Ibiere Seck – Turning Bad Facts Into Strengths

Voice Over (: 00:00:02

Ready to take your verdicts and jury selection to the next level. Jury consultant, Harry Plotkin and trial lawyer Dan Kramer, are your ticket to tipping the scales before trial begins. You're not just picking a jury, you're picking justice produced and powered by law pods.

Dan Kramer (: 00:00:21

Alright, welcome to another episode of Picking Justice. Very excited for this one. But Harry Plotkin. I got to ask Hawaiian shirt in the wintertime. Huh? Did you ever rock that back in the northeast growing up?

Harry Plotkin (: 00:00:35

I remember the first time I went to the Macy's Day parade when a freshman year of college and my aunts and uncles picked me up and I had flip flops on. I'm just a California, California kid, so I don't really layer too much, but

Dan Kramer (: 00:00:49

It's looking good, dude. Looking good. Anyway, I'm really excited for today's episode. This attorney is someone I personally looked up since I was brand new, even though I think she graduated one year before me, but I still look up to her. If I can ever be as smooth in a courtroom as she is, I will have been a success

Ibiere Seck (: 00:01:07

In

Dan Kramer (: 00:01:07

My career. But we got the great EBA SEC here with us today. She is truly one of the greats out there and she still has a long runway ahead of her, but she's basically swept every award out there, CAOC, Streetfighter of the year. She won top 40 under 40 Callos Rising Star National Bar Nation's Best Advocate Award, numerous seven and eight figure verdicts. One of my favorites out there. Eary S How you doing?

Ibiere Seck (: 00:01:35

I'm doing well. How are you? It's good to see you.

Dan Kramer (: 00:01:39

Doing great. And also a fantastic mother of two, is that right?

Ibiere Seck (: 00:01:42

That is true. I do have,

Dan Kramer (: 00:01:44

And when this airs, you will be a past president, immediate past president of Consumer Attorneys Association of Los Angeles, which she really has been a groundbreaking president. It's been amazing to watch her as a fellow board member, do what she's done by leading the biggest plaintiff's bar organization. So how do you feel about that? How do you feel about your tenure?

Ibiere Seck (: 00:02:04

I feel good about it. I feel like it was a successful year. We did a lot of really good work. I had a really good time, and most importantly, I just had a great time interacting with our members. It gave me the opportunity to just get out there and shake hands, hug people, and interact. A lot of speaking, a lot of traveling, but it was well worth it. I'm better because of it.

Dan Kramer (: 00:02:30

Yeah, no, it was great seeing you the way you interact, specifically with the judges out there and being on the bench bar committee with you, really helping our members with how to deal with the judges and a lot of obstacles we have to overcome.

Ibiere Seck (: 00:02:41

Yeah,

Dan Kramer (: 00:02:41

Like short jury selections, right? Harry Plotkin.

Harry Plotkin (: 00:02:45

Yeah, that's a tough one. It's happening more often than ever, and especially in LA I feel like there's a lot of, I mean, I don't blame the judges. There's a ton of pressure on them to just resolve as many cases as they can and get it done super quickly. But is shave enough two minutes off a mini opening, really going to make the trial really any shorter? Not really. That's a whole nother story. But I wanted to ask. The president of the United States always gets all the blame or credit if inflation is going or gas prices, and they're like, why isn't the president doing this? Do you take a lot of the credit for all the verdicts this year under your watch? I feel like you deserve a lot of it.

Ibiere Seck (: 00:03:17

Are all those kind of yours too? I wish. We'll see when the checks come in. Exactly. That's when they'll know If I truly get credit until then, no. I let my colleagues take credit for their very hard work. But I will tell you, I'm astonished at some of the verdicts that I've seen in the last two years. I served on the CALA trial lawyer, the year committee many times over the last five years. But last year I chaired it. And when I tell you the verdicts that we were seeing, I mean dozens and dozens and dozens of eight figure verdicts, we were seeing nine figure verdicts five years ago, 10 years ago. That was unheard of. And so people have really mastered the art of trying cases and I am so impressed. I'm not talking about seasoned lawyers, I'm talking about very new lawyers, people who are just entering the profession, who are just having the courage to try cases. I mean, I'm in awe of it and I love watching people in trial. I don't care if you've been practicing 50 years or five months, if you're picking a jury, I want to see it. So I'm just really impressed, very proud of my colleagues. We're doing good work, we're serving the community and we're holding corporations and institutions and entities accountable. So it's just good all the way around. Love

Dan Kramer (: 00:04:45

It. I think Harry Plotkin was responsible for like 60% of the, I think you picked 60% of those juries, but I do want to ask you more directly because you see it. I mean, you're obviously friends with all these trial lawyers. You hit these verdicts as well. Do you think the changes or what you're seeing these bigger verdicts recently, do you think it's that the education for trial lawyers, such as things like this podcast, what Cala does, COC, many other podcasts out there that plaintiff lawyers are just being educated better? You think jurors are different? What's your theory?

