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Flatten the Research Curve

Flatten the Research Curve

Wolters Kluwer

Ed. Note: Welcome to our daily feature Trivia Question of the Day!

According to data collected by ALM for their 2020 Am Law 200 ranking, which firm saw the largest percentage increase in gross revenue?

Hint: This firm, founded in 1905 and operating primarily in the Southeast U.S., went up an insane 31.2 percent in gross revenue. 

See the answer on the next page.

We really appreciate the difficulties that people are going through and that people may take a less than optimal job because they have financial concerns. No one holds your job against you particularly at the early part of your career.

— David Muraskin, a 2009 graduate of Stanford Law School, offering advice to 2020 law school graduates who may unexpectedly find themselves out of work due to the COVID-19 pandemic. Muraskin currently works as the Food Project litigation director at Public Justice and teaches at George Washington University Law School and Vermont Law School.

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Staci Zaretsky is a senior editor at Above the Law, where she’s worked since 2011. She’d love to hear from you, so please feel free to email her with any tips, questions, comments, or critiques. You can follow her on Twitter or connect with her on LinkedIn.

U.S. District Judge Robert E. Payne has had it with California Congressman Devin Nunes and his wacko libelslander lawyer Stephen Biss. Twice on the same day, Judge Payne told Nunes to take his nonsensical lawsuit against the media to a jurisdiction which bears some actual relation to the case and quit gumming up the works in Virginia’s Eastern District.

Nunes, who is on a mission to protect the First Amendment with a mountain of garbage suits against the “liberal media,” likes to file in Virginia state court, where the anti-SLAPP law is weak, or in the Eastern District of Virginia where the “rocket docket” is fast. It also happens to be the jurisdiction where Biss is barred. What a coincidence!

Nunes has sued both Twitter and his hometown paper the Sacramento Bee, via its parent company McClatchy, in Virginia, alleging that the ability to read the allegedly defamatory statements in Old Dominion is nexus enough. The argument over venue in the Twitter and McClatchy suits continues, but Judge Payne has now transferred another two of Nunes’s suits, this time against CNN and the Washington Post, to New York and DC respectively, citing lack of connection to his courtroom.

Nunes alleged he was defamed by CNN which ran a story in November citing Rudy Giuliani’s associate Lev Parnas, who claimed that Nunes met with disgraced Ukrainian prosecutor Viktor Shokin in Vienna in 2018. According to Nunes’s histrionic complaint, the network knew that Parnas was not a credible source, but ran the story anyway because “CNN is the mother of fake news. It is the least trusted name. CNN is eroding the fabric of America, proselytizing, sowing distrust and disharmony. It must be held accountable.” He claims to have been damaged with his California constituents to the tune of $435,350,000, demands venue in the Eastern District of Virginia because CNN’s story could be read there, but insists that his case should be adjudicated under New York law. Because … sure, why not.

The suit against the Washington Post concerns a February 20, 2020 article about a House Intelligence Committee briefing on Russian interference to aid Donald Trump’s re-election, which infuriated the president and resulted in the dismissal of Acting Director of National Intelligence Joseph Maguire. Nunes alleges that Shane Harris — but not Ellen Nakashima, Josh Dawsey, or Ann Gearan, the other authors of the piece — defamed Nunes by claiming that he told Trump about the briefing. According to the complaint, “Harris is well-known as a puppet of the FBI and CIA, employed to selectively leak talking points and classified information and to smear targets.” Nunes demands $250,350,000 for damage in the eyes of his California constituents, with venue in Virginia, but adjudicated under DC law. Because, again … sure, why not.

Well, apparently, Judge Payne can think of one or two reasons. In the Post ruling, he notes that the fact that the paper was physically printed in Virginia and could be read there is a “tenuous connection [] insufficient to give significant weight to Nunes’s choice of forum.” Nor was he impressed with the congressman’s argument that, as a member of the House Intelligence Committee he has oversight of the Office of the Director of National Intelligence, which is located in Virginia. And His Honor was singularly unimpressed with the argument that transfer to DC, where Nunes actually works, “would accomplish absolutely nothing more than merely shifting the balance of inconvenience to [Nunes.]”

In the CNN ruling, Judge Payne was even more direct.

