Modern Family Matters

Get the Inside Scoop! Attorney Tips on How to Best Prepare for a Family Law Mediation

March 11, 2022 with Caryn Jones Season 1 Episode 48
Modern Family Matters
Get the Inside Scoop! Attorney Tips on How to Best Prepare for a Family Law Mediation
Show Notes Transcript

Join us as we sit down with attorney, Caryn Jones, to discuss how divorcing spouses can adequately prepare for mediation in order to reach agreements on issues that need resolution in order to finalize a divorce, such as child custody, parenting time, child support, spousal support and property division. In this interview, Caryn addresses the following:

•    What is Mediation?
 •    Is Mediation Legally Binding, Expensive, or Public?
 •    Do I Need a Lawyer, and How Do I Choose a Mediator?
 •    Is Mediation the Answer for Everybody?
 •    How Should I Prepare for Mediation, and What Documents/Information Will be Needed?
 •    How Can I Shift My Mindset from Winning to Working it Out?
 •    I Know That I Have Emotional Triggers – How Do I Prepare for That?
 •    On The Day of the Mediation, How Do I Act - What Do I Need to Make Sure I Do?
 •    …and much more! 

If you would like to speak with one of our family law attorneys, please call our office at (503) 227-0200, or visit our website at

Disclaimer: Nothing in this communication is intended to provide legal advice nor does it constitute a client-attorney relationship, therefore you should not interpret the contents as such.

Welcome to Modern Family Matters, a podcast devoted to exploring family law topics that matter most to you. Covering a wide range of legal, personal, and family law matters, with expert analysis from skilled attorneys and professional guests, we hope that our podcast provides answers, clarity, and guidance towards a better tomorrow for you and your family. Here's your host, Steve Altishin.

Steve Altishin  0:31  
Hi, everyone. I'm Steve Altishin, Director of Client partnerships here at Pacific Cascade Family Law. And today, I'm here with attorney Caryn Jones to talk about mediation in family law cases and how to prepare for them. So how're you doing, Caryn?

Caryn Jones  0:49  
I'm doing great, Steve this morning.

Steve Altishin  0:52  
So before we just jumped into this one, tell us a little bit about yourself. I know you have a history with mediation. 

Caryn Jones  0:59  
Sure. So my name is Caryn, as you said, I am an attorney. I've been an attorney in Oregon since 2009, and I additionally have gone through, oh gosh, probably 60 hours of basic mediation and advanced mediation training in family law. And so, I've done the "Woody Moston Mediation Training", if you don't know him, he is an amazing mediator who does a really great training. So, I everything I know I learned from Woody. And,  previous to coming to Pacific Cascade, I worked as a mediator and did family law mediations primarily with pro se parties or unrepresented parties.

Steve Altishin  1:46  
Well, then, that's perfect. This is going to be great. So Karen, let's just start with a basic question. What is mediation?

Caryn Jones  1:56  
That's a very good question. So mediation is a process by which the parties come in and meet with a neutral third party whose job is to assist them in coming up with a mutually acceptable resolution. So the mediator is neutral, which means they're not giving either party legal advice. So that's a big difference from if each party is working with a lawyer or if one party's working with a lawyer and having things drafted and sent to the other party. In mediation, the mediator is neutral as to the results. And like I said, not giving advice to either party, so they can give information. So for example, when I'm a mediator, I can let the parties know what the court is looking at, just in general, when they're looking at custody and parenting time cases where I can give them information about how child support is calculated or spousal support factors, but I'm not advising either party. So that's the biggest difference.

Steve Altishin  3:01  
So, do mediations always end up in a settlement, but they are forced to settle?

Caryn Jones  3:07  
No. No one's forced to settle. And mediation, the entire mediation process is voluntary, with a little asterisk, because the court is going to require everyone to at least attempt some form of alternative dispute resolution like mediation. So, beyond just showing up and checking that box and letting the court know, "hey, we've appeared for mediation and given it a try," everything else is voluntary. So, if one party says I no longer want to participate, mediation is done. And its coming to a conclusion is also voluntary. So, if one party ends the mediation or you're not able to resolve everything, then you would proceed with your case through either court or through your attorneys continuing the negotiations.

Steve Altishin  3:53  
Got it. So, let's say we do come to an agreement. We sat there when we were in your office, we came to an agreement. Is that legally binding? Do we have to have to stick with it? 

