87. Mark Kosieradzki, Kozieradzki Smith Law Firm 30(b)(6): Making Corporations answer to you

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Mark Kosieradzki is a Minnesota-based attorney whose practice is dedicated to fighting for senior citizens against nursing home abuse and neglect. Mark is also the preeminent scholar on Federal Rule of Civil Procedure 30(b)(6), which allows prosecutors to depose corporations more thoroughly and efficiently. 30(b)(6) is an important part of your arsenal as a prosecutor, and Marks here to show you how to use it best.

In this episode, we discuss how 30(b)(6) can be an invaluable asset, as well as the Kozieradzki Smith Law Firm approach to nursing home cases.

Transcript

Mark Kosieradzki

Cases should be tried on the merits. You know, we get all the facts in front of everyone and then, you know, we argue the law and the principles on it, but it’s not about hiding the facts. It’s about how we interpret those facts.

Chris Dreyer

When you’re investigating the cause of the injury or death, it can be really hard to get access to all the information.

Mark Kosieradzki

You can use one or two 30 (b) (6) depositions to cut through a year of nonsense. It’s a powerful and efficient way to get to information and to commit an institution to a position so that you know what they’re going to say, and they’re not going to try to sandbag you at trial.

Chris Dreyer

Mark Kosieradzki is a nationally acclaimed lawyer specializing in nursing and neglect cases. He pioneered new ways to hold companies accountable through his use of federal rule, civil procedure, 30 (B)(6), and his writing and teaching on the topic has garnered him a national reputation among prosecutors. Mark and I got together to chat about what makes nursing home cases unique as well as all things, 30 (B)(6). You’re listening to the personal injury marketing mastermind, the show where elite personal injury attorneys and leading edge marketers give you exclusive access to growth strategies for your firm. I’m your host, Chris Dreyer, founder and CEO of rankings.io. We help elite personal injury attorneys dominate first page rankings with search engine optimization. Being at the forefront of marketing is all about understanding people. So let’s get to know our guests. Here’s Mark Kosieradzki co-founder and president at Kosieradzki Smith law firm.

Mark Kosieradzki

I’ve been a lawyer for 42 years. When I started, I worked for a big general practice firm that did everything from dog bites and car wrecks to civil rights actions. And it was a great firm, but after 17 years, I kind of wanted to be my own guy. So I started my own law firm. I just took off one day cause I’m going to do it my own. And in that process, I was taking anything that came in the door and I got this call on a nursing home case because everyone was saying, well, nobody takes those because you know, the death of a 90 year old who has a three-year life expectancy is, you know, you can’t afford to handle that case. So I didn’t take it. And then another one came around. And then a third one, I’m just thinking that this just isn’t right. Something doesn’t feel right that this really bad stuff is happening to people. So. I decided, well, let’s, you know, let’s see if we can try to hold wrongdoers accountable. And as I started digging into it, I realized it wasn’t so much about what happened, but why it happened. And it’s you know, they taught us in Watergate many, many years ago, follow the money. And when I started doing that. I found that we have a whole industry that’s killing mama for money. And once we started uncovering that, then you know, the cases not only became economically feasible, but they became about. You know, what was really happening was that people were laundering money or channeling money through these institutions, cutting staff, cutting materials, cutting quality, and people were getting harmed and killed. And so I handled the case once I understood that theater. And it was pretty successful. So more people started calling me. And the next thing I know, I’m the national chair of the nursing home group. And you know, now I get 600 calls a year about it.

Chris Dreyer

Yeah. That’s fantastic. You know, so many times you hear individuals. Like either they’re taking every case. You can get revenue. When you start a new business and you find this kind of blue ocean, right. Where it’s not as competitive individuals, aren’t taking these cases and you can really throw your hat in the ring, become an expert, get that that credibility from being a niche expert. You know, I got to say too, when you’re talking about, you know, The neglect side, I was immediately thinking, Hey, is it it’s, it’s mostly gotta be under staffing. And, you know, I hear about these bedsore cases and I’d imagine, have you seen an increase? And I wasn’t going to go this direction. I wasn’t totally prepped, but from the COVID situation where there wasn’t their family members checking on them, do you, have you seen an increase in the neglect type of thing?

