fbpx

The Personal
Injury Mastermind

The Podcast

185. Mike Alder, AlderLaw — Maximizing Existing Cases: When To File, Even For Pre-Lit Firms

How do you get more value out of existing cases? File them. If the insurance adjuster is being unreasonable or unfair, there is a good chance they will try to settle for pennies on the dollar. To get full value, Michael Alder advocates filing early and often. The Owner of AlderLaw  (@alderlaw) has recovered over $1.7 Billion dollars for his clients. And never backs down from a fight.

Today he digs into the appropriate time to file cases – even if you’re a pre-lit firm. Why depositions are more important than closing arguments, and how to get the financial help you need to try cases successfully. 

Links

Want to hear more from elite personal injury lawyers and industry-leading marketers?

Follow us on social media for more.

What’s in This Episode:

  • Who is Michael Alder?
  • Why you need to establish the caliper of attorney you are from the jump.
  • Why the number of cases filed can increase case velocity.
  • How to get the funding you need to take your case to trial.

Past Guests

Past guests on Personal Injury Mastermind: Brent Sibley, Sam Glover, Larry Nussbaum, Michael Mogill, Brian Chase, Jay Kelley, Alvaro Arauz, Eric Chaffin, Brian Panish, John Gomez, Sol Weiss, Matthew Dolman, Gabriel Levin, Seth Godin, David Craig, Pete Strom, John Ruhlin, Andrew Finkelstein, Harry Morton, Shay Rowbottom, Maria Monroy, Dave Thomas, Marc Anidjar, Bob Simon, Seth Price, John Gomez, Megan Hargroder, Brandon Yosha, Mike Mandell, Brett Sachs, Paul Faust, Jennifer Gore-Cuthbert

Transcript

Michael Alder:

It is the most important skill by a large factor.

Chris Dreyer:

Your first impression matters so much. It can determine the value of your case even before you step foot in the courtroom.

Michael Alder:

If we pre-lit ask to disclose insurance limits and they don’t, we file. If we believe that this adjuster’s not going to be reasonable, file. If they have a video of a dash cam and they won’t provide it, file. I am teaching the other side what kind of leopard I am.

Chris Dreyer:

Welcome to Personal Injury Mastermind. I’m your host, Chris Dryer, founder and CEO of Rankings.io, the preeminent personal injury marketing agency. Each week you get insights and wisdom from some of the best in the industry. Before we get started, hit that follow button so that you never miss an episode. Ready to dominate your market? Let’s go. How do you get more value out of existing cases? File them. I know you’re thinking, “Wait, if I’m a pre-lit firm, why would I file a case?” Hear me out. Insurance companies don’t have your best interest at heart. And adjusters aren’t going to give you max value from the jump. Shocker, I know. If the insurance adjuster is being unreasonable or unfair, there’s a good chance they will try to settle for pennies on the dollar. To get max value, according to Mike, you got to nip that behavior in the butt.
The owner of AlderLaw has recovered over 1.7 billion for his clients, and he’s one of the best litigators in the state of California. Over two decades of successful litigation has taught him invaluable lessons which he shares today. Mike digs in into the appropriate time to file cases, even if you’re a pre-lit firm, why depositions are more important than closing arguments, and how to get financial help you need to try cases successfully. Here’s Mike Alder, owner at AlderLaw on how he first got into law.

Michael Alder:

When I was in college, I didn’t know any lawyers. My parents were teachers. I had a path to become a teacher. And, I met someone, and they said on the front lawn of a fraternity as I’m drinking, they go, “Well, what do you want to do?” And I said, “Well, I’d like to have another beer. What do you want to do?” She said, “Oh, I’m going to go to law school. I’m going to become an entertainment lawyer. And, I’m going to move to LA.” That was the start of my legal career. Sorry, it’s not more exciting than that, but.

Chris Dreyer:

Everyone has a story. A lot of times it’s the father, hey, they’re following their footsteps. And, I like asking that question, because it’s so different, everyone that answers it. I want to jump right ahead. What pulled you to create your own firm and step out on your own?

