probably not be the only content ever to appear on this blog.