Chris Dreyer:
When the stakes are high and the time is short, one name echoes in the courtrooms across the Gulf Coast. Andy Citrin.
Andy Citrin:
When it's a serious case, we go straight there, we sign it immediately.
Chris Dreyer:
40 years in the game, over 10,000 clients serve, more than $600 million recovered. When a truck crashes and changes a family's life at 2:00 AM, his team doesn't wait for sunrise. They're already on the scene. When others draft polite demand letters, Andy's filing lawsuits and worrying insurance companies non-stop.
Andy Citrin:
You walk into a law firm like mine, that's what separates the men from the boys in this business.
Chris Dreyer:
I'm Chris Dreyer, founder and CEO of Rankings.io, the elite personal injury marketing agency for firms on the way to the top, today on Personal Injury Mastermind, I sit down with the man behind the A.N.D.Y. W.I.N.S. Trial Process. This system is turning associates into courtroom killers and turning insurance companies inside out. Let's get into it.
So you're coming up on 40 years as an injury attorney?
Andy Citrin:
Yeah, not just 40 years, but I just had my largest verdict in my 40-year career. We just came out of a $6 million verdict in federal court over in Mobile. We have another seasoned lawyer over at our Pascagoula office, Judge Michael Fondren, and he's had some big wins recently too. So we've been on a roll getting verdicts and staying focused on the craft.
Chris Dreyer:
Let's go. Let's go. So tell me about the big case, the big verdict. Tell me a little bit about it.
Andy Citrin:
18-wheeler driver was on his cell phone, ran into a divided highway. He was already on disability, but he had a traumatic brain injury. And he was a wonderful man. And I'll tell you, it was a joy to be in federal court because federal court and their tight deadlines, it's almost too rigid with the pretrial and all that, but they keep a case on track and delivers one of the things that I think that my firm's known for, which is high tempo. And I like that high tempo. So we got it from crash to verdict in just over three years, which is good for a case of that magnitude. I like to do it in half that time, to be honest, but still the whole methodology that we follow in the office came to life in that case.
Chris Dreyer:
That's amazing. Congrats on that.
Andy Citrin:
Thank you.
Chris Dreyer:
That's the A.N.D.Y. W.I.N.S. Trial Process and how it's reshaping the game. It's had a huge impact.
Andy Citrin:
Start with great talent and then teach them the winning process. This is what all great trial lawyers do. I just found a way to use my brand to describe our methodology in our process. Some lawyers will be bothered, "I'm not going to follow the A.N.D.Y. W.I.N.S. Trial Process," but when they hear what W.I.N.S. stands for, the W.I.N.S. Trial Process, they'll be completely on board with that. And so I'll tell you what both mean if you want me to.
Chris Dreyer:
Yeah.
Andy Citrin:
What I learned in law school was that justice delayed is justice denied. Speed matters. So when you bring that high tempo mindset, you're already off to a good start. So what A.N.D.Y. W.I.N.S., let me tell you what it means, file immediately and fight, go hard and fast until the insurance company does what's right.
Chris Dreyer:
The Andy and A.N.D.Y. W.I.N.S. stands for Act Now Don't Yield. And I got to tell you, Andy is all gas.
Andy Citrin:
You don't bring an elephant's foot into stamp out a flea. Once we file, there's no taking your foot off the accelerator. They don't hire us to be reverse insurance adjusters and write polite demand letters. Everybody loves to lay down, but that's not lawyering, that's just processing. And we didn't go to law school and go to all this trouble and learn this craft and stay dedicated and go to seminar after seminar after seminar and study cross-examination techniques and watch podcasts and stay dialed into what the greats are doing in America so that we could be reverse insurance adjusters.
So I thought about what W.I.N.S. stood for and I thought, "We worry insurance nonstop." And I thought, wait a minute, that's clever. Act now. Don't yield. Worry insurance nonstop. This worries insurance and insurance companies will pay big. Or if they don't, you're going to be so ready for trial that you're not even going to want to let them settle the case. We have this rapid response protocol and when a big truck case calls, it's like the fireman sliding down the pole, the alarm goes off, it could come in at 2:00 in the morning.