Michael Alder:

Well, is this a real show or the Instagram fake show? If it’s a real show? I got fired. I had been working for my mentor for a long time, who I think a lot of people acknowledge, certainly I do as the greatest trial lawyer I’ve ever seen. A guy named Michael Pugh. And, he’s trained in LA, Gary Dordick, John Taylor, Jeff Wells, Pat McNicholas. We all went through Doug Shaffer. We went through the Pew School. But it’s not a lifetime path. And he made that clear and it ran its course. And so, fortuitously he fired me. Or, I got back from a long trip and none of my stuff was in the office anymore. So, I assumed that. So I wrote him a wonderful note and I said, “Look, I’m sorry it ended this way, but I got to tell you, you are the most amazing lawyer. You’ve taught me the most that I could ever imagine. You have set me up for my legal career, and I so appreciate it.”
And then started my own firm out of my house with one case. I remember I was in a building on Ventura Boulevard in the valley in a mailbox, et cetera, but this one they called their mailboxes suites. So I was in suite 101. Two years later, that building got torn down. But by that time I had an office.

Chris Dreyer:

You’ve got some legendary trial results. You’re personally involved in every case your firm takes on. How do you manage to make time for that? What goes into the extent that you’re involved in these cases?

Michael Alder:

As your practice matures and you get more cases, it’s harder to be “personally involved” in every case. And in fact, we reached a point just recently, I’d say, maybe six to eight months ago, where I thought that we had too many cases. Because, while the quantity was there, the quality suffered. Because, I felt like we weren’t paying enough attention, and I was not involved in as many of the cases as I could be. So we’ve used technology, we’ve learned from the Mike Morse’s of the world, the [inaudible 00:05:02] today, some of the people you probably have interviewed the Chad Dudleys, Dudley DeBosier. Primarily now we use Slack as creating a channel for every case. We have our case management software that we’ve hired. You may know Vista Consulting, Baton Rouge, Tim K, Heather Carroll, and they’ve helped us identify the projections, and the values, and the grading of different cases.
And so I can print that as it’s updated, and then I’ll use that and go with Slack that has everybody on the particular team that’s on that case, “Hey, what’s going on? What’s happening next? How can I be involved? What’s the damages? What’s the liability? Let’s talk about that. Hey, do this.” That stuff. And that allows me to at least stay on a higher level experience strategy, plus motivation of keeping the case going. But then, on the really significant larger cases, obviously I’m more involved in. I mean, I’m at the ground floor. I love taking depos. So, if I’ve got a free day or a free day next week, I’ll just send a firm-wide email and say, “Anybody got any depos they got coming up? I’d love to do them.”

Chris Dreyer:

I had Chad on. Chad Dudley, we were talking about those top 5%’s and how do I identify those? Because a lot of times that could be half the firm’s revenue, whether it’s a pre-lit firm or a trial firm. And, I want to get into pre-lit, it lends itself more to productization, run them through the assembly line, you’re not getting maximum value. It’s focused on cashflow and these averages. Like, “Here’s the average of this case typically results, versus the trial.” You’re getting maximum value. So you said quantities before, and I want to lean into that, because if I’ve talked to a Mike Morse and he’s saying, “Well, my pod can handle 70 cases.” I can’t remember the exact number. A pre-lit firm may need 250 cases to do good, where the case selection criteria of a trial, someone that’s actually going to trial may need significantly less, because you’re getting a lot more value.