Mark Kosieradzki

Well, you’re spot on, on that when COVID came around and they shut the doors, not only to family members, but to state investigators. So all of a sudden we have a lot of places that doesn’t have anybody checking up on them. And what happens is, you know, we can take the money and not provide the service. And it, we saw a real uptick in calls of not just people getting COVID these, I mean, cold, you know, that that’s a pretty complicated cause and effect type of deal, but the you’re spot on, on the failure and the neglect that happened when there’s nobody that nobody reminding of the shop.

Chris Dreyer

Yeah, it’s really, really unfortunate. They, you know, the other thing that I hear and I’ve read is it’s, you know, some attorneys might think that because these victims are seniors, that juries are less likely to award a, a big verdict. Is that just a myth? You know, what would you say to attorneys who are tentative to take on these types of cases?

Mark Kosieradzki

Well, one of the things I’ve been teaching at the national college advocacy for decades is. Yeah, damages aren’t necessarily about damages it’s. Why something happened is what will motivate the jurors to follow the law. Because a lot of times the jurors will say, well, you know, stuff happens. It was an accident. And as a result they said, yeah, we got to get, you know, we were told that we have to allow some, some damages, but it’s not that big a deal on the other hand. If they see that it’s about bad conduct, about money laundering, about cutting staff, about making the workers as victims. The most conservative jurors are often the ones who are most outraged by that. And once they’re outraged, they’ll follow the wall. And the law says, you know, what are the damages? You know, what is the harm that occurred? And they’re not going to water it down because they say stuff happens. And so I think it is a myth that the nursing home case that is a function of momma dying from money is going to be 10 or a hundred times bigger than the identical situation of mama dying in a rear end collision.

Chris Dreyer

Yeah. That, that makes a lot of sense when you explain it like that. The, the other question that I had, and I know you kind of alluded to it, maybe the full answer, but, but I’ve got to dig in here a little bit is, you know, I imagine that that many of the people that contact you are not the victims themselves, right? Their, their loved ones. It’s, it’s a much broader demographic or, you know, so, you know, what’s, what’s some of your recommendations in terms of a marketing strategy to make sure you’re reaching the actual right.

Mark Kosieradzki

On the right people are the, are the loved ones of either the dementia patient who’s been sexually abused, but really doesn’t have the ability to express express it or a victim of a wrongful death. I think what we find at least from, you know, the philosophy of my firm is we’re there to help people get through really, really tough. Possibly the toughest thing they’ve ever gone through that, you know, mom or dad who raised them and molded them to be who they are is all of a sudden being abused. And it’s really upsetting. And most of the people who come to us, you know, they, they want to find out what happened. And they feel like they have to do something do something just in response to this terrible thing that happened to their parents. So it wouldn’t happen to anybody again. So this is not a area for people who want to just churn and burn and make money because the people who who are the clients. Really have a huge emotional stake in those. And in a very large percentage of the time, it’s not about the money, it’s about the principle for them. And so if you’re trying to reach people, then you have to know where they’re coming from. And and it takes compassion and, and it takes it takes understanding and knowing where they’re coming from. And for those of us, who’ve watched our parents, you know, what that process is like. And even when you see it coming, it’s hard. And so all of a sudden you get this surprise call, that mama was, you know, fell out of a window and you’re saying, well, what was she doing next to an open window? I mean, you wouldn’t do that a daycare center or, you know, mama. Was found with someone sexually assaulting her. I mean, these are things that, you know, create nightmares for their children and we’re, we’re there to help them hold wrongdoers accountable, and to make sure that we find out what happened and can, and hopefully do things to prevent it from ever happening again.