Ibiere Seck (: 00:05:13

I think it's all of the above. I think the culture has changed. People are viewing money differently. You used to try a case and say, we asked for a million dollars. Justice is a million dollars. Wow, a million dollars. Gosh. And they think, we don't want to make that person rich, a millionaire like a millionaire. Now people are talking about trillionaires. I mean,

(: 00:05:38

We have multi-billionaires. It's not, people see money differently. They recognize the value or the lack of value of the American dollar, and they recognize that you also, in order to send a message, you need to hit people in the pocketbook. I mean, that's just the reality, the kind of work that we're doing. We're not making people uninjured. We aren't reversing time and preventing a tragedy from happening. What we're doing is we're sending a message. We're righting wrongs, we're making people whole. And we have, I think, gotten better at explaining to the jury why it is important to appraise the value of people's harms and losses in a meaningful way. Not just being flippant about it. You can't bring such and such back, or it doesn't change things. No, actually your verdict speaks volumes and it will send a message to people and remind them that when you harm someone, you have to be accountable for it. And we have to do the hard work of putting a value on it. I think our attorneys have gotten better at saying it right? They've gotten better at giving examples of how you do it. And when we see those verdicts, people tend to, they're more courageous about trying cases and jurors they're reading about these verdicts and they say, oh, okay, that's not out of the ordinary for $50 million verdict

Harry Plotkin (: 00:07:12

A hundred percent. I love what you said about even in cases without punitive verdicts in the case, I think trial lawyers are getting better at explaining to jurors why, even though it's not going to help necessarily fix this person, it really does make a difference to preventing future ones. I mean, every time I get a big verdict, even though it's not going to help necessarily the plaintiff completely, I feel like it's going to help people down the road. And one of the things I like to do in voir dire, and we can talk about this in a minute, but is talk to jurors about this idea that if you don't put the proper value on something, does that affect how safe and careful people are? If you're in a store, sometimes I'll use this analogy, and there's this vase and it says 30 cents on it, you think people are going to be careful around that vase, or if it's a super important to you, shouldn't you put a high price value on it and price tag on it? So it's kind of the same thing where people are kind of getting like, if we put the proper value on a person's quality of life, then maybe hopefully people will be a little more companies, people, drivers will be more careful about actually protecting, because you're not going to knock something over. You're going to be careful if something's worth a lot,

Dan Kramer (: 00:08:13

How are you directly having the attorneys that work with you? Ask that question. How do you present that concept in a simple way to the jury?

Harry Plotkin (: 00:08:21

I don't necessarily have the attorneys, I'm working with you that in every case, but I have in some cases, especially with the jury's not getting it, and they're focused on, well, how's this going to help the person? Or whatever. But just to say, you're going to have to appraise the value of something that we think is very valuable. And one of the things you can talk about is you can say, what are your thoughts on whether, for example, it's important, putting a proper value on something like a price tag actually helps for others to recognize how careful they need to be with whatever. And you can use that example of a price tag in a store or something in a store. There's a price tag and something says thousand dollars on it. Are you going to make sure your kids, Hey, don't screw around with that.

(: 00:08:58

Stay away from it. If it says 10 cents, you're going to be like, whatever kids, do whatever you want, you can play football in the store. So just giving them that analogy for them to give 'em something to think about. But given jurors, I mean, that's one thing that's so important, I think with damages, given them reasons, motivations to give big damages and why other than, because if all they're left with is like, well, how's it going to help this person? And I don't understand how $10 million is going to make a difference to this person. That's not enough. But if you give them, and there's a million different ways to give 'em different reasons, but that's just one of them.

Dan Kramer (: 00:09:27

Especially if you don't have a sweet grandmother on the other side who admitted liability in a rear end car crash, you're not sending a message to anyone there. I mean, that's a lot tougher. And then you really have to spend a lot of time. That's what I want to ask you er, about talking about appraising the value of loss of quality of life in jury selection, I think. So how do you do that? What's your kind of way to introduce this concept in your jury selection, and when do you sequence it?