Michael Alder:

We only have pre-lit cases. If the adjuster, defense lawyer, third-party administrator is treating us fairly, or we think we’re going to be treated fairly. If we get any hesitation, any inkling that they’re not going to treat us fairly, we file. So, we get a significant amount of cases that are already in litigation that right before experts, that they need trial expertise, they need litigation help, or they need financial help. But it’s also a big percentage is early on, and I’m a big believer in, leopards don’t change their spots. Every one of us is looking at everybody else and sizing them up pretty quickly. And we all believe that leopards don’t change their spots.
So, I’m going to a law school this afternoon. I’m going to say, “Hey, if you go on a blind date. Let’s say a woman is waiting for a blind date and the guy shows up late, he shows up disheveled. Right? He may have a very legitimate reason for that. But statistically, you realize that more likely than not, at least, certainly probably more than that, they don’t give a crap about this. They’re not reliable, because we know that leopards don’t change their spots. In other words, you show up late for a meeting, that usually means you lack motivation, you’re not organized, you’re not this, you’re not consistent, you sleep late, et cetera. Right?” Do you agree with that?

Chris Dreyer:

A 100%.

Michael Alder:

The best people about determining what kind of leopard you are, are insurance companies, because they deal with tens of thousands of lawyers and cases. And they know that if a lawyer does, or a law firm does X, Y, or Z, that statistically they’ll do X, Y, and Z later. Right? And it doesn’t matter if you have a good reason for doing X, Y, or Z. Statistically, they know it doesn’t matter. So for example, if you say, “Well, I’m not going to file because my client’s still treating, and I’m going to wait till the statute and file right before the statute.” You’ve already told the insurance company what kind of leopard you are. And they know that that kind of lawyer is not going to go to trial, not going to spend money on cases. “If we wait them out, they’re going to fold, or they’ll take a low offer.” Right?
Conversely, and this is our philosophy, if we pre-lit ask to disclose insurance limits and they don’t, we file. If we believe that this adjuster’s not going to be reasonable, a rear end accident. “Well, we believe the plaintiff stopped early and was 10% at fault.” File. If they have a video of a dash cam and they won’t provide it, file. It’s so important, because those types of things in addition to file serve and in California or whatever jurisdiction, the very earliest that you notice depos, you notice them. Of course, it’s going to be unilaterally set.
And when they squawk and say, “We’re not available.” Then you say, “Well look, I’m happy to move it as soon as you give me a date that’s relatively close in time, I’ll move it to that date. Oh, by the way, my client’s available for depo right now. You want to do a medical exam? You don’t need to give me statutory notice. They can show up tomorrow. Find the doctor you want.” “Oh, Mike, aren’t you giving away the farm?” No, I am teaching the other side what kind of leopard I am. And so, because of that, we don’t have a lot of pre-lit cases. If your case is significant, it ain’t going to settle for real value pre-lit, period. If you got a slip and fall case, it ain’t going to settle pre-lit for full value. If you’ve got a $500 million policy, it ain’t going to settle pre-lit for full value. They could give a crap.
So, we know that when there’s certain types of cases, or certain behaviors, we move right into litigation. And as an aside, I’ve met with, I don’t even know how many young lawyers starting their practice, and I always say, “Let me come to your office.” “Mike, you want to come to my office? We’re in LA. How are you going to drive all…” I’m like, “Look, let me come to your office. I want to see your setup.” And, I could not tell you, Chris, how many young lawyers that I go to and I’m like, “How many cases do you have there?” “30.” I’m like, “How many are pre-lit?” “28.” I said, “I’m going to come back in two weeks. I want you to come back and tell me on each one, do you think the adjuster is treating you fairly or will treat you fairly?”
These are pre-lit adjusters, right? “And then, I’m going to have you file a lawsuit and every one that you don’t believe is treating you fairly or will.” “Oh, Mike, but that’s $800 a case.” I said, “I will loan you the money interest free, because I know if you do what I say that you are going to settle 70% of the cases that if they give you bullshit, you file, you go to a new litigation adjuster or a defense lawyer, especially the cases where you just need another 10 grand or 15 grand, that puts you over the edge. And I’m not worried about you, Stephanie, because you’re going to have more money than you ever had before to give it back to me.” 100% of the lawyers that follow that advice have paid me back and go, “I’ve settled four cases in the last three, four months than I have in the last year and a half.”
What are you doing? Yeah, you’re getting to an adjuster or a lawyer that has more authority or whatever. But really, they’re flagging you up. “Get this guy out of… This woman out of my face. It’s another 10 grand. They’re going to make us spend another 100 grand litigating this case. We’re not going to be able to wait them out. We’re not going to be able to outspend them. We don’t want that case on our radar. We want the billboard lawyers that are no lawyer is touching them that we know are going to take 50 cents on the dollar. I want those people in my network. I don’t want an Alder in my network, or anybody else who’s willing to push.”
And then as the last thing I would say, by far, the most frequent things I get is, “My client’s still treating. I want to wait until my client stops treating. And, I’m not set up for litigation.” And I’ve always found that to be… Yeah, if you’ve got a $15,000 policy, and you need to wait for the MRI, and the ortho, and the this to tell you whatever to pop the policy, great. But if you’ve got a bigger policy, why the hell would you wait until your client stops treating and you tell the insurance company, “Okay, no more issues. Hey, pay me money.” And also, you’re letting time go by. Your client can still treat while you’re in litigation. But I’m going to be in litigation. I’m not set up. 70% of those cases that you’ve been working on pre-lit are going to settle in the first month or two. You’re not going to be inundated with case with work. You’re going to be inundated with money.