Caryn Jones  4:05  
Well, probably. If you come to a mediated agreement, and your mediator drafted it up and both of you sign it, then that would be an enforceable settlement that if one of you decided to go back on, the other party could then take that signed mediated agreement into court and have it enforced by the court. It's not a judgment. So, it's not immediately enforceable by contempt of court or anything like that, but it is an enforceable settlement agreement. The other thing to note is that every other part of mediation is confidential. And so, when you come into mediation with your soon to be ex spouse, you should feel free to raise the issues that are concerning to you, or provide information that you may or may not want brought up later in court because it's all confidential, and the purpose is that the court wants to encourage parties to settle. And so, we want it to be confidential. So people feel comfortable making concessions or making offers that are less than what they may offer if they ended up in court, knowing that that's not going to be brought up and used against them later in a trial. You can't come into trial and say, "well, hey, they offered this in mediation, and I want that," because all of that's going to be confidential.

Steve Altishin  5:23  
That also makes sense. So, I know a lot of people ask this question...

Caryn Jones  5:27  
I kind of went off on a tangent of confidentiality. 

Steve Altishin  5:31  
No, that's wonderful. Because it's sort of in line with a lot of the legal rules about negotiation. I mean, people aren't going to negotiate if they're going to come back later and have someone say, "well, he said this and that." 

Caryn Jones  5:46  
They totally filter to make this a confidential central settlement proposal, but the entire mediation process is protected.

Steve Altishin  5:55  
Can anybody look in it? I mean, is it a public record then, or not?

Caryn Jones  6:02  
No, it would not be a public record. And, even if you subpoenaed the mediator to trial, the only thing they can really say is whether or not you reached an agreement and what the final agreement was. So, when I mediate with people, I let them know everything we say here, any agreements that we are considering, it's all going to be confidential. The only thing that you can ever bring into court later is going to be that final mediated agreement, if both of you sign it.

Steve Altishin  6:32  
Got it. So how expensive is mediation?

Caryn Jones  6:37  
I would say it varies widely, like any divorce case. And so, some people will spend hours in mediation before they're able to come up with a result. Some people are able to come into mediation, having a basic framework of what they think might be fair they're able to come up with the final result more quickly. Most mediators bill hourly, like attorneys, but the parties are sharing the costs. So, you're paying your mediator likely about 300 to 350 an hour, each person's going to pay their half or sometimes people choose to just take that out of the property division. So it's jointly paid from funds from the property that you're going to be dividing up in your divorce. Overall, mediation is generally a much less expensive way to resolve your divorce than litigation. Obviously, we all know trials can get very expensive. And, even if each of you have an attorney during mediation, or on the side, and you're coming into mediation without your attorneys, it's still overall, the total cost is going to be a lot less than if you were to just go into court and have a judge resolve everything for you. I would say most people in a mediated divorce are going to spend probably $3000 to $5000 on average, and then that would be split between the two parties. So, as I go over more than... 

Steve Altishin  8:02  
It sounds like it could be more than one day, sounds like the meetings aren't necessarily just okay, you come in, you're here for x hours, we either get it done or you're gone?

Caryn Jones  8:11  
Well, yes. So I think there's a wide range of time commitment as well. So I'll just dive into the different options for mediation. Stop me if you want me to answer something different. So, some people mediate with a mediator and don't have attorneys. And so, that generally was what I did when I was leading. So I was the mediator, each party would just come into my office, and we'll usually do about a two to three hour session at a time. If we need more time, the parties would come back a week or two later, do another session until we get to the end. So some people need one to two sessions, some people would need four to five sessions. And so, it really just depends on the parties and how quickly they're able to come to a resolution. The other option is, usually the mediator will do it with represented parties. So each party has an attorney who's advising them and advocating for them, and they all come to mediation. And usually what that looks like is, you've hired the mediator for the day, you're all going to be there for probably eight to 10 hours. It's a very expensive day because each person's paying their own attorney as well as half of the mediator's cost. But again, the the cost of that very expensive day is a lot less than a day at trial. So still, you're probably coming out ahead if you're able to come up with a mediated agreement, even if you have your attorneys there. So that's kind of the two most common options.

Steve Altishin  9:40  
That makes total sense. So is mediation. The answer for everybody is how do I know if mediation is right in my case? 

