JGLLawEpisode ===

[00:00:00] David Bulitt: Welcome to JGL Law for you. JGL Law for You is a podcast by lawyers, but not for lawyers Only on JGL law for you. We will be discussing a wide array of topics to help you navigate the many legal processes, developments in the law, other current events, and how they may affect you, your family, or your business.

[00:00:20] Today we have an interesting discussion with two of my partners who principals at Joseph Greenwald and Lake Veronica Nni, who focuses her practice on complex litigation, has been doing so for more than 20 years now. Over the last 10 years, she has done complex class action cases. She's represented whistleblowers under the False Claims Act, and she focuses a lot of her practice on healthcare fraud.

[00:00:45] Joining her is Drew Fra Boys, also a principal and a partner of Mines GRE Lake. He focuses his practice on complex personal injury cases, wrongful death, civil rights. Commercial matters. Another complex class [00:01:00] action cases. And today, folks, we're talking about a case that has been in the news and very interested to hear the information about this case, the background of this case, and it's a major class action case versus the Psychiatric Institute of Washington.

[00:01:16] Now folks, before we get into the case and what it's about, for those who don't know, what is the Psychiatric Institute of Washington?

[00:01:24] Drew LaFramboise: Well, good morning, David, and it's great to be with you again on the JGL Podcast. Always happy to be here. So the Psychiatric Institute of Washington is the only private facility in the District of Columbia that's dedicated to psychiatric and behavioral health treatment.

[00:01:40] It's been around for decades and it's a large facility, 130 plus beds, treats thousands of patients per year. Importantly for the purpose of our case, which I know we'll get into in a little more detail as we go in 2014, it was acquired by Universal Health [00:02:00] Services or UHS, which is another defendant in our case.

[00:02:04] And UHS is the largest for-profit owner and operator of psychiatric facilities in the country. Uh, it's a global company, fortune 500 company at revenue in the multi-billions per year. Facilities all over the world. So since 2014, psychiatric Institute of Washington or PIW has been operated, owned and managed by UHS, but yes, to your question, it's, it's the, the only private psych facility in the District of Columbia.

[00:02:35] David Bulitt: And they serve both in patients as well as folks who are daily in and out type patients, or do people spend the evenings?

[00:02:42] Drew LaFramboise: That's correct. And that's an important distinction here. So yes, they have both outpatient programs and inpatient services. The focus of our case, which I know we'll talk about in more detail, is the inpatient side of PIW, which is the largest component of its business by I think, orders of magnitude in terms [00:03:00] of the patient population that it serves.

[00:03:02] David Bulitt: And again, just to give a broad picture in terms of employees, doctors assistance, what's the staff look like?

[00:03:08] Drew LaFramboise: So there are physicians there, certainly there are psychiatrists and psychologists, there are social workers. Then there are, there are nurses, and then there's a, a large component of the staff in the, in terms of the inpatient services are what are referred to as techs, and these are folks who handle the day-to-day operations of the facility in terms of interfacing with patients, uh, working with patients, delivering food, delivering medication, things of that nature.

[00:03:39] They're the ones who were kind of on the floor day in, day out. Okay.

[00:03:43] David Bulitt: So now I've got a picture of the facility. Who runs it, who operates it, who works there? What's the case about?

[00:03:48] Drew LaFramboise: Sure. I'll take this one too. I don't, I, I know I'm soaking up a lot of the oxygen here, but Veronica's gonna do a lot of talking, I think eventually.

[00:03:55] So we represent a woman who's a District of Columbia resident, uh, an [00:04:00] adult woman who in the complaint, she is named Jane Doe. Uh, that's obviously a pseudonym to protect her identity. So we'll call her Ms. Doe for the purpose of this conversation. In April of 2024, Ms. Doe had an argument with her estranged husband who she was engaged in divorce proceedings with, and the argument was over.

[00:04:20] Certain things don't really matter for the purpose of the case, but in any event, her husband called the police and he made a report about her that was false. The report was that she was suicidal and that she had underlying mental health conditions, neither of which were true. The police found her, detained her and took her to a District of Columbia run facility, an emergency facility called CPEP.