Chris Dreyer:

I’ve got so many follow-up questions here. Okay. So Mike, this is fantastic, because I’d always made this distinction of, “Hey, your cash flow suffers when you’re a trial when you’re a litigating firm.” But you’re saying, “No, you’re going to settle these faster, so the cash flow is there.” So, let me put you in a scenario here. Okay? Firms that are a 100, 150 employees, full of paraprofessionals, and they’re not taking any cases to trial, and they’re in this scenario, they’ve got the big office, and they got the desks, how do they transition assembly line to the litigating firm?

Michael Alder:

Well, first of all, what’s their mindset? What’s their goal? Are they interested in them making as much money as possible, or are they interested in helping their clients get as much money as possible? There are many firms that the primary interest is how do the owners of or the people at the top make the most money? And they treat clients differently. They treat them as widgets, right? They don’t need to talk to the client, because they’re a widget and it’s just a bag of money that I need to extract out of that case. If you instead have a mindset of, “I will make plenty of money if I maximize the value for my client.” Now just that mindset change increases the quality of your legal representation. And, you and I know that a case manager is not doing legal work. Certainly, can be very well-educated on certain issues of the law, but that pre-lit legal work is just checking boxes and getting whatever. That’s not legal work. And the carriers don’t look at it as legal work.
So what are you doing for legal work? Well, you need a lawyer to evaluate, “Is it time to file? Are we being treated fairly?” You can’t expect those paraprofessionals, those hundreds of employees to be able to make… Certainly they could if you train them and ask them. But to make those decisions of, “Am I being treated fairly?” Look, I have a lot of friends and I’ve hired people from the insurance business. My managing attorney, Craig [inaudible 00:17:06] was a former managing attorney for farmers in-house counsel in California. There’s no doubt that periodically carriers put out a dictate. I remember AAA said, “We are going to now say the plaintiff is 20% comparatively responsible in all cases, every case, every pre-lit case.” They said, “Well, we believe the plaintiff’s 20% at fault, because they stopped early, they were speeding, they were driving.” Whatever.
And I said, “The only way to stop that is as soon as they say 20% and there’s no comparative, you file.” They go, “Oh, well, we got to… Okay. It works on all these other people that aren’t looking at the case with a lawyer. But for lawyers that look at the file, let’s just pay them.” I am not in any way saying that pre-lit law firms aren’t real lawyers and trial lawyers are real lawyers. I know several pre-lit predominant firms that care about their clients and really do it well. I don’t know if you know Mark Sweet in Orange County. Sweet Law. Not Sweet James, but Sweet Law is a big pre-lit law firm. And, every time we talk, he talks about his clients. I know that he does everything in his power to maximize value for clients. And I totally respect him for that. But we all know the bill firms that don’t. I get it.