Chris Dreyer:
Secure that truck.
Andy Citrin:
You do not even brush your teeth. You go as fast as you can to the scene. This actually happened in a case. I was working on a triple death case, an 18-wheeler was driving too fast in the rain and killed a mother and a father and their daughter. I followed the whole rapid response protocol. I get suit filed and I get the local television coverage of the event. Every news channel in town sent their people out. Anyway, I'm looking at it four or five months down the road and I'm watching it from the time they arrived. They arrived about an hour and a half after the crash. So as they're setting up the guy's doing this sort of thing, he goes, "Can you hear me?" Because it's just the camera lights come on and he's testing his mic.
So I got all this B roll that they provided through our subpoena and walking in the background was the defense attorney. In the background. It's pouring down rain, it's 10:00 on a Friday night and the defense attorney who's now defending this case is on scene. And I'm like, "Holy cow. They dispatched him immediately." So I later asked him, I said, "What's the deal man? You're in the footage. You were there an hour and a half after the crash." He goes, "Man, I keep a ready bag. These insurance companies, they want us on scene in these serious cases as soon as possible." And I thought, "Heck yeah, you want to be at that scene." I want you to call me the second. Everybody is safe and secure and getting the medical treatment they need. I want your second call to be to me so I can get to the scene as fast as those defense attorneys are. Right?
So when I say act now, boom. Rapid response protocol. When it's a serious case, we go straight there, we sign it immediately. We get our experts on route, we get our investigator on route, we go to the scene, we get everything we can locked down, the black boxes and all the peripheral videos from neighbors or whatever. We just go straight into lock it down and then we file suit as fast as the law allows. I mean, within 72 hours is my preference.
You will distinguish yourself as a lawyer if you get a high tempo mindset. So I came into that and then joined a law firm where it was like, man, once we decided to take a case, it was pedal to the metal. And now you've got to act with great skill.
Chris Dreyer:
There's another acronym that Andy uses, TRIAL. T-R-I-A-L stands for?
Andy Citrin:
Ten, reckless, intel, ASAP and limits.
Chris Dreyer:
The 10 is an interesting one. If your plaintiff is a standup citizen, aka 10 out of 10, it makes your job a whole lot easier. But according to Andy, it is possible to transform clients with criminal records, drug issues, and even pre-existing conditions into perfect tens.
Andy Citrin:
You can turn every single client into a ten if you know how to counsel them, if you know how to get them into a winning mindset. So you say, "You are not going to be a poor pitiful me in this case. Not if you want to win." And I've always said love. You've got to love our clients so that you can see, yes, they had to face adversity. Hell yes. You realize when someone gets charged with a crime or makes the kind of decisions that lead to a criminal offense, a guilty plea or a conviction, man, they messed up. They have to own that. I've had to face adversities. I've made some bad decisions, I've made a lot of mistakes, but it has nothing to do with the fact that I was innocently driving home when your 18 wheeler came blowing out of a side road and clobbered me and turned my car into a smashed ball of steel. So you just own that, right?
Next you prove reckless disregard for the rights and safety of other and prove that there was an intentional choice made, a conscious intentional choice. It wasn't an accident. And in fact, in Alabama, we don't call them accident reports. They're called crash reports. And it was a choice. And we did it knowing that we could seriously injure or kill an innocent random citizen in an instant. In an instant. So you prove that in every case so that you can open up punitive damages. The courts are not going to let you go to punitive damages in every case. If you're taught that from the minute you walk into a law firm like mine, that's what separates the men from the boys in this business, cross examination skills. So you bring that to bear on your young talent, both paralegals and they start to get excited because they're like, "You're dang right, I could prove that. I could prove that that was a choice."
Chris Dreyer:
The I in trial stands for intel. With intel, you're trying to find a defense's vulnerabilities.
Andy Citrin:
Is it knowledge? Is it pattern and practice? Is it other similar incidences? Is it complete callous disregard either at the wreck scene or an aftermath? Have they done anything to try to prevent this from happening? So you get to make a punitive argument by showing that they took no action. But even on the internal stuff, they don't want you seeing what they said in their text messages. They don't want you seeing what they said in the board of directors meeting. Those C-suite people don't want to give depositions to talk about what they knew and when they knew it. God, they will do everything in their power to prevent a C-suite in a corporation from having to give a deposition. Those are their vulnerabilities. We have a whole list of what their vulnerabilities are. We go for them.