[T]he Court has significant concerns about forum shopping, especially given that Nunes works in Washington, D.C., not Virginia. As the Court has explained to Plaintiff’s counsel on numerous occasions, the ‘Court cannot stand as a willing repository for cases which have no real nexus to this district. The ‘rocket docket’ certainly attracts plaintiff(s), but the Court must ensure that this attraction does not dull the ability of the Court to continue to act in an expeditious manner.”

But before shoving them out the door, Judge Payne unsubtly reminded Nunes and Biss that frivolous, abusive motions may result in sanctions, both for the litigant and his counsel. In both rulings, the judge quoted an admonition issued to Biss in yet another inane SLAPP suit filed by Biss in EDVA, saying:

It is with chagrin that [the] Court must begin to address this motion by observing that . . . Plaitiff[] engages in ad hominin attacks against [CNN and others in the Amended Complaint,] which the Court cannot tolerate. . . . The Court reminds Counsel for Plaintiff[] that, as an officer of the Court, he may be sanctioned for engaging in conduct unbefitting of this Court.

AHEM.

Memorandum Opinion [Nunes v. WP Company, LLC, No 3:20-cv-00146-REP (E. D. Va. May 21, 2020)]
Memorandum Opinion [Nunes v. CNN, No. 3:19-cv-00889-REP (E. D. Va. May 21, 2020)]

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Elizabeth Dye (@5DollarFeminist) lives in Baltimore where she writes about law and politics.

Last year, on May 28, I got a weird phone call from my buddy Sergio. Weird for a number of reasons, starting with the fact that it was actually an incoming call from someone my own age rather than a text message.

“You hear about Matt?” Sergio said. I had not heard about Matt. Matt was dead.

I didn’t believe him, at first. Sergio didn’t know all the details, something about Matt having trouble breathing at work so they took him to the hospital. Matt was by no means a paragon of health, but the guy was only 31, and he could skate circles around me on the ice. It didn’t feel real. I’d certainly fallen for pranks (that were not always in good taste) at the hands of my friends before, repeatedly, like for multiple decades. I wouldn’t put it past them.

But six days later, I was looking at a little box that contained all that was left of my friend. I went over and tried to tell his mother what a difference her son had made in the lives of his friends. In my life. I worried I didn’t say the right things.

Matt and I were both in the trumpet section in the high school marching band, and we both liked Green Day. Years later, we’d get together in the Twin Cities with the boys and do cookouts all summer long. Matt liked to grill. He preferred salmon, although I usually got something much less expensive for myself, like brats, having become quite a cheapskate during law school. In the fall, I’d always cook a turkey for Matt and his roommates and whoever else showed up — my first employer after law school gave away turkeys at Thanksgiving, and that started a decade-long tradition for us. I got pretty good at making gravy.

Have you ever gotten drunk with your friends and rented kayaks? Try it — really fun (put on a lifejacket first). When Snapchat came out, Matt would use it to film people who’d be just rounding a corner at the house as he blew an airhorn. The end of every video would be him giggling like a schoolgirl. He was always a solid wingman on a double date. One time, we ran into a bachelorette party at Toby Keith’s I Love This Bar and Grill, and that’s a great story I won’t tell right now, because people in his family might read this. Another time, we just went to an Applebee’s because there was nothing else to do and told dad jokes to each other for like three hours.

Q: What did Abraham Lincoln say before he went to Ford’s Theatre?

A: ‘I need to see this play like I need a hole in my head.’

*pause for effect* Too soon?

We’d watch the Vikings and him or his brother or I would blow a ringing note on the horn — literally a bull’s horn fitted with a mouthpiece — whenever there was a touchdown, and also just periodically from time to time for no reason at all. He’d get out his mandolin and strum it during the commercials. As Matt got older, he grew out his hair and beard and increasingly resembled a Viking himself. Half the time when I cruised up on my motorcycle, he’d be outside, and he always smiled when I pulled in.

That was far from the first time I’ve lost someone unexpectedly. And, unless I’m next, it won’t be the last. But this doesn’t get easier. You just carry it around with you.

As we approach 100,000 coronavirus deaths in the U.S. (we might actually hit that number on the anniversary of my friend’s death), I think of how random and cruel it was that Matt had to die. But while these deaths we’re now facing are certainly cruel, they’re not all so random. We know, generally, who’s most at risk. We are capable of tracing many of these cases back to a particular source. And while I’ve been as wont as anyone to voice frustration about all the pandemic restrictions, you know, I’ve been bearing them a little easier these days. Maybe just wearing a mask to the store could save someone like my friend. A little extra beard itch for a few months is a pretty small price to pay for that.