Chris Dreyer

In terms of motivation high, imagine cheese that when I you’re hearing some of those, some of the things that you’ve mentioned, I can’t help, but imagine like what would happen if something happened like that to my mom? Oh, geez. It just, all these emotions go through you your mind and it’s, it’s, you know, your heart focusing in on what you’re saying. The other thing I was thinking is, you know, a lot of law firms they’ll use. Third party intake company, a or a live chat. And one of the things I’ve seen with those is just a lack of emotional intelligence in terms of GQ. So, you know, when individuals are contacting you, I imagine that that your staff just have to be supremely you know, trained in that and just have that skill of emotional intelligence.

Mark Kosieradzki

Yeah, this isn’t about data transfer. Yeah. This is about human connection. We have one woman who literally is a Saint and she listens to people every day and talks to them and hears them out to understand, you know, what their needs are. And. Yeah, it was, it’s just, it’s really kind of cool. I just got an email from someone that we turned down and we turned it down 95% of the cases, 96. And she wrote this email and says, thank you for taking so much time to listen to us, to guide us, to let us know what the options are. And you know, any was spectacular. She She just is all about love and compassion and it’s reflective of who you are as a law firm. And well, I want to thank you. Didn’t take the case, but I want to thank you for hearing us. And we get so many calls from referrals of people who we turned down and, but it’s but we don’t have the chat. We don’t even have the automated while we have an automated phone answering service, but the way it works is it. If it doesn’t go to the person who answers a form within two rings or rolls to someone else and within six rings, you will always get a human being. So we’re kind of old school.

Chris Dreyer

Yeah. I liked that. I liked that well, and, and also due to niching, right? You have, you know, it’s not this volume where you’re trying to get 10,000 auto accidents.

Mark Kosieradzki

Right. And that was how I started my career.

Chris Dreyer

And then there’s a place for that. But you know, tt’s a red ocean there though. I mean, it’s, it’s.

Mark Kosieradzki

I will tell you when I first started practicing law, it was, you know, 40 years ago, 40 plus years ago. And my job was to take every piece of dog dropping case that the senior partners couldn’t get settled on and I’d have to go try. So I’ve got more jury trials. Most law firms have because we weren’t just cranking them. And I’m not going to say that was necessarily the best legal work that I’ve done in my life. But boy, did I learn how to do it. And I learned how to think on my feet and I learned how to win big and how to lose. I learned how to lose cases that I never thought were possible to lose. I won cases that were impossible to win. So there is a niche for it. And certainly I think that the people handle those cases. And I did it for 17, 20 years. It, helps mold conduct because you very seldom hear someone say I better stop drinking because I might kill someone or I might run into something, but you’ll hear people saying I better stop drinking and driving because I might get sued. So that’s what changes content. And so there is a real role for holding wrongdoers accountable, because if you hold wrongdoers accountable, other wrongdoers are gonna say, I better be careful. I might get sued. So I’ve been there. I’ve done that. I’ve tried so many of those and I feel really good about the accountability that we’ve helped instill perhaps with fairer, but it doesn’t matter that they’re instilled and And now we’re doing it on a, kind of a much more challenging scale in the healthcare industry, assisted living medical malpractice, nursing home assisted living where there’s the layers of, of corporate hiding is pretty stunning. I mean, I had a case once that we had 170 subsidiaries running one nursing home. I mean everything, you know, from, you know, who was binary. We even had one where there was a Ponzi scheme where the corporations sold ownership, shares, and every bed in the nursing home. It was crazy. It was absolutely crazy.

Chris Dreyer

You know the other question and I hadn’t, I was going to have, you know, one final question before we jump over to 30 (B)(6), I’d love to dive in about that. As there’s I looked up the stat today, there are over 46 million adults over 65 in the U S today. And that number is expected to grow to 90 million by 2050. You know, how do you think these increased numbers will affect elder care and elder abuse, these types of situations.