Caryn Jones  9:55  
Well, I think, again, the court is going to require pretty much everyone to mediate with the exception being if there's a restraining order. Some mediators are comfortable mediating, even if there is a restraining order. We would just have to make accommodation so that the parties aren't violating that restraining order. If there's domestic violence in your relationship, or any kind of power dynamics that are concerning, that can affect each party's ability to negotiate. So if that's the case, if you want to mediate and you have concerns about domestic violence, it generally makes more sense to do the kind of mediation where you have an attorney so that you have  someone there to advocate for you, and to kind of have that barrier if there's been domestic violence in the relationship. So that would be one consideration. I don't think it means you can't mediate, it just means you need to take additional steps to make sure that each party is safe and able to negotiate properly. Other than that, I think everyone should at least give it a try. It's a great way to resolve things, especially if there's children involved. You know, a trial can damage the co-parenting relationship for years, if not forever. And so, it can really help people who are going to have to deal with each other for the next 18 years or less, so that you're able to have a functional co-parenting relationship going forward.

Steve Altishin  11:32  
Good practice for trying to work things out the next 20 years.

Caryn Jones  11:35  
It's true. There's going to be ongoing things you have to resolve after the divorce if you have kids. And then when you have a parenting plan, I think that a lot of times, people are a lot more likely to stick to a parenting plan and abide by the rules if they have agreed to them, versus if they've been imposed on them by a judge, and they're upset about the result. So that can also be a benefit to co-parents for the rest of their co- parenting relationship.

Steve Altishin  11:37  
Oh, yeah. So do I have to agree on everything? Can we agree on XY and Z and not on ABC and go from there?

Caryn Jones  12:23  
Absolutely. You don't have to agree on everything. You can come into mediation and resolve your parenting plan, but say, "hey, we still can't agree on custody and child support. And so, we're going to need to go to court on those or continue working with our attorneys on those." What I usually tell people, either as an attorney or as a mediator is, the more that you can settle outside of court, the better. So even if we can only settle 2 out of 10 issues, that's going to make a difference in the amount of time your attorney needs to spend on trial. And so, it's always worth giving it a try and agreeing to whatever you can.

Steve Altishin  13:01  
So you convinced me, I decided to use mediation. How do I start? I mean, what do I need to put together to get prepared for what I've got to go out and find?

Caryn Jones  13:15  
I mean, the more information you have, the better I think that applies in mediation or with your attorney. The more organized you can be. Oregon has a lot of required discovery. So the more that you have of that the better, because then oftentimes we'll start with a mediation, and we'll get into some financial details, and the parties don't have all of the information available. And so we say, "okay, this is all we can do today,  go find those answers, figure out what's in those accounts or where those things are, and then we'll come back once we have more information." So that's knowing what's in every bank account, and all of those kinds of things. What people's incomes are. What your taxes are. The more information you have, the better your mediator's going to be able to help you, especially on financial issues.

Steve Altishin  14:08  
And the less money you're gonna spend on your mediator. If you don't have to come back again, after you've gathered stuff.

Caryn Jones  14:15  
Or your attorney. It applies for mediation or with your attorney. Generally, when parties come into mediation with an attorney, the attorney's have kind of done all of that work that needs to be done. So they should come in a little more prepared. If people are representing themselves, they may show up to mediation not knowing what they need, or not knowing all of the details of the finances. And sometimes, something we have to work on in mediation is letting people know hey, "here's the discovery statutes. Here's *****what you do have to provide to the other party and so you're going to need to be able to provide that if either of you needs that information, and then they can go get that information and exchange

Steve Altishin  14:55  
it in your mediation Experienced? Do you ever see spouses who are kind of coming to you to say, Look, we're not, we don't hate each other. We just need to get this divorce. And you know, can you know? What can we do to work together to get ready for the mediation? I mean, is there is there there's that? Uh, no, no? Or is that something that you would maybe encourage?

Caryn Jones  15:24  
No, I think when I was doing mediation, I would definitely encourage people to come up with as much as they could together, because that saves time in mediation, so I can provide them with the discovery statute, obviously, I can't give either of them legal advice. But I can say, hey, here's all the documents, the court is going to require you to exchange. Some people don't feel like they need to exchange all of those documents in mediation, and that's okay. We just put in something in your judgment that says, hey, everyone agrees that they've had enough information to make the decisions in this divorce. But so, you know, not everyone feels like they need two years worth of the other party's credit card bills. And they just want to know, hey, what's what's on the credit card right now. But I would provide each party with that discovery statute. So they know, okay, here's all of the documents I'm going to have to provide. If we're not able to settle this in mediation, and that can give them a place to start

Steve Altishin  16:17  
other forms, you're going to get to help either coming up with this information or putting it into some format. And did the mediators generally have forms they give out to the folks?