[00:04:43] She was held at CEP overnight and she was restrained, put into an ambulance and taken to PIW. This is a very common thing that happens in the District of Columbia, and in fact, PIW has a contract and has had a contract for years with the district for this very purpose to [00:05:00] take emergence, what they call emergency psychiatric admissions, inpatient admissions.

[00:05:04] So folks who are picked up by the police who are referred to Cpep by physicians or other facilities, they can then go to PIW per the multimillion dollar contract that PIW has with the district. And Ms. Doe is one of those folks.

[00:05:18] David Bulitt: Let me interrupt you for a second.

[00:05:19] Drew LaFramboise: So sure.

[00:05:20] David Bulitt: Husband calls the police, says, my wife, you need to get over here.

[00:05:23] My wife is having a, some sort of a, an incident. Something's going on. The police show up as a result of that telephone call. And then what happens? Do the police talk to her? The police talk to him, or they just wrap her up and throw in the back of a car?

[00:05:37] Drew LaFramboise: Yeah, closer to the ladder. So they, they restrain her, put her into the car, into the cruiser.

[00:05:42] Uh, don't really tell her where she's going. She shows up at CPEP. She's shuffled into CPEP. They do a five minute evaluation. They put her in a padded room. Uh, she's kept there overnight, no real information shared with her. And then she's taken to PIW. The next morning she [00:06:00] gets to PIW, very surface level evaluation.

[00:06:04] Done takes a couple of minutes. They document that she's suicidal, despite her saying over and over during the evaluation that she's not suicidal and they commit her. Voluntarily against her will.

[00:06:17] David Bulitt: I'm listening to this, you know, under a family lawyer's lens, right, saying if it was this easy, the hospitals would be filled with people because every time there was an argument in the midst of a divorce or separation situation that isn't particularly pretty, one of the people's getting hauled off and, and locked up.

[00:06:33] Drew LaFramboise: And in fact, there's a form in the District of Columbia called FD 12, and that form is used to involuntarily commit a person on an emergency basis. So the police use it. Often physicians and hospitals can use the same, uh, similar form, but there's a box in the FD 12 form that says, what's the basis for the emergency commitment?

[00:06:54] And the police officer wrote, husband reports, suicidal ideation [00:07:00] and mental health history. So it was entirely based on the false reports according to our allegations from the husband. Again, as Veronica said, no independent assessment or evaluation was done to corroborate anything,

[00:07:12] David Bulitt: neither at the police level, nor at either the two mental health stops that she makes between the pickup and then when she gets dropped off over with, uh, the U at PIW.

[00:07:24] Drew LaFramboise: That's correct. And in fact, at every step of the way, Ms. Doe is adamant that she's. Not suicidal, that she has no plan, that she has no ideation, and people just keep checking off the suicidal ideation box. And in fact, and this is actually important because under District of Columbia civil commitment law, which we cite in our complaint, a medical provider such as PIW, they should always err on the side of the least intrusive measure of treatment.

[00:07:53] So if a person says that they have no plan, that they have no suicidal ideation, that they don't meet the criteria for [00:08:00] involuntary commitment under the law, PIW cannot commit them. And in fact, I believe the civil commitment law shall not commit them. And so what PIW is doing here is they're a failing to take the patient's word for it, and B, failing to follow the law.

[00:08:17] As a result, she did not meet the criteria for suicidal ideation. That's what we've alleged in the complaint, but nonetheless, she's committed to PIW. The term of the commitment was supposed to be seven days. This is a person, by the way, and we should have given a little background on Ms. Doe. She's a working professional in the city.

[00:08:35] Two young kids, no mental health history. Has never been diagnosed with anything other than, you know, generalized anxiety, which we probably all have.

[00:08:45] David Bulitt: 99% of the population in this country are.

[00:08:48] Veronica Nannis: David, to your question though, during this whole litany that Drew is explaining to my horror, right, hopefully to many people's horror, I.