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Jonathan Wolf is a litigation associate at a midsize, full-service Minnesota firm. He also teaches as an adjunct writing professor at Mitchell Hamline School of Law, has written for a wide variety of publications, and makes it both his business and his pleasure to be financially and scientifically literate. Any views he expresses are probably pure gold, but are nonetheless solely his own and should not be attributed to any organization with which he is affiliated. He wouldn’t want to share the credit anyway. He can be reached at jon_wolf@hotmail.com.

Grab some popcorn, pull up a chair, and watch the Georgia Supreme Court hold oral arguments by videoconference! The case? What happens when a sperm bank sells bad sperm? In this case, the sperm bank is alleged to have sold sperm provided by a donor who lied about his IQ, professional background, and criminal history. Even more, a child who was conceived with his donated sperm has genetic conditions allegedly passed down by the sperm donor.

While the justices asked the hard questions of the attorney for the parent plaintiffs, the justices really went for the jugular with the sperm bank’s attorney.

The case is styled Norman v. Xytex, and oral argument took place on May 21, 2020. Readers may recall this case, where hopeful parents chose sperm from Xytex Donor 9623, thanks to Xytex’s profile of a donor with stellar credentials: a clean health record, 160 IQ, PhD student, and proficiency in four languages. Impressive!

Too bad none of those were true. Instead, when 9623’s identity was accidentally revealed by the sperm bank, some quick research found him to actually be a felon and college drop-out suffering from bipolar disorder as well as schizophrenia. In fact, while 9623 checked “no” on Xytex’s questionnaire as to whether he had any history of mental health issues, he had been hospitalized multiple times for mental illness prior to first donating with Xytex. If the donor had been truthful, or if any of this information was known to potential recipients — as the justices point out — donor 9623 would not have been anyone’s choice source for donor sperm.

Not knowing any of this, the plaintiffs chose Donor 9623’s sperm, and conceived a son from his sperm. Their son has suffered severe mental health issues, and the plaintiffs are asking for the sperm bank to pay the costs related to their son’s mental health treatment.

Since bringing suit against Xytex, the plaintiffs have had a rough road. The trial court and the Georgia Court of Appeals both dismissed the plaintiffs’ claims, finding that they amounted to “wrongful birth” claims, which are barred in the state under an old Georgia Supreme Court case called Abelson. In Abelson, a doctor negligently failed to diagnosis the in utero condition of a fetus. When the parents brought suit, the court found it against public policy to award damages based on the missed opportunity to abort a human life. In Abelson, the parents conceded that the doctor’s failure didn’t affect the health of the child; the only difference was that if the doctor had not been negligent, the parents would have had the option to terminate the pregnancy.

Law Professors Weigh In.

An amicus brief was submitted on behalf of 38 law professors in support of the plaintiffs. In the brief, the professors argue that it would be mistake for the Georgia Supreme Court to apply Abelson in a case like this.

First, they point out that in Abelson, unlike here, the conception and the condition of the fetus existed prior to and regardless of the doctor’s negligence.  And in Abelson, the plaintiffs argued they would have terminated the pregnancy if they had been given an accurate diagnosis. Here, if the plaintiffs had full information as to the donor, they would not have terminated an existing pregnancy, but instead would have simply chosen a different donor.

Second, unlike in Abelson, the plaintiffs are not claiming that their injury is predicated on the birth or life of their child. The plaintiffs do not ask for the ordinary costs of raising a child, but for the extraordinary costs (mental health treatment for their son) relating to the defendants’ alleged wrongdoings. The law professors point out that Georgia courts routinely award compensation to parents for costs related to a child harmed by a defendant.

Plaintiffs Can At Least Recover The Cost Of The Sperm, Right?

The plaintiffs paid approximately $1,600 to Xytex for Donor 9623’s sperm. Forget the extraordinary costs issue for a second; at oral argument, the Georgia Supreme Court justices really wanted to understand why, if the plaintiffs indeed could prove wrongdoing by the defendants, Xytex wouldn’t at least be responsible for paying the $1,600 in fees back.