Chris Dreyer:
All right, so far in the T-R-I-A-L or TRIAL process, we've got T for ten, R for reckless, I for intel, and a for ASAP.
Andy Citrin:
We do everything as fast as the law allows because you give them a day, you'll lose a week. You lose a week, you lose a month. You lose a month, you'll lose a quarter. You lose a quarter, you could lose a year. You do it with filing, we do it with discovery and depositions and we do it with trial setting. We want the earliest. Number one, we don't want to be to say, "Yeah, I'll put you on the docket March of '26." Say, "Well judge, which number am I going to be on your docket?" "Well, I don't know. There's 27 cases set that day." If you are just leaving it to chance, the lottery, that you're going to be picked, number one out of 27 other cases or whatever's on his docket, chances are you're going to get put third, fourth, fifth or God knows where. And if you're third, fourth or fifth, your chances of going to trial then are slim to none.
So what you have to do is become a lawyer and a law firm that the judge wants number one on his docket. You are polite, you're professional, you're always prepared. You're right on the law. You deliver the tight concise briefs so the judge can feel confident these guys are not going to lead me astray. I'm not going to get reversed. They're going to give me a fast speedy trial. You do that in front of a judge a few times and all of a sudden you're going to be getting all the number one trial settings. But I always say to the defense, "Look, look at Rule 1C, it's just commandment, "We shall ensure the just, speedy and inexpensive resolution of every action." So you're professionally obliged to follow Rule 1 as much as I am. And look, my client is the injured party here, you're just protecting insurance money. We're going to set this case for trial and I do not want to hear any asks for continuance.
So the judges, if they see that you're going to show up and you're going to be professional, you're going to be concise. You're going to bring a worthy case in their court. They will do what they can do to accommodate the defense lawyers within reason, but they will get you to trial as soon as possible. That's how you do it. You win the judge through professionalism and skill and speed.
And then that last thing is limits. One of the biggest tragedies we personal injury lawyers have to deal with is people will come to us with catastrophic injuries or deaths and there's almost no insurance, right? In Alabama, you're only required to have a $25,000 liability policy and you can drive a car. Now under a federal law, you're only required to have $750,000 to drive an eighteen-wheeler. A lot of them have more, but most of our serious injuries and death cases come from car wrecks.
So what can a lawyer do? Well, a lawyer can try to pop limits. And what that means is you get the case, move fast, like I'm saying, and you get in front of the insurance company and you say, "Look, your client, Chris Dreyer, only has $25,000. We're going to give you 10 days to pay that $25,000. And if you don't, there will never be another chance to settle this case for your policy limits because we're going to be going for an excess judgment against you for negligent failure to settle."
This is our only leverage over the insurance companies to make sure they move fast because we give them a reasonable deadline. The law says that if an insurance company receives, your insurance company, let's say it's you, Chris. You've caused a bad car crash and you've caused a half million dollar injury, but you've only got $25,000 in coverage. If we representing the plaintiff, give the insurance company all the information that they need to make a settlement decision and they do it negligently, they're on the hook for whatever verdict the jury ultimately returns. It's hard to prove. It's why it says it's rarefied air. But great lawyers, the great technicians that are really good at this, they know how to pop limits. And that's something we try to do in every case.
Why? Go back to the A.N.D.Y. W.I.N.S., it worries insurance to death. If you go, "Look, you guys think you're protected by the $25,000 limits Chris has, Haha, that ship left the station 10 days after we filed suit. We gave you all the medical records, we gave you all the liability evidence, and you thumbed your nose at us. Now we're going for a $5 million verdict and we're going to get it. And then you people are going to be on the hook for $4,975,000 more than you contracted with Chris. So thank you very much for when your negligence is our win." And that's what we call popping limits. So you see that worries insurance.