Caryn Jones  16:30  
I think that probably varies by mediator. I think most mediators, if you're, if you're doing this with people who are representing themselves, I think most mediators are probably going to give them an intake form of some sort that says, hey, you know, let me know, all of the basic information, you know, what do you know about your finances? What are the accounts? What's out there? What do we need to resolve, so they'll have some kind of intake form similar to what your attorney might have? And then other than that, I don't know, you know, there may be some mediators who have more forms, and some mediators who just don't use forms and take that information as they're mediating, you know, some of that information, like the the basics that go into the vital statistics form, and things like that are going to be on an intake form. Because that speeds things up.

Steve Altishin  17:19  
If it's, I'm not either represented yet by an attorney, or the attorney is helping me but I'm doing the mediation. And I'm looking for a mediator are these the kinds of questions I can ask the mediator first kind of how they do it, but they, you know, at a cost, you know, what expectations they have of the people when they come in?

Caryn Jones  17:42  
Absolutely, when I was doing mediation, I used to do a free 15 minute phone call for each party in the mediation so that they had that opportunity to ask, you know, what I would want from them what the process looks like. And also to get a feel for who I was as a mediator, because that's really important. Mediation, again, is voluntary. And so each person has to agree to use the same mediator. If you're doing the court connected mediation, where you go through the county for custody and parenting time issues, you don't really have much choice, you just go with the mediator that the court assigns you to but if you're doing a Private Mediation, each party has to agree to use the same mediator. So it is important to connect with the mediator get a feel for who they are, how they operate, what their procedures are, and make sure that each of you is comfortable using them before you start the mediation.

Steve Altishin  18:37  
That leads to a question. So mediation then, it's not just about a divorce proceeding, I take it. There are maybe, you know, modifications, or you just want custody, or you were never married. Communication can work on all of those other kinds of family law matters.

Caryn Jones  18:57  
Absolutely. You can mediate really any family law matter. From a prenup to a, you know, a Separation Agreement. If the two of you want to come up with a framework for how you're going to operate during a separation while you try to see if you do need to file for divorce, or if you want to move forward, a mediator can help you sit down and come up with a plan for where the kids are going to be while you're separating and how we're going to pay finances. And you don't even need to file the separation or the divorce. You can do sort of an extra judicial mediation to get you through that separation period where you decide whether or not you're even going to file divorce. So I think mediation is a great tool for all of those kinds of situations that might fall outside of normal litigation, as well as being used for divorces, modifications, you know, needing to establish custody and parenti ng time.

Steve Altishin  19:57  
Sounds like it's a pretty flexible way to try to resolve your problems. So let's say I have a bunch of things I want to say to the mediator. Well, I've looked at my stuff, I've gotten ready for it. But it's so easy to know what you want to say, and then go into a meeting like that, and forget. How do I make sure that the things I want to make sure I tell the mediator, I tell the mediator?

Caryn Jones  20:29  
That's a good question, Steve. I would highly recommend, you know, when you're calm and outside of mediation, and able to organize things, making yourself a nice list of everything that you want to make sure that you cover in mediation, and then looking at that before you end any mediation sessions, so that you can make sure that you've covered everything. I will jump ahead, I think maybe, to meeting separately with the mediator. So you know, if you have your list of things that you really want to make sure the mediator knows, but some of them you're not particularly interested in talking about in front of the other party, that is something you can do in mediation. Again, whether you have an attorney there or not, if I was working with two parties who were not represented by attorneys, either if a party requested it, or if I felt like it would benefit the parties in a mediation, we can do what's called caucusing, which means that I would put one person in one room and one person in the other room and I would just go back and forth between them. And sometimes that can help, you know, if I was observing that the parties were just really stuck on an issue. And I thought it might help to talk separately with each party, I might do that, or if either party requested it. And so that's something, when I was doing mediations, what I would do in the first session is sit down and talk to the parties individually. Just to give them an opportunity to get, you know, there's a lot of emotion going on in all divorce and custody cases. And so I give them an opportunity to kind of get all of that off their chest to give me some information about where each person is coming from. And then that helps me, as the mediator, to move them closer to the middle and to get them to a resolution, even if I'm not disclosing that to the other person. So whatever the person wants to tell me in that caucus session, I would keep confidential. Unless it was something like, you know, my favorite example to use is oh, by the way, I'm pregnant and he doesn't know it. Well, you're gonna have to tell them, hat's gonna have to come out. And then we would talk about, okay, how are we going to disclose that one? But other than, you know, something that would be required to be disclosed in order to continue the mediation, that would all stay confidential.