The sperm bank’s attorney, to the justices’ frustration, was not about to concede that a sperm bank would ever owe fees back — regardless of the various proposed alternative fact scenarios proposed by the justices. And while never wanting to concede, even on a minimal amount, is perhaps instinctual for an attorney; here, the failure to adequately respond to this point might have undermined the credibility of the defendant’s counsel.

As argued on the amicus brief, pure civil immunity in this context would be a strange result. It might also entail negative consequences for both public health and child welfare, if sperm banks could make knowingly false representations about the sperm they sell. One Supreme Court justice went so far as to tip his hand, by saying “that can’t be right” during the oral argument.

Professor Jody Madeira, one of the amici, was optimistic that we’ll see the Georgia Supreme Court reverse the lower courts’ opinions here. “Watching these oral arguments made me hopeful that, at last, it might be possible to hold gamete banks liable for the type of negligent behavior that in any other context would be slam-dunks for the plaintiffs.” After all, sperm banks are in a unique position in this context. Their negligence can have long-lasting consequences for both the children conceived with the sperm and their families. And sperm banks hold the power in any transaction. That’s partly because sperm is still frequently sold as anonymous, and clients are completely reliant on the sperm bank’s vetting of the donor. That’s why, like most other people or businesses, sperm banks, too, should be subject to appropriate liability when negligence — or worse — can be established.

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Ellen Trachman is the Managing Attorney of Trachman Law Center, LLC, a Denver-based law firm specializing in assisted reproductive technology law, and co-host of the podcast I Want To Put A Baby In You. You can reach her at babies@abovethelaw.com.

In addition to zooming more than I ever wanted to zoom, I am reading about pandemics. I know I am not the only one. The topic fascinates me, and the books try to help me understand what is going on and why. My list includes two novels: Station Eleven by Emily St John Mandel and The End of October by Lawrence Wright, and two works of nonfiction, The Great Influenza by John Barry and Pale Death by Laura Spinney. Suggestions for others gratefully accepted.

Part of my fascination is imagining what our world will look like once the lockdown is behind us and we get on with whatever the “new normal” may be. We dinosaurs remember the years before 9/11 when we could accompany family and friends to the airline gate to see them off and be at the gate to welcome them home. Does anyone else of similar vintage remember those days? Yes, kids, there was such a time. Gone forever.

My ADR provider has had weekly zoom meetings to update its panel on the state of the courts, when they might reopen and what they will look like when they do. The provider also talks about when their offices might reopen, still to be determined, and what steps will be taken to ensure everyone’s safety and well-being, from the parties and their counsel, to the neutrals, to the staff. Given that we are in Los Angeles County, face masks and social distancing will be the way of the world for some time to come.

So, the question then becomes how to conduct mediations? Option A: Go into the office and know that I can’t shake hands, have to sit at least six feet away from however many counsel and parties there are (that can be a logistical nightmare depending on how many) and be unable to get “up close and personal” when it’s needed. Several times when a case has settled at mediation either the plaintiff or defendant or both wanted to hug me in relief because the case is finally over. (At least I think that was the reason.) Obviously, personal contact is verboten.

How much facial expression can I see if there are masks covering everything but the eyes? Yes, I know the saying that the eyes are the window to the soul, but are the eyes sufficient, do they tell me enough?

Option B: use Zoom or whatever other method to conduct mediations. What do you think about that? Would you use that method or prefer to mediate face to face, to the extent possible these days? A recent unscientific poll showed that judicial officers favored Zoom over any other remote online platform.

Right now, I think that mediating via Zoom or whatever other platform is safer from a health perspective. Upsides? No need to commute to an office, no need to worry about face masks, and no need for social distancing from your client and the mediator. Downsides? You and your client are not in the same location, so you can’t deliver that gentle (or not so gentle) kick under the mediation table when your client says more than he should. Security issues that have arisen with Zoom bombing seem to have receded.

From this mediator’s perspective, depending upon how the video is positioned, Option B doesn’t necessarily see body language. Fidgeting, leg jiggling, and other physical tics below the neck may offer clues that aren’t picked up otherwise.

And then there’s the age-old issue — older than mediation — getting the parties and counsel to agree to use this technology to try to get the case settled. Just as expected, some counsel are comfortable using it, while others are fearful. Is the case at the point where it is ready to settle and are parties and counsel ready? What’s the cost/benefit analysis of waiting some lengthy period of time for a trial date? From a plaintiff’s perspective, the answer is usually “there is none,” while a defendant’s perspective is often “we have the money, let’s keep it until we absolutely have to let it go.” Other defendants may roll their eyes as the legal fees continue to mount and would rather pay the plaintiff something than continue to pay their attorneys.