Chris Dreyer:

When you have heavy hitting trolley attorneys that you’ve nurtured, you’ve developed that are very skilled, how do you keep them under your firm? And, do you have to profit share? What goes into that?

Michael Alder:

Well, it’s hard, right? Over the 23 years that I’ve had a firm, at some point you nurture young talent, just like I was nurtured, just like every trial lawyer that’s out there, they had a mentor and the student passes the master or whatever. It’s once they start to get a little bit big for the britches, God forbid they get a good verdict, right? They want more money. They want to own a piece of the pie. They want to take care of themselves and their family. And that is something to be encouraged. I have, in the past, followed what my mentor said is when I started working for Mike Pugh, the first thing he said is, “You’re never going to be a partner here. I want you to learn here. But, this is my shop and it’s going to always be my shop.” And so, I’ve had some really excellent lawyers come through my firm, get to that point of, it needs to stop being AlderLaw and become Alder and whatever. And I’m like, “How do I help you start your firm?”
But now, I’ve got some really excellent lawyers in our firm with help of Tim K at Vista and some thought leaders, I am now starting to think about how do I include them in the profit sharing, not just bonuses, but profit. How do they own and take ownership of cases, ultimately taking ownership of part of the firm? Because I want to keep these lawyers. I mean, I want them to be the lawyers I work with for a long period of time. And I put a lot of effort into helping them become the lawyers that they are. That institutional knowledge, I want to keep in the firm, because I know when they do things the way that our firm does it, our clients benefit.

Chris Dreyer:

When Mike first opened his firm, the only thing he knew was trying cases. For the first five years of practice, all of his cases were less than three months from trial. And trial comes with substantial upfront costs. Over the years, good lawyers were running out of funds for trials and coming to Mike for help. Having been there himself, mike started the Warrior Fund.

Michael Alder:

They were afraid of the risk of trial, because if they put too much of their total money into a case and it didn’t come out well, they go belly up. And so, I never wanted money to be a reason why a young lawyer didn’t take a case to trial, because I realized, one, it helps them. Two, it helps their clients. And three, it helps my clients, because the more cases we try, the better everybody is. And so, I just said, “Look, if you’re a lawyer four or five years or less, I’ll pay half of your costs up to 10 grand, and if you win or you settle, give it back to me.” If you don’t, I’ll eat it. And I’ll help you prepare for the trial, strategize, whatever. And that was just like, I experienced that myself. I had won just one trial over the year. Now, all these opportunities, I’m trying now eight figure case…
I mean, And so that was what? 12 years, 13 years ago I started that. Interestingly, I’ve not helped a ton of people. I’d say, maybe 30 or 40 people have taken me up on it over a decade or more.

Chris Dreyer:

Why? Well, what’s the catch? What’s the catch?

Michael Alder:

Every speech I would do at trial, or I would talk about the Warrior Fund, I would send stuff out about it. So many people are looking at, “What are you trying to get overrun?” And I get it. But that’s the impetus. It’s still here. I still do it. I still help people. There are no strings attached. Right? I am a firm believer in good karma, good works, good deeds is a good life and it is good business, period, paragraph.

Chris Dreyer:

I want to switch over to this, because you lit up when you said this earlier. And, you’ve got a database of over 9,000 depositions. What is it about depositions? Tell me about that. Why do you just thrive and love depos so much?

Michael Alder:

Because, it is the most important skill, by a large factor, in being a good litigator, a great litigator. Overwhelmingly more important to your cases, than being a good trial lawyer, than being a good paper lawyer, whatever. And the reason I say that is… And I teach a class now, I’m an adjunct at Loyola Law School on this topic. When the dean said, when I was complaining about, “Law schools don’t teach you shit about pricing law.” He’s like, “I know. How do we do that?” I’m like, “Well, let’s teach a class on depositions.” And, it started that way. And, this fall, it’s expanded to a full professor class.