So you're getting after the good intel, you're moving fast, and then you've also opened up... You're not protected. I hate to tell you this XYZ insurance company, but you're not protected by your contract with Chris. You dumbasses failed to pay it. I told you to pay it then. If there's a giant verdict in this case, you guys have huge exposure. "Oh my God, what should we do? We better settle. We better try to settle." And when you do this A.N.D.Y. W.I.N.S. Trial Method, both the mindset with the tempo and readiness initiative, action and leadership, and combine it with making the client they're a 10, proven recklessness, going for that juicy intel, moving as soon as the law allows, getting the earliest trial setting and opening up limits, they're about to pee blood up in that insurance company.
Chris Dreyer:
As you can hear, Andy's process is all gas and no breaks. And what I love about it is it works. He has done this time and time again. He's coaching up younger attorneys to do the same.
Andy Citrin:
Because I see the lights go on for these young lawyers in these paralegals. So we're reducing the caseload, we're focusing on where this kind of approach makes sense financially. Because if I go A.N.D.Y. W.I.N.S. Trial Process on a $50,000 case, I'm not going to keep it inexpensive, but if I can turn a $50,000 case with some of those methods into a $5 million case, then whatever I spend on it is a bargain. And if I have a big case with huge limits, that system works with those cases as well.
So that's the approach and that's why I'm excited, because I can teach this. We just hired two young lawyers, they're both 30 and they joined us back in January. And they just got back from Trial Lawyers University where they were going to study all the techniques. Because if you start with great talent and then you bring them in and you teach them our process and you reward them when they do it the right way, you reward the behaviors that you're looking for. So we now pay for verdicts extra. We want to incentivize verdicts. I don't care if you get a defense verdict or a plaintiff's verdict, but you just show me that you followed the process and you took it to verdict, I give you a bonus, even if it's a defense verdict, because you can't win them all. I want you learning the mindset and seeing and then practicing it and practicing it. You get in that batting cage as often as you can. They get it.
Chris Dreyer:
Andy pushes his trials to be as quick as possible. Fast trials equal happy juries and larger verdicts.
Andy Citrin:
First of all, they don't want to spend any more time than necessary. They don't want to be there. The longer a case draws out, those jurors are getting bored. They're waiting in the hallway. They're day two, day five, day six. When those cases drag out like that, they're eventually going to not be able to resist the temptation to start doing some research and talking to people, and they're going to get influenced, and then they're going to start thinking of things that could have happened or should have happened. And instead of just being in a hard and fast trial where they get to the point and they're asked to decide, where there is no time for that outside influence. You drag a case out, idle hands are going to be the devil's workshop, and they might end up returning a smaller verdict because of those outside influences that could infiltrate and contaminate the legal process.
So you got to have a great technical team that can handle all of the courtroom technology, the graphics, the simplification. They're good storytellers, they're producers. You got to have them on your team because ultimately you're producing a story that is going to provide a compelling outcome, hopefully a compelling outcome for your client because the jury gets to decide. They're watching the whole thing unfold, and if it doesn't move quickly and stay consistent and drive it home, then you're going to lose the jury. So you got to have technical expertise. If you're really bad at it like I am, then you've got to get a who. You've got to find someone who can do that for you.
Chris Dreyer:
A little Dan Sullivan there.
Andy Citrin:
Yeah, yeah, exactly.
Chris Dreyer:
Andy, that was a masterclass of motivation. Those red meat eaters, if they're listening to the pod at night, they're not going to be able to sleep. I don't have them. I think you nailed the focus of this podcast, and I think we put a stamp on it. For our audience listening that wants to connect with a real through and through trial attorney, how can they get in touch?
Andy Citrin:
Oh, ANDYWINS.com or just call me. I would literally talk to anybody. If they're from this podcast, call my cell phone (251) 454-0040. Text me first. Let me know you're calling me about the podcast, and then let me know who you are and I'll reach right out. But it's also just reach out through the firm, which is (251) 888-8888. But yeah, I would just assume reach out to me through the cell phone, text.
Chris Dreyer:
That's a wrap with Andy Citrin. If you're fired up, do me a favor, subscribe to Personal Injury Mastermind and never miss an episode. Until next time, keep your foot on the gas.