Mark Kosieradzki

Well, what I find is wherever there’s money to be made, you will find people out there trying to make the money. And some people are really scrupulous and they’re all about a great product and others are about turning the money. And if you’ve got lots and lots and lots of elders, and you’ve got the government paying for it. It’s going to be like government contractors. There’s going to be people trying to get licenses all over the place. And what we’ve been finding is assisted livings are like nursing home and in many, many states that are unregulated and as a result, You know, they create these really beautiful places. And a lot of them were just terrifying places because the care’s not given, but it looks pretty and it’s not, that’s not insurance, it’s cash base. So people are going to be spending six, eight, $9,000 a month to live in this kind of nice apartment where they think it’s safe. And a lot of times it’s not.

Chris Dreyer

Yeah, that’s really scary and, and unfortunate. And that, you know, as, as a non attorney listening or, or just an individual is thinking about using one of these facilities, it’s you know, do your due diligence and, and ask around the experts of who gives the best care for anyone unfamiliar with federal rule or civil procedure. For anyone unfamiliar with it, federal rule or civil procedure 30 (B)(6), it may seem a bit of an enigma. I asked Mark if he could, if he could describe the rule and why it’s so.

Mark Kosieradzki

Sure 30 (B)(6) is a federal rule, almost every on that almost every state has a corollary of the state rules. And what it is is it’s a process. It’s a rule that allows a lawyer to ask an institution. Questions as an institution, as opposed to the individuals, because it, it could be a corporation, it could be government, it could be a partnership. That’s a conglomerate of dozens hundreds, sometimes thousands, sometimes a million people who have information. And I know you’re going to find this really hard to believe in some of your listeners will be too, but corporations and the government are not always forthright with the information they want to share. And this rule was developed and Nope, it really did anything. For decades, but it, it, but it was philosophical. And it’s saying, rather than saying, I want to talk to the president of the corporation, or I want to talk to the product manager or the head nurse and say, I want to learn what the corporation knows about these areas. And he identified the subject matter. And then it’s the organizations job. To gather up all the information and answer your questions. And some wires will say that’s a lot of work. And I say, well, it’s not as much work as having to take the testimony of dozens of people and disrupting the business. So it is an efficient way of getting institutional knowledge. And I wrote the book on it.

Chris Dreyer

It seems you know, more outcome driven, you find the who, right. Who’s going to answer it. But I had a question from the outside is, and forgive me not an attorney. Would this allow them time to coach up that individual to maybe stray away from the correct information? Or is it better because you actually get to the person that has the implant.

Mark Kosieradzki

It’s not necessarily just one person and they’re going to get coached up. Having that. My job is to ask the questions in a way that it doesn’t matter if it’s a coach up or not. And, and it’s not necessarily any given person, their job is to create the witness, to tell us what they’re, what these facts are. What happened in this operating world? What was the design process? Why did this construction company not put together a demolition plan? What are you claiming are the rules? And through that we can craft questions first in this notice that we send out saying these are the things we want you to be fully prepared to talk about, right. And then we have to know how to frame the questions in a way that they can’t sidestep them because people lie all the time, all the time.

Chris Dreyer

And you kind of gave me a few examples, but maybe you could walk me through, I don’t know if you can share like an actual example of where you’ve used this or maybe like an improv, maybe give me like give you a story of maybe like a short example of this.