Even when the state courts do finally get back in business, Zooming will be the way of the legal world for many things. Case management conferences and motions are already being heard remotely and have been prepandemic. Jury trials? A Texas court has conducted a nonbinding summary trial on Zoom, with the hope that the case will settle at mediation. Even if nonbinding the jurors’ decision may make settlement easier as it indicates how a full-blown trial might play out.

There’s been so much talk about legal innovation and how to apply it to the practice. Here is a perfect opportunity to see if legal innovation works in the context of a jury trial. California has had a summary jury trial procedure, but it’s been barely used. Given our herd mentality, I am not surprised. Thoughts of a lesser verdict, if one at all, and potential malpractice liability clutter the mind.

Will many people physically show up for jury duty in these pandemic times? It’s not just going through security, but what about temperature checks, people who are asymptomatic? Who will want to sit in a jury assembly room with hundreds of others, when you are clueless as to whether they are taking (have taken) similar precautions to stay safe? Just the thought of using a restroom in a courthouse may well be taking your life in your hands. The less said, the better.

So someone must lead the innovation, to take the risk, to try something new. I think Zoom jury trials may be the coming wave. How else are we going to get going again?

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Jill Switzer has been an active member of the State Bar of California for over 40 years. She remembers practicing law in a kinder, gentler time. She’s had a diverse legal career, including stints as a deputy district attorney, a solo practice, and several senior in-house gigs. She now mediates full-time, which gives her the opportunity to see dinosaurs, millennials, and those in-between interact — it’s not always civil. You can reach her by email at oldladylawyer@gmail.com.

The ongoing COVID-19 pandemic has impacted every part of daily life, and most of us have socially distanced and worked from home to reduce the spread of the virus. As detailed on this website in numerous prior articles, many legal issues have also cropped up because of COVID-19, and lawsuits have been filed due to closures related to the pandemic and executive orders designed to slow its spread. Some employers and government agencies have also taken action against individuals based on their COVID-19 status, and additional measures will likely affect people depending on whether they have recovered from COVID-19. The situation has made me wonder whether COVID-19 status should be a protected classification so that government agencies, employers, and others cannot arbitrarily take action against someone because of their experience with the virus.

I recently became more aware of the misunderstandings and stigmas individuals may face because they have recovered from COVID-19. Indeed, I discovered a few weeks ago that I have COVID-19 antibodies, which were presumably the result of an illness I experienced in March. I do not want to spend too much time discussing my own experience with COVID-19, since my symptoms were relatively mild, and David Lat (who is a much better writer than I am) has already written compellingly about his experience with COVID-19 on these pages. However, I have been frustrated with some misconceptions about individuals who have recovered from COVID-19. People seem to hold erroneous beliefs about how long individuals may be contagious after they recover, whether there is always permanent harm from COVID-19, and other issues. I confess that before I knew I had COVID-19 antibodies, I was much less informed about the virus.

In any case, people who have recovered from COVID-19 already face significant disadvantages, even if they have fully recuperated from the virus. For instance, the military announced several weeks ago that recovering from COVID-19 would be a permanently disqualifying condition for entrance into the armed services. Although the military later clarified that such a disqualification would only apply to individuals hospitalized because of COVID-19, many people who have recovered from the virus will face obstacles to joining the military due to these restrictions.

Presumably, recruits could apply for a medical waiver, but as someone who has gone through the military medical waiver process twice (once successfully and once unsuccessfully), I can say firsthand how frustrating, arbitrary, and time-consuming this process can be. Furthermore, and I am not a physician (though if I can kvell, my triplet brother is a pulmonologist and critical care physician who has given me useful info about the virus), but many people who recover from COVID-19, even if they are hospitalized, will have no permanent health issues. Of course, some people with permanent issues because of COVID-19 may not be healthy enough for military service, but this example shows how just the status of having COVID-19 can impact your opportunities. In addition, if the military is restricting employment because of an applicant’s COVID-19 status, it is possible that law enforcement agencies and other government entities may make it difficult for applicants to secure jobs if they ever had COVID-19.