[00:08:56] The police did not do any sort of independent [00:09:00] assessment, which I assumed they would have. Um, I think your question assumes that they would have, they don't. CPAP doesn't really do one of any substance whatsoever. Everyone is tragically taking, uh, one accuser's word for it so far, and Drew's brought us all the way to the next morning where based on one.

[00:09:22] You do divorce work, David, as divorces go, they are messy, uh, a hundred percent of the time. And this, it's a little horrific, but that sort of drew completely lays out Ms doe's allegations here. That's exactly what happened. So you can see two or three, you know, fail safes that should have kicked in are not doing so, and now we brought her all the way to the next morning and involuntary committed at this place.

[00:09:43] No one knows where she is except for the ex-husband who accused her and got her committed

[00:09:48] Drew LaFramboise: and she is terrified. She has no idea what's going on. She's trying to figure out how to contact her employer, how to get ahold of her kids, but she's essentially just thrown into this system now, [00:10:00] and she is involuntarily committed.

[00:10:02] Her freedoms are taken away. Her liberty's taken away. She's now, you know, gonna be living at PIW for the next several days, and she has no idea what what that entails.

[00:10:11] Veronica Nannis: Another important point about Ms. Doe is so as a working professional, she has good private health insurance. And I will just tell you that a lot, not everybody, but a lot of patients who end up in any type of mental health situation generally are having Medicare or Medicaid or some sort of federal or state assistance.

[00:10:33] That's their insurance. But Ms. O is a working professional. You know, had one of those sort of. Premium private insurances that we all know. And that's gonna be important in a little bit. But, um, to give you a little flavor of what she was going through, um, it's important to note that she's got good insurance too.

[00:10:49] David Bulitt: Yeah, no. I'm gonna assume, I'm gonna assume that at some point the folks at PIW learn that she has health insurance. And therefore we're not dealing with Medicare or Medicaid. We're dealing with a private insurer [00:11:00] that in turn tells us we're gonna be able to get paid.

[00:11:03] Veronica Nannis: Correct. And we're gonna be able to get paid more for private insurance than I, the entity would get paid for any state or federal assistance.

[00:11:11] So I know within the first five minutes, and that really is the intake that we allege was really to, to get more about. What her insurance is and what they're getting paid than they did to truly independently evaluate her mental health. Situation.

[00:11:28] David Bulitt: Now what, let me just ask a question, and I don't know if this is relevant or not, but as they're looking to bring her, evaluate her and admit her, is there a significant amount of space in the facility or is it pretty much filled up?

[00:11:41] Drew LaFramboise: The short answer is no. There's not a significant amount of space and, and what we've alleged in the complaint is that this is a facility that is overpopulated and understaffed. It has been for years. That's been the condition that has always been the case, uh, especially since UHS took over in 2014, and [00:12:00] that, that's intentional on the part of PIW and UHS, that's what we've alleged in.

[00:12:06] In other words, it's heads and beds. That's the corporate strategy for UHS, it's to increase occupancy and cut staff and resources. And in doing so to increase shareholder value. And that's, you know, UHS has been very public about, about this. This is not us providing color commentary. This is based on the public statements.

[00:12:28] By UH S's executives in earnings calls and in other public forum. So that is the strategy and that's very, that's very much consistent with what our client confronted when she was admitted.

[00:12:41] David Bulitt: So I'm gonna take a while. Guess that this is not the first time that these folks have either been sued or investigated for incidents similar to Jane Doe?

[00:12:52] Veronica Nannis: You are. So Ray David, I will tell you that probably. I don't know. Somewhere around 20 pages of our [00:13:00] 75 page complaint talks about the previous investigations that PIW and UHS have been under at state level, the federal level, the DC City level. And not surprisingly, tying it to what I do normally for my day job is represent whistleblowers.

[00:13:20] UHS and PIW were investigated by the federal government and in 2020 they settled a False Claims Act lawsuit for $122 million back to the federal government. PIW was included in that, and that was for a period of time from 2006 to 2018. So that period of time the government was alleging at that time and the defendants paid $122 million to make this case go away.