Steve Altishin  22:49  
They can't tell you they're going to, you know, rob their business and all their money and go to Mexico?

Caryn Jones  22:56  

Steve Altishin  22:57  
Well, they can tell you, but you might have to say something.

Caryn Jones  23:01  

Steve Altishin  23:02  
So, is this something that can also happen before the actual mediation meeting between the two of you? I mean, are there times when someone can make call you up the day ahead, or two days ahead or whatever, and say, 'Look, here are my concerns for the mediation that we're having tomorrow'? Or does that all kind of occur in the mediation itself? 

Caryn Jones  23:24  
Sure, I would say if a party wanted to call the mediator prior to that, I think mediators may vary on how they deal with that. When I was mediating, I would, if one party wanted to have a call, I would essentially treat that as a caucus session. So no different than if we were meeting separately in a room in a mediation session, it would be the same thing. So I'd consider it part of the mediation, I would bill them for it, but yeah you can do that.

Steve Altishin  23:52  
So it's allowed?

Caryn Jones  23:54  
Right. Each person is allowed to talk to the mediator separately. Again, no legal advice is going to be given in those separate meetings, but you can give the mediator information that you don't necessarily want to share with the other party.

Steve Altishin  24:07  
So another issue that I know kind of happens is, you know, getting ready emotionally. If I come into you and I say, 'I've got this mediation, and I really want to win. That's all I care about is winning.' How do you get them to maybe shift from that to try to mediate to work it out? 

Caryn Jones  24:40  
Well, I mean, if your only goal is winning, mediation isn't going to be very productive. So I think in that case, I'd have a conversation with the person about, youknow, what are you going to benefit if you get everything that you want? How will that benefit you and kind of refocusing them on what what are your real goals? How do you want to see your life after this divorce is final? You know, what is your vision for your children? And how can we get you there in a way that is collaborative and benefits everyone so that you can get through this divorce without spending all that money and going through the emotional trauma of a trial?

Steve Altishin  25:22  
What about, maybe not winning, but I want to convince the mediator of this-- it's important that you, the mediator, understand that this is true, and that is not true. I have to convince that mediator in order for the mediation to work, is that correct?

Caryn Jones  25:40  
No, I don't think you need to convince the mediator. I think it's helpful to provide the mediator with information about why you're wanting what you're wanting. But the mediators job is not to decide who's right and who's wrong, their job is not to decide what the result should be. Their job is to facilitate that conversation to get the two of you a result that you can agree with. And so it's helpful to give the mediator the information about why you're asking what you're asking, or why something is important to you, but always keep in mind that the mediators, they're not there to make a decision or to decide who's right.

Steve Altishin  26:17  
I think that's really important for people to know. You know, what mediators can do and what they can't do. So here's another thing...there's all these things that may be going on in the divorce, and they're taking you in different directions. How do I really know what I want? I mean, it's kind of a weird question, but I'm assuming the mediators say, What do you want? And, you know, I could say, I want this, this, that, that, but is that it? I mean, how do I know what I really want?

Caryn Jones  26:57  
It's a good question, Steve, what do you want? Well, I think if you really go into a divorce having no idea what you want, that might be a situation where you might need some legal advice. And so I would recommend that you would meet with a lawyer, because the mediator can't give you legal advice and can't tell you what is best for you. So even if you're coming to the mediation without your attorney, or it's just you and your spouse, or soon to be ex spouse or co-parent, coming into the mediation just by yourselves as pro se parties, you can have an attorney on the side who's advising you, whether or not the other party has an attorney. And so you can meet with your attorney before mediation and get an idea of, you know, what is my best case scenario if I go to court? What is my worst case scenario if I go to court? What should I be asking for here, and what's reasonable? And so that's your attorneys role is to give you that information and advise you about what you should want, what's realistic for you. And then you can use that information to go into mediation and know where you can concede and where you can stay firm, because, you know, like, 'Okay, well, here's my worst case scenario if I go into court.'