Chris Dreyer:

Wow.

Michael Alder:

Primarily around litigation strategies. But depos are a huge part of it. Let me tell you why. People want to always come to my closings or read my closings. I’m like, “Nah, don’t read that. Come to a depo. You’ll get way more out of that than coming to my closing argument.” I’ve done a 100 plus jury trials. I don’t even know. I lost track. But I’ve done 10,000 cases. All the non-trial cases settle. So, 99% of my cases settle. In all of those cases that are litigated, there’s a first depo. That first depo, especially pre-COVID. And now, back to in-person is really the first opportunity that you meet the opposing counsel. That you size them up, that they size you up, right? That you get to show who you are. And after that first depo, which is usually a plaintiff, or a defendant, or a P&K, they write a letter to the carrier. And they either asked for reserves, or they changed the reserves, or amend the reserves.
And if you make a good impression, not because of what you accomplished in the depo from an information standpoint, how they feel about you, they will write in the letter that the plaintiff’s case is better. Maybe they don’t say, “Alder’s looks like a great lawyer and I’m scared shitless. Pay me more money.” No, they won’t say that. They’ll say, “Boy, this is a good case for the plaintiff. The plaintiff makes a great presentation. Our client’s not going to look good at trial.” Whatever. And that impression and that mindset is setting you up for the case. And so, when I give techniques about depo strategy, and I say, “Clean the detritus and the trash out of your office. Get good coffee. Get half and half, instead of the powder stuff.”
Chris, I swear to God, I sold the case for half a million dollars more because I had half and half, because at the first depot, the defense lawyer’s looking for the creamer for their delicious Starbucks coffee in my clean office that has a video always at every depot that has a whiteboard in the room, that there’s another depo going on in the conference room next door. And there’s a lot of activity, and I’m in a suit and a tie, and I’m looking good, and maybe [inaudible 00:26:38] blow up. That’s probably meaningless to the case. But it looks like I’m prepared. And they go, “Hey Mike, where’s the creamer for the coffee?” And they’re looking for the powder stuff. And I say, “It’s right there in the carafe. I swear to you, way more often than you might think, they’re like, “Wait, is this half and half?” And I’m like, “Yeah, baby, we’re big time.” People don’t understand that that mindset, and you get that in a depo, you don’t get it in special interrogatories.
Special interrogatories, we don’t stand out anymore. They are nine months of back and forth, every objection under the sun. You get a watered down answer that you could have gotten into depo directly. And you don’t spend all of that time. So, that’s why I’m so excited about depos, because depos, depos, depos are the way you move your cases forward. You got to stall negotiation, notice a damn depo. It makes the defense lawyer go get the file out of the corner of their office. I guess you’d say, now that’s whatever… In theory, or it calls up on the computer. How many times has this case just been languishing, and you do something like notice a depo, notice a witness depo, figure out something. They pull out the case, email, call, text Mike. “Hey, I noticed you noticed this depo. Hey, why isn’t this case settled? What can we do to get this case settled?” It’s activity. It’s movement.
And so, I’m like, we can notice depos 20 days after service. 20 days after service. With the relevant time period, we’re setting up the defendant. And if there’s a P&K depo 40 days after we served the complaint, it sets the tone.

Chris Dreyer:

I love every bit of that. And, I’d imagine too, so do you have the occasional where maybe you have the defense on the other side and you’re like, “Hey, Bob.” And you’ve taken him to court, and taken him to trial, and you have that scenario too, where they see you… I think the perception’s everything.