[00:13:50] The allegations were though that patients were being sort of systematically mistreated that patients were being admitted. Who were ineligible to [00:14:00] be admitted. So very much like our allegations with Ms. Doe, that she did not meet the suicidal sort of ideation criteria. The government found that PIW and UHS had failed to provide adequate staffing, failed to provide adequate training, failed to supervise their staff, failed to supervise the patients, build it for services that were not rendered.

[00:14:22] It goes on and on and on. Improper use of physical restraints. It goes on and on in terms of the allegations that the federal government brought, and again, that period covered 2006 to 2018. We sort of are picking up now with Ms. Doe in the last three years. So we filed this case a couple months ago at the very beginning of 2025, and we can go back three years from that.

[00:14:48] So although the government has investigated and settled this, that. Ended in 2018 with PIW and UHS entering into what's called a corporate integrity [00:15:00] agreement, which means that the government. Monitors, UHS and PIW going forward, they're supposed to monitor them going forward for a period of five years.

[00:15:09] Our allegations are that obviously there's some overlap there, and while they were under this corporate integrity agreement, I. We are alleging that if they had changed at all, they slipped back into their old ways or maybe they never changed at all. Right? Their allegations were that everything that the government sort of found and alleged back on that False Claims Act case, Ms.

[00:15:31] Doe is finding again, um, much more recently and we are hearing from even more witnesses and patients that allege that this is continuing through today.

[00:15:42] David Bulitt: So. Working on whistleblower cases, and this, this is somewhat different, so executive summary, what's a whistleblower case and how does this differ from that?

[00:15:52] Veronica Nannis: Yeah, so a whistleblower case is usually somebody internal. What we think of when we hear that in the news whistleblower is usually somewhat [00:16:00] internal, so it can be. A nurse, a doctor, some, a staff member in the coding office, a compliance officer, anyone. It could be a patient, it could even be a competitor, but for the most part, it's somebody internal, an employee, or a patient who's working at someplace and who realizes that?

[00:16:17] They think the company is engaged in some sort of fraud, whether it's criminal or not, some sort of improper behavior, and that that has something to do with a federal or state funds. And so the healthcare system, everything does right? Everyone who just about every sort of provider, especially at a hospital like this, is going to be a Medicare provider and a Medicaid provider.

[00:16:42] And so when that happens. When you have a defendant like this who is alleged to have been billing for services they didn't give, that means that Medicare and Medicaid are using our tax dollars to reimburse these defendants for services. They never gave the patient, so [00:17:00] who makes out their rate? The patients don't make out, they don't get the services.

[00:17:03] The taxpayers don't make out our taxpayers just going to line the pockets of these defendants. Under that scenario, the defendant's the only one who makes out, but that. Case was brought by a, usually a, A citizen, A whistleblower is really brought on behalf of the governments 'cause it's the government that overpaid, it's Medicare, it's Medicaid, it's tricare.

[00:17:23] They're the ones who overpaid. So that's their claim. So when I'm talking about. The government having sued them and settled for this period, 2006 to 2018. That was because that was the federal government and the state's government claim very different in a class action now where we have an individual who, by the way, is unbelievably brave to come forward.

[00:17:45] And say that this happened to her and she's not bringing this class action on behalf of the government. She's bringing it on behalf of herself and other patients who were similarly situated within the same time period, and who may not even know that, [00:18:00] that there is a class action case. They may not even know, uh, that there's a potential for them to join a class.

[00:18:05] It doesn't have to happen as long as you have at least one person to bring forward this case. Then we hope that from the plaintiff's side, we hope that it gets certified by the judge and that it turns into a class where, where it would be able to encompass all the similarly situated patients who were at PIW within the timeframe.

[00:18:24] David Bulitt: Okay. So, so Drew, you know, what's, what's, what's the end game here? What's, what's the goal of this, of this piece of litigation?