Mark Kosieradzki

I mean, I can do it on all kinds of different levels and it’s all depends on the case. Example I use and I promise to give you two examples, just so the first one is how you take a routine case where someone fell down the stairs in a fishing resort and they get a very, very serious Angelo. And you, you, you want to get the information necessary for The elements of your case, like who built the staircase? Did it follow the codes? What, what are the expected use of that staircase? Wasn’t this an open and obvious danger. Did the customer do anything wrong? And you literally say, I want this corporation to provide to me. One or more persons to provide all information known or available to the corporation about who built this staircase, what were the code questions that you were using code that you were using? What are the expected uses of this property? What kind of customers use it? Yeah, broad questions like that, but that just goes right to the heart of it. You know, if, if you ask for the manager or the owner, and this is, well, I can’t remember who built it, or I can’t remember when it was built or, you know, we’ve got all kinds of different customers. Well, now they say you gotta, you gotta take a scan. You have to take a stand on that because wires. Unfortunately, him kind of followed our sports world where they think it’s win at all costs. And it doesn’t, it’s not about playing by the rules. It’s about seeing what you can get away with and lawyers on both sides of the equation do that. And I’m, I’m, you know, I’m pretty opposed to that. I mean, I think my dad taught me when I was a young man in sports is, is if you, if you went by cheating in win and And so I look for ways to zero in on it. So a second example, that was one. How you take a routine case. Another example would be if you want to get. Contents of a computer or out of paper files and the rules say, all you gotta do is ask for it and they’re supposed to give it to you, but they’d give you all kinds of quizzes. Oh, we don’t know. We don’t know what you mean by personnel file or it’s too hard to find, or it’s going to be not, it’s going to be overburdened and it’s vague and it doesn’t have anything to do with anything. And so. I’ll use the 30 (B)(6) to the corporation saying here is six categories of documents I’m interested in and I’d like to know what, what documents are. Electronic information falls within the category of this title. And where is it kept? And how’s it organized. And how would you, if a court told you you had to go find it, how would you go about looking for it? And a perfect example was I asked for it. I asked for the personnel file. But, and they said that’s, what’s in the personnel file. They list all the stuff I said, well, what about the discipline records? Oh, that’s not the employee personnel file. That’s a different file that, and then as we talked about it, this was back in the paper file. They would have an HR file and then they’d have a health file in it, a discipline file, background check file. And so they just redefine it or they say, I I’d asked for data about nursing homes and what is a sexist, how many people you have in the room, in the building. And the lawyers would say, well, I don’t know what you mean by census. And you know, that that’d be too hard for us to calculate. So I asked them in this area, do you keep census? Yeah. You know what census means? Yeah. So it will tell us what it means. It means how many people we have in the building. Do you keep track of it close? Sure. In what, well, we have a computerized report that we generate twice a day about it. How hard is it? Three keystrokes. Can you print it? Well, sure. How hard is that? Click print with a mouse button, but they already said it’s vague overburden itself. We don’t know what you’re talking about and be too much work to get it. So this is a way to bypass the intermediary lawyer. Who’s trying to prevent you from getting the information, because if we follow the rules, it really should be an everybody. Who’s a lawyer. Who you know, is in your audience is going to know about Hickman versus Taylor. It’s back in the forties, the Supreme court says cases should be tried on the merits. You know, we get all the facts in front of everyone. And you know, we argue the law and the principles on it, but it’s not about hiding the facts. It’s about how we interpret those facts. But that seems to have been lost in a very big part of the current generation or multiple generations of lawyers.

Chris Dreyer

And I was, I was thinking, you know, you just want to scream semantics, right.

Mark Kosieradzki

it’s nonsense. Right,

Chris Dreyer

right. You know, I had a, I had a question here and this, I’m not sure if you’ve done a study related to this, but. From a, just a revenue standpoint and I’m kind of echoing Jay Abraham here where, you know, the ways to generate revenue is you, you get more leads, you extend the value of a case. But also let’s you, you increase your frequency, so you’re settling cost cases more quickly. So have you done a study to see, you know, how the application of 30 (B)(6) is applied to, you know, closing a case more quickly because you’re not running around in circles trying to find the right person. And have you found that it really makes an impact in terms of frequency?