In addition, people who never had COVID-19 can also face disadvantages. The jury is still out about whether recovering from COVID-19 confers immunity, and how long-term and durable this immunity may be. However, many are operating under the assumption that recovering from COVID-19 confers some kind of immunity, and that individuals with antibodies should be allowed to leave quarantine first. In fact, there are some talks of governments issuing immunity certificates or immunity passports to people with COVID-19 antibodies so that they can more easily return to work, travel internationally, and perform other activities that are currently restricted. Indeed, some commentators have suggested that people with COVID-19 antibodies should be given preference for certain frontline jobs because they may have some level of immunity to the virus.

However, it is unfair to disadvantage people because they have never had COVID-19. Such individuals are likely following social distancing guidelines and are making sacrifices in order to flatten the curve. Furthermore, in a worst-case scenario, conferring benefits to people who have COVID-19 antibodies may incentivize individuals to be exposed to COVID-19! Although this might sound unrealistic, it is definitely a possibility that should be considered.

I am not an expert on discrimination laws, but it seems possible that existing laws relating to disabilities may apply to COVID-19 status, depending on the situation and how severe a person experiences symptoms and disabilities relating to COVID-19. In addition, as more people experience COVID-19, and as additional information about the virus becomes available, there may be fewer restrictions based on someone’s COVID-19 status.

All told, it is clear that businesses and governments are considering limitations and benefits depending on a person’s COVID-19 status. Such measures may be reasonable in some situations and unfair or capricious in others. In any case, it is important to contemplate how such measures may run afoul of existing protections, and new safeguards may be considered so people are not treated arbitrarily based on whether they have recovered from COVID-19.

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Jordan Rothman is a partner of The Rothman Law Firm, a full-service New York and New Jersey law firm. He is also the founder of Student Debt Diaries, a website discussing how he paid off his student loans. You can reach Jordan through email at jordan@rothmanlawyer.com.

The saga of Superior Court of New Jersey Judge John F. Russo Jr. is, at long last, over. Back in 2018, we first told you about Russo, who was in hot water for some wildly inappropriate questioning of an alleged sexual assault survivor. And, the questioning was downright shocking.

As a refresher, at a hearing the defense asked the woman about the alleged assault, when Russo took over questioning and things took a turn:

RUSSO: Do you know how to stop somebody from having intercourse with you?

WOMAN: Yes.

RUSSO: How would you do that?

WOMAN: I’d probably physically harm them somehow.

RUSSO: Short of physically harming them?

WOMAN: Tell them no.

RUSSO: Tell them no. What else?

WOMAN: To stop.

RUSSO: To stop. What else?

WOMAN: And to run away or try to get away.

RUSSO: Run away, get away. Anything else?

WOMAN: I — that’s all I know.

RUSSO: Block your body parts?

WOMAN: Yeah.

RUSSO: Close your legs? Call the police? Did you do any of those things?

It was recommended by a three-judge panel that Russo be removed from office for “severe misconduct” following multiple incidents, including the “close your legs” comment. This was after the state supreme court’s Advisory Committee on Judicial Conduct also found inappropriate behavior but was split on the proper punishment.

Yesterday, the Supreme Court of New Jersey ordered Russo’s removal from the bench, and they didn’t mince words in condemning Russo’s actions:

Viewed together, Respondent’s multiple acts of misconduct have lasting consequences. His pattern of misconduct and unethical behavior not only undermined the integrity of different court proceedings but also impaired his integrity and the Judiciary’s. His overall behavior reflects a lack of probity and fitness to serve as a judge. And his conduct breached the public’s trust.

It is inconceivable that Respondent could sit in judgment in domestic violence or sexual assault matters in the future. No reasonable victim could have confidence in a court system were he to preside over those kinds of cases again. Nor could any objective, informed member of the public. For the same reasons, public confidence in the integrity and independence of the Judiciary would be undermined if Respondent were to preside over other types of cases. Legitimate concerns about integrity, ethics, and public confidence extend to all areas of the Judiciary.

Good to see the Supreme Court of New Jersey got it right.

Read the full order below.

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Kathryn Rubino is a Senior Editor at Above the Law, and host of The Jabot podcast. AtL tipsters are the best, so please connect with her. Feel free to email her with any tips, questions, or comments and follow her on Twitter (@Kathryn1).