[00:18:32] Drew LaFramboise: So largely, I mean, this is a claim for damages. So our client,

[00:18:37] David Bulitt: what's that mean? What's that mean again? Remember people, what is debt? What See damages? What's that mean?

[00:18:41] Drew LaFramboise: So these would be civil money damages.

[00:18:44] I mean, there, there's really two types of relief that we're seeking here, right? There's monetary damages and then there's, there's injunctive. Relief. So you know, that would be to actually have the court order PIW and UHS to either do something or stop doing something. That's largely, largely what that means.[00:19:00]

[00:19:00] But the crux of the case is a money damages case. And so our contention and our allegation is that Ms. Doe has been damaged civilly in that she's suffered civil harm, uh, and therefore has a claim to monetary damages. To compensate her for that civil harm and that all other similarly situated class members also have claims for civil damages.

[00:19:23] So, you know, under, under the civil justice system, the, usually the only remedy we have is money. Nobody's going to jail for this. There's no, there's no imprisonment. It's really monetary damages, and that's how we hold wrongdoers accountable and that's how we. Compensate victims of civil harm. So that is certainly the focus from a damages perspective and a remedy perspective.

[00:19:47] That's the focus here. It's to bring that level of justice to our client and all other class members that hopefully the court eventually certifies

[00:19:56] David Bulitt: and also to preclude them from doing this to other people. Right. Isn't, [00:20:00] and that's, that's part of what you're trying to accomplish. I assume we don't want any more Jane Doe getting called, getting.

[00:20:06] Locked up for no reason 'cause their husband said they're crazy.

[00:20:09] Drew LaFramboise: Right? That's the sort of the next level. So yes, the sort of micro focus here is to try to get civil justice for our client and class members, but then what we certainly hope in a case like this. Is that we are able to change corporate behavior that we're able to regulate if the government's, you know, not gonna do it, or maybe they're limited in what they can do to regulate the corporate behavior of UHS and PIW and make sure that moving forward they're prioritizing the wellbeing of their patients over their bottom line.

[00:20:41] That's ultimately what we wanna try to achieve in this case from a macro standpoint.

[00:20:46] David Bulitt: Okay, so, so if there are folks out there who are either patients at PPIW or new people that were patients at PIW over the last three, four years, whatever it may be, you know what, if anything ought they do now [00:21:00] that they're hearing all of this.

[00:21:01] Drew LaFramboise: We would certainly recommend that if they wanna discuss their legal rights to contact us. That's sort of the first thing. If they're interested in discussing their legal rights and potentially pursuing a legal action or being part of this class, we'd also recommend that they try to get their medical records from PIW and their medical bills.

[00:21:19] They can get their medical bills either directly from PIW or from their insurance company, regardless of whether that's private or public payer. And then, yeah, they can reach out to us and we are happy to discuss their rights and their story and hear their story and learn more about what happened to them.

[00:21:35] David Bulitt: And are you just looking at PIW here in the district, or are you also interested in speaking with folks who have been patients at other UHS facilities, wherever they may be in the country.

[00:21:47] Veronica Nannis: Yeah. Yeah. I'll tell you that without asking for it. We've been contacted by, as you can imagine, David, some folks from other UHS facilities.

[00:21:56] Like Drew said in the beginning, [00:22:00] UHS is the largest, I think I. Sort of parent and provider of mental health facilities, definitely in the United States. And then they've also gone global. So they have several, several, several, several psychiatric entities, very much like PIW and and and several states. And if somebody hears, knows of someone who was in one of those institutions who have faced some of the very similar facts to the what.

[00:22:24] Ms. Joe is talking about what we've been talking about here today. We do recommend that they contact us and we are happy to speak with those folks as well for a few things, right? First of all, we want to see if there's a way that we can help other folks who are, you know, who might inquire, whether it's through this case or through a different potential case or a different avenue.

[00:22:43] We will check that out for them. We also wanna see, obviously, if there were other people in there who maybe for for one reason or another, missed out on themselves, being able to go after and pursue a claim. Maybe it's been too long, for instance, or something like that. [00:23:00] But they may be willing to talk to us, nevertheless, about their experience and they may.