Mark Kosieradzki

It makes an impact on multiple levels. The first one. Is what you’re talking about. You can use one or two 30 (B)(6) depositions cut through a year of nonsense of looking for some, you have to know what you’re doing. I mean, it’s, it’s a skill set. I mean, you just can’t just pick it up and do it, right. I mean, my book pages and 900 footnotes, you know, it’s but it’s a very powerful and efficient way to get to information and to, to. Commit an institution to a position that, you know what they’re going to say, and they’re not going to try to sandbag you at trial. But another thing that I would encourage everyone to think about is there’s one school of thought that the diff the defendants or the insurance companies decide the value of the case. And the job of the plaintiff’s lawyer is to. Get to that number with as little work as possible, because then that would be you get more for your hourly return and that’s certainly a valid way to evaluate that. Another way of looking at it is the value of the case is not determined by the defense insurance industry. But determined by what it would take to make me go away. And that means I may have to put a lot more work into a case. But my return on every hour will be a lot higher because the value of the case was not determined by the way. An example that I can’t go into too much detail in that recently I resolved a case where we worked it up. I mean, we’d spent $60,000 on it. We had, God knows how many hours we did 30 (B)(6) We enforce the rules. So they had to produce emails to us. We really held their feet to the fire. There was a couple of other firms who were watching what we were doing and we’re going to just piggyback on us saying, well, we will set the value of the case and then we’re going to settle our cases without all that work. And what I have learned is they were offered 1% of what I sell my case for. so they’re frustrated and because they’re thinking once again, that damages drive the damages and that’s all it is. And if you uncover bad conduct the responding institutions or defendants or insurance companies are going to be really nervous about what’s going to happen. Whereas if it was just about, you know, the result of the damages. Then the case will not have the strength that it otherwise would. And for those people who do a lot of contract stuff, and this is what I’ve learned is you can have a basic soft tissue case and it’s a rear-ender with low impact. And, you know, you’re, you know, you’re lucky to get eight, 10, $15,000. If it’s a drunk driver, who’s done the identical thing, particularly a drunk driver with a history it’s whatever the insurance policy limits are. It’s because the conduct is agreed now out here, people say, well, you know, there, there may not be coverage for that and say, you know what I mean? I’ve litigated that many times in my career. And it’s, it’s been a threat by the defense and she never really never really happened in the bad conduct. Really drives it.

Chris Dreyer

There are so many reasons to use 30 (B)(6) in general. It’s barely brought up at law school. I asked Mark how he discovered the rules, importance and what he’s doing to educate us.

Mark Kosieradzki

That’s a really good the point because my law school, if it hits 60 seconds on 36, I wouldn’t be surprised. And and every time I get a new lawyer, a lawsuit working with me, I asked him to bring you into a civil procedures book. Cause I want to see how much was in it. Well, I’ve never seen a civil procedure book go more than two pages on 30(B)(6). It’s just, it’s not even a 30,000 foot. It’s a 200,000 foot field. You know, my book – it’s the second edition is over 600 pages long because there was a lot of issues. And the way I got into it was really kind of funny. I’ve been teaching at the advanced deposition college for the American association of justice for 25, 30 years. And I tried 30 (B)(6) a bunch of times over the first 20 years of my career and it never worked and everybody was unprepared I’ll I got frustrated and pissed and I didn’t know what to do, but they asked me to teach us, oh, why are we wasting our time? It doesn’t work well, it’s got to be part of the program. And I did that crazy concept called we will research and I started studying it. I said, oh my God, this thing. Can really work, but you have to figure out how to prove that they’re achieving. So I spent the next decade practicing it and doing it and then getting better and better as I got along and teaching more and more. And then Paul Scoptur it was, was a great friend of mine he’s passed on now, but was a litigation scholar wrote a book with Phillip Miller who is equally great called Advanced Depositions. And Paul said, you know, we need a sequel to the book. And 30 (B)(6) would be a great sequel. Will you write it? I said, well, sure. And you know, I thought it’d be, you know, 80 pages and three, four months to do it. Well, four and a half years later, and five pay, you know, 500 pages later, the first edition got, and then it really took off and it, and Laura’s is all over the country started doing it. I’m not going to say there’s a direct correlation, but I’d like to think there is that the next thing we know, the the defense industry is partitioning the Supreme court and the federal rules committee to water down the rules. I mean, basically taking everything I wrote about and trying to take it away. And so, you know, I testified before the rules committee with a lot of other people and I was one of hundreds, if not thousands of people who wrote in on it and the Supreme court and the rules committee got it. They understood the gamesmanship and, and you know, the mischief that goes on and they have no part of it. And they made a slight tweak to make it much better in my estimation. And so I wrote the, the pandemic came around. I said, well, we’re not in court. So I spent another six months updating it and wrote two new chapters and wonderful 200 new cases and refined a lot of the things that I learned during the federal rules committee hearings. And it’s, it’s a powerful tool. And it’s actually for the benefit of both sides, because it can cause. Cut the cost dramatically, efficiently get to the issues, but what a lot of people who will pose it, don’t like is it really cuts at, and sometimes the eliminates the gamesmanship that’s. So if wires think that that’s what their job is.