Michael Alder:

If you’re nice to the court reporter or the court reporting service and they know you, “Mr. Alder.” “Mike… Hey, good.” Or the videographer, right? You walk in and the videographer and the court reporter, “Oh, Mr. Alder, I didn’t know you were taking this depo.” It says something. Not because I’m some badass, but maybe because I brought them muffins, or I went down to get a cup of coffee, or a power bar and I asked, “Hey, do you want something? Hey, I’m ordering Starbucks. Anybody want a Starbucks?” They don’t take you up on it. But all of that goes to that mindset.
And I’m a big quick thinker guy, right? I’m a big dad joke, puns, right? And so, I’ll test the other side. I’ll start messing with him, right? I’ll start an expert depo with, “Doc, how you doing today?” And they’ll go, “I’m doing fine.” I’m like, “Well, let me see what I can do about that.” Right? And they’re like, “Wait. What? What?” Not because I’m trying to harass them, but those things are out of the ordinary. They’re going, “Damn, this guy’s funny. Oh, he’s going to… The jury’s going to like him.” And then, the letter goes, not the plaintiff lawyer, so good lawyer, it’s, “Eh, I need some more money, because we got some problems with this case.” Right? All of that goes into it. You can’t do that over the phone. You can’t do it with written discovery. Get your ass in an in-person depo. If you can’t do it in-person, get it in a remote depo.

Chris Dreyer:

Wow, there’s so much power there. And, thank you for sharing that. And, what’s next for you? And then, how can the attorneys listening, who may want to take you up on the Warrior Fund get in touch with you?

Michael Alder:

If this is shameless plug time.

Chris Dreyer:

Yes, sir.

Michael Alder:

Let me say that I have a YouTube channel called Alder Talk, A-L-D-E-R Talk, where a lot of the little two and three minute… I have maybe 50 different videos or more on different things that will come up. If you follow me on Instagram at AlderLaw, I would say, Instagram, AlderLaw or personally, if you want life advice, Mike.Alder. And my YouTube channel, which is Alder Talk. You go on there, you have access to reach me in any way possible.

Chris Dreyer:

Thanks so much to Mike Alder for sharing his wisdom today. Let’s hit the takeaways. Time for the PIM Points. Here we go. PIM Point number one, leopards, don’t change their spots. And according to Mike, neither do attorneys. Show insurance companies what kind of lawyer you are upfront. They see thousands of attorneys and will push around anyone they can. Come out swinging.

Michael Alder:

The very earliest they can notice depos. You notice them, of course, it’s going to be unilaterally set. And when they squawk and say, “We’re not available.” Then you say, “Well look, I’m happy to move it as soon as you give me a date that’s relatively close in time, I’ll move it to that date. Oh, by the way, my client’s available for depo right now. You want to do a medical exam? You don’t need to give me statutory notice. They can show up tomorrow. Find the doctor you want.” “Oh, Mike, aren’t you giving away the farm?” No, I am teaching the other side what kind of leopard I am.

Chris Dreyer:

Next up, PIM Point number two, gather up all your cases. See where you’re not being treated fairly by the pre-lit adjuster, if not, file.

Michael Alder:

“I will loan you the money interest free, because I know if you do what I say, that you are going to settle 70% of the cases that if they give you bullshit, you file, you go to a new litigation adjuster or a defense lawyer, especially the cases where you just need another 10 grand or 15 grand, that puts you over the edge. And, I’m not worried about you, Stephanie, because you’re going to have more money than you ever had before to give it back to me.”

Chris Dreyer:

And PIM Point number three, giving isn’t a dirty word. Believe in the good. As attorneys, you see some really heavy stuff. So skepticism is completely reasonable, especially when an offer sounds too good to be true. But when someone like Mike is reaching out a hand, you could do well to take it.

Michael Alder:

There are no strings attached. I am a firm believer in good karma, good works, good deeds is a good life, and it is good business.

Chris Dreyer:

Want even more trial wisdom? Check out Mike’s book, the Trial Lawyer’s Bible. It’s a compilation of articles and litigation strategies at Mike’s firm with step-by-step processes. You can find the link in the show notes. While you’re checking out those resources, please hit the follow button so you never miss an episode of Personal Injury Mastermind, with me, Chris Dryer, founder and CEO of Rankings.io. All right, everybody. Thanks for hanging out. See you next time. I’m out.