[00:23:04] Be willing to be a witness or to support this case. And we've had, frankly, calls and inquiries over the last three to four weeks from everyone that, you know, sort of runs the gamut in there. And it's been encouraging. I think what the other thing I was gonna say, David, is that this is, I think, really filling a gap that's out there, right?

[00:23:23] We had all of the different federal government and state, and even the DC Council, you know, investigating, having these. Findings that they make and these suggestions for going forward. They have this big case that they settle for $122 million, but those were all about sort of what was happening. More of the macro level that the governments are looking at.

[00:23:43] None of those investigations or settlements led to $1 in the pocket of a patient, right? So. Our case is trying to sort of fill that gap where there's been all this stuff about this before, but nobody's really brought this action from the [00:24:00] patient's perspective and to try to put some dollars back in the patient so that, for instance, if they have PTSD.

[00:24:07] As a cause of going through this, we think they should be able to get some civil, civil damages from that and be able to pay for a therapist to, or whatever they need to address the traumatic situation that they were put through at PIW. And so, you know, we're really. Sort of patient focused on this.

[00:24:24] Obviously those are our clients and telling their story and getting them as much justice as possible, both at PIW and elsewhere. If it turns out that something similar is happening in other UHS facilities,

[00:24:35] Drew LaFramboise: we believe the damages are are significant here. And I think it's important to realize when we talk about involuntary commitment, what we're talking about and we're talking about a complete restriction of freedom and outside of jail, right?

[00:24:48] And I mean, this is really the only time this happens civilly. In this country is through involuntary hospitalization, and so we believe that certainly Ms. Doe has alleged, and that there's many, many other people out there [00:25:00] like her, that we've had their freedom taken away under false pretenses through falsification of records, and that when they've been put into this system at PIW, they have not received therapy.

[00:25:11] They've not received treatment, they've not received any benefits that PIW and UHS are required to provide under law. Federal and District of Columbia law that they've been subjected to unsanitary and unsafe conditions, that they haven't been allowed to go outside and breathe fresh air for days and weeks at a time.

[00:25:28] Um, I mean, we're talking about what we believe to be very serious claims and that warrant. Substantial damages to our client and to into the class of folks. I know that some people maybe think of class actions and they think of, oh, well you, you file your claim and then you get a check for $13 a couple years later.

[00:25:45] Right? We're not talking about that type of class action here. We're talking about a very serious and not, not to Cade on those types of class actions because they certainly do have a role in our, in our justice system. But in this particular case, we believe the damages are very substantial.

[00:25:59] Veronica Nannis: Yeah, we're talking [00:26:00] about imprisonment and not allowing Ms.

[00:26:02] Doe to talk to her attorney, right, to get her out, which you would even get if she was in, being held by the police. So really substantial, really significant constitutional violations. I.

[00:26:14] David Bulitt: I, you know, you mentioned Class Action and Andre, and again, a lot of folks that listen here are not lawyers. And you're right, they read something in the newspaper, think they join a class against Nissan or whoever.

[00:26:25] They get their $9 check after $7, uh, seven years, whatever it may be. But, but what, just if you can, is. As dumb down as possible. That's a bad term. But in terms of layman's terms, what is a class action? What is it exactly?

[00:26:41] Drew LaFramboise: A class action is, is a creation of civil procedure. So it's a type of case that is actually prescribed in the rules of procedure in our court system.

[00:26:51] I. That allows a single person or few people to file a case on behalf of themselves and many other people who are similarly [00:27:00] situated and have the same claims and causes of action against the same people or entities. So it's a way of basically taking hundreds or thousands of individual claims and putting them into a single case.

[00:27:15] It's designed as a way of building efficiencies into the system so that you don't have hundreds and thousands of cases out there, kind of in, in different courts with different rulings, at different damages, awards against, against a single entity. When we pursue these, there's certain requirements that you have to hit in order to have a class action certified by a court.