Chris Dreyer

Yeah. So I can just imagine it. It’s just the, the other side wanting to kick the can down the road. Just keep kicking. It keeps going.

Mark Kosieradzki

Oh, they do. And then time runs out and you don’t get the information. And one of the things I tell my friends who teach in the trial schools, which I’ve taught it also, but there’s one thing that’s much more important than eloquence. Great closing arguments, brilliance, and it’s called evidence. If you don’t have evidence, you’re not going to everything else was empty rhetoric. So, right. So 36 is all about getting the evidence. So you can really go to town with those rhetorical skills that you’ve hold over the years.

Chris Dreyer

Absolutely. Mark, it’s been such a pleasure having you on the show. Where can people pick up your books? Not just your 30 (B)(6) book, but, but all of your books and how can they get in touch with

Mark Kosieradzki

you? Okay. Well, 30 (B)(6) at is part of trial guidance and all you have to do is Google trial guides 30 (B)(6) and it’ll pop up. Same thing with my book on nursing hall. That’s a trial guides book for the people who do day-to-day litigation, car wreck litigation, fall downs, plus people who do complex litigation. My book deposition obstruction breaking through. Is available from a J press. And that deals with, how do you deal with lawyers who try to just get in the way of you asking legitimate questions and depositions? That’s a book that goes to every kind of litigation there is. 30 (B)(6) goes to cases that deal with institutions and nursing home obviously goes to nursing home cases. The way to get hold of me as my office number is 7637467800. And I’m at Mark@koslawfirm.com. I’m always happy to help people with cases, you know, I talk to people all the time. Sometimes I joined trial themes to help them with the 30 (B)(6) and discovery planning. I’m happy to help drive the case too, but. At this stage of my life, I don’t have to have that. I’m much more interested in the chess moves because that really makes the difference when you get the evidence. And once you get the evidence, the chances of you trying the case go down pretty dramatically.

Chris Dreyer

Mark. Thanks so much for coming on the show.

Mark Kosieradzki

Thanks for having me.

Chris Dreyer

Mark is a true expert when it comes to 30 (B)(6) and it was so great to pick his brain and learn all about the rule and how it can be effectively put to you. If you’re interested in incorporating these depositions into your practice, check out Mark’s book or his lectures on the subject. It’s never bad idea to have another tool in your tool belt. I’d like to thank Mark Kosieradzki from the Kosieradzki Smith law firm for sharing his story with us. And I hope you gained some valuable insights from the conversation you’ve been listening to the personal injury marketing mastermind. I’m Chris Dreyer. If you like this episode, leave us a review. We’d love to hear from our list. I’ll catch you on next. Week’s PIMM with another incredible guest and all the strategies you need to master personal injury marketing.

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