Steve Altishin  28:18  
Again, that's really important to know. A mediator is not going to say, 'Well, if you do this you're gonna get killed in court, or you're gonna win that'-- that's not their job. What if I've got emotional triggers? A lot of people will understand this, and the other party knows what your emotional triggers are. What advice would you give to people to kind of prepare that their emotional triggers may be hit?

Caryn Jones  28:48  
Mmhmm. Well, I think that emotional triggers, and especially if people have a lot of trauma from other aspects of their life, from the marriage, from the relationship-- all of that is really important to let your mediator know. So in those initial meetings, where you're maybe meeting separately with the mediator, the mediator should be doing domestic violence kind of questions to get a feel for if there is any kind of power and control issues or domestic violence issues. So in those meetings, if there are things that are really triggering for you, and not necessarily domestic violence, but just Gosh, I'm still really mad that he spent all that money on that jet ski. Those kinds of things that could be triggering to you during mediation are good to let the mediator know so that way the mediator knows like, okay, this is coming up and maybe I need to give everyone a five minute bathroom break or, you know, go take a walk and manage your emotions. So, number one, let the let the mediator know of any important emotional triggers or trauma that you have in your background. And then number two, you know, set aside some time for yourself before or after the mediation so that you can do some self care, go for a walk, talk to people. And also know that either person can take a break at any point in the mediation. And so if you need 10 minutes, feel free to say, I just need to take a walk, or I need to go have a cigarette, or whatever it is that you need to do, so that you can stay in control of your emotions during the mediation.

Steve Altishin  30:32  
I love that. Because that seems to me that it's where mediation can go really wrong, really fast. And sort of, you know, the best laid plans of mice and men after getting ugly. You can do all your planning, do everything, and it can just unravel at the time. Just as a final-- we're almost at the end, we've already hit 30 minutes-- but maybe a couple  of your thoughts as we leave about not letting your emotions get in the way, but maybe not necessarily holding them in because maybe the mediator wants to know something about them. Maybe that's important. But you know, when you're in there, when you're in the heat of the battle at the mediation, and there's maybe no one but the two of you and the mediator, what can they have in their mind from you that can help?

Caryn Jones  31:35  
Well, I would say that-- and when I was mediating, I might even jump in in a mediation when things are getting heated or emotional, whether I separate the parties and have this conversation with them individually, or whether I do it together--just to stay focused on the benefits to you of resolving this through mediation. Financial benefits, and emotional benefits. Maybe not in the heat of the moment, but the overall, the process of mediation, even when it gets heated and emotional, is a lot easier on people than, you know, sitting through a five day trial, where you're going to have to say all of the things that you need to win your case that are going to damage that relationship even further. So staying focused on that. The goal is to come out of this with the best result that you can get in a more collaborative and less expensive way than litigating it. And it's not always possible to solve everything through mediation, and that's why lawyers stay in business. If everyone was able to just get everything done collaboratively, I think we would. But the more you can resolve outside of court, the better. And I think that's, you know, the policy of the state and the courts as well is to encourage that, to really encourage people to settle things outside of court whenever possible. So my advice when things are getting heated is just to keep your mind focused on that end goal of coming up with a result and keeping yourself out of court. And, you know, if you have kids, there's long lasting benefits for your kids by doing that. And even if you don't have kids, it's just your own personal benefit of taking charge of the results.

Steve Altishin  33:16  
Yeah, it's a place where you don't have to burn your bridges. So don't burn your bridges! Well, we are unfortunately done. And I really want to thank you. This was incredibly informative. How mediation works, how to prepare, again, as normal, you make complex issues, complex rules, and what seems like daunting challenges clearer and easier to understand. I really thank you for that, and thank you for being here today.

Caryn Jones  33:54  
No problem. Thank you, Steve. It's always a pleasure to hang out with you and chat about mediation or any other legal topic.

Steve Altishin  34:01  
Well, we'll get you on again, I can guarantee it. And everyone else, I want to thank you for joining us today. If anyone has further questions on today's topic, post it here and we can get you connected with Caryn or another one of our attorneys. And until next time, stay safe, stay happy, and be well.

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