[00:27:35] In other words, the court says, yes, this is a class action and it can proceed. And so you know, you have to establish that the represented the class representative of the plaintiff or plaintiffs are adequate. That they have the types of claims that everyone else has, more or less, that the claims are typical of one another, that there's commonality in the facts between the class representative and the class itself, and that there's a, [00:28:00] a sufficient number of people that are being alleged to be part of this class.

[00:28:04] If you check those boxes, then you know, hopefully the court would certify it and you can proceed as a class action.

[00:28:10] David Bulitt: I mean, you know, this is gonna show my age a little bit, but I, I, I keep thinking of, um, some movies, right? Uh, one Flew of the Cuckoo's Nest, I think of the Snake Pit, which goes back even further than that.

[00:28:19] I dunno if you guys saw either of those, but, but people who have mental illness, uh, you know, are of the most at risk members of our society. And what you're laying out for me, and I'm sitting here, the hair on my back is standing up when I hear about how she ended up in there to begin with, what you're laying out here for these folks is.

[00:28:39] Is this institution taking extreme advantage of people who are in some cases of the most risk or class of the most risk of, of our citizens here? And, and, um, you know, from my perspective, I. Uh, you know, you couldn't be doing better work than what you're doing than what you're doing now. We'll know where, [00:29:00] in terms of this case, where does it stand?

[00:29:02] Um, you know, what, what are, what, what are the mile markers, so to speak, that you look for in terms of, you know, class actions and this case particularly?

[00:29:10] Veronica Nannis: Yeah. We filed a, in the very beginning of February and. As these things go, and this is boring part of law, but we serve the defendant. So basically telling the defendant, Hey, you've been sued and here's a copy of the allegations.

[00:29:22] Here's a copy of the complaint right out of the box defendants, and we know that they're going to do it. In this case, they get to file something in court called a motion to dismiss, and what that does is it's their attempt right out of the box to get the case. Kicked out completely. Um, and so they wanna say, Hey, we see what you've alleged here, but this is, you're not, you know, judge under the law.

[00:29:45] Even if what they're saying is true, there's no case here. Throw the whole thing out and let's send them pack and let's not waste your time, my time, everybody else's time. So we know that the defendants are gonna do that here. Every defendant does it, and we're waiting on that. So that's really the first [00:30:00] hurdle that we have to clear.

[00:30:01] We are very confident that we will clear it, but it's something that we have to clear. It's something every plaintiff has to clear kind of out of the box. Usually before we get to serious discovery, which is when we get to get their documents, we get to put their people under. Oath and ask them questions in a deposition, we get to show them their own emails and make them explain, show them their videos, show them their text messages and anything that we have and make them explain what they're doing and they def get to do the same thing with our clients.

[00:30:32] And so that before we get to that exchange of information, that discovery piece, we do have to get past this first hurdle.

[00:30:38] David Bulitt: Gotcha. Okay. And if, and if folks want to speak with either of you, um, or anyone on your team about what they may know or what they may have heard, what's the best way to get, get hold of each of the two of you?

[00:30:49] Drew LaFramboise: They can reach out to us. Probably the best way is to reach our main line, which is 3 0 1 2 2 0 2 2 oh oh. 3 1 2 2 0 2 2 oh. [00:31:00] And if they call that number, they can get transferred to me or, or Veronica or any member of our team. You know, they can say that they wanna talk with a lawyer about the PIW case and our receptionist will know where to where to send them.

[00:31:12] They can also go to our website, um, which is jgl law.com, and they can submit a confidential online inquiry, uh, with the same type of information, and, and folks may feel more comfortable doing that in a case like this as well.

[00:31:25] David Bulitt: Okay. Thank you. I wanna thank you, Veronica. Thank you Drew. Folks out there.

[00:31:29] There are times in life when you need to stand up. Stand up for yourself, stand up for others who may come After you, contact Veronica, contact Drew if you know anything about. This hospital, this entity, this organization. I am David Bull. This is JGL Law for you.