Ibiere Seck (: 00:09:54

Well, in jury selection, I think it's important to recognize that the jury is comprised of individuals. I mean, I'm stating the obvious, but I've seen people within our profession going into the jury selection process, treating it as if it's a body, it's an entity, it's in a single entity. I need this group to do X, Y, z. I get that my approaches is slightly different. I see it as very unique individuals who have very unique experiences that each have very deep held beliefs, and I need to do what I can to make them feel like they are an integral part of this process. They are simply put on this earth to complete this one task, which is right a wrong, and that they have to feel so invested in it that they're willing to sacrifice their time, take time away from their families and their jobs, and feel good about being there so that they really do feel like they're a part of a larger process, a larger mission.

(: 00:11:19

So when I talk about these concepts, I'm looking at the individual and I'm wondering what is it about their life experience that is similar to the experience of the person I represent? So when we're talking about the human harms and losses, we are asking the jury to put a value of praise, the value of that individual's harms and losses. But if person, if the jury doesn't relate in some way to that, if they don't know what it feels like or they can't imagine someone taking something of value away from them, then they really have no purpose. They can't serve their purpose on the jury. So when we talk about harms and losses, I want people to start thinking about the things in their lives that are priceless, that are invaluable. Even if I don't ask them directly. And a lot of times I will ask them directly, what's important to you?

(: 00:12:16

What does good health mean to you? What do you wake up every morning hoping you can do? Who do you look forward to seeing? What do you want to do when you retire? What would be one thing that you would want to be remembered for? Those sorts of things. I want them to really start getting into that, feeling it, feeling it, feeling it. So then when we start talking about damages in the case or the losses, in our case, the jury can't help but think, wow, what if that were me? What if you took away my ability to dance? What if you took a bell of my ability to sing? What if you took my ability to hold my child? What if you took my ability to travel? All those things. They start to really say, oh, wow, that's major. That's worth a lot.

Dan Kramer (: 00:13:02

That's fantastic, by the way. But with those types of questions, what do you want to be known for? What do you like to do? Are you looking for answers that may indicate the person is not a good juror? And then what would an example of those? You're not

Ibiere Seck (: 00:13:15

At all. I'm not thinking about whether or not they're a good juror at that point. I'm wanting them to feel something. I'm beginning the process of building empathy and understanding and connection,

Harry Plotkin (: 00:13:28

Recognizing the things that are incredibly valuable to them too. Not just, Hey, we're here to hear about somebody else complaining about something, but we all have these things, right? Thinking about the valuable things in their life.

Ibiere Seck (: 00:13:41

But what it will tell me, it will tell me. If someone says, oh, nothing. Oh, no, nothing. I don't look forward to anything. Oh, no, nothing is important to me. I don't value any to me, that's easy. Well, yeah, probably not the right person for this jury. I want you to feel like what it feels like to lose something. I want you to empathize with my client, and that's it. So in that case, yes.

Dan Kramer (: 00:14:02

And when are you doing that? When are you putting that into your sequence of your jury selection? I mean, when are you introducing this idea?

Ibiere Seck (: 00:14:09

Well, sometimes things will come up during the jury selection where you might be asking a question, have you ever been a caregiver? Have you ever been a caregiver? Have you ever had to care for someone who's suffered an injury, elderly parent? What was that like? And then you can get into that process of talking about what it means to actually see someone suffering. And then you ask the questions like, well, what were some of the things that that person could not do that you found yourself having to step in? What was it like to see that person not being able to do those things? And how important is it to you personally to have good health? What do you base it on? Well, I base it on because I had to take care of my grandmother who had amnesia and the fact that she couldn't recognize me that was devastating or that she could no longer leave the house.

(: 00:14:54

And it's like, for the rest of you, let's talk about this. What are some of the things that are important for you to be able to do each day? What are the things that we sometimes take for granted? Just having an honest conversation. Most of the time it's organic. It just comes up and I'm like, oh, good time to talk about this. And then where isn't really flowing? Maybe I'm trying the case with someone else and they've probably primed the jurors. I can kind of come in and just ask the question directly, and I just say, frankly, I want to ask you all about just, we've been talking about the value of good health. What does it mean to you? And just have a very easy, simple conversation. And you'd be surprised. People love talking about themselves, they love talking about the things they love to do. And then you just go, and then everyone's raising their hands like, oh me, next, let me tell you about gardening. Oh wait, tell me about fishing. Let me tell you about bird watching and all these things. That's how it works.

Harry Plotkin (: 00:15:42

And they love you for talking about, they come in, I think in like, oh, this is, gosh, I hate being here, and now we got to talk to some lawyer who's probably going to try to trick me or just use me in some way or manipulate me. And then you're talking about you're actually interested in talking about what matters to them. I mean, most jurors really, really

Ibiere Seck (: 00:15:58

Love

Harry Plotkin (: 00:15:59

It when you do that and they're like, oh, this person actually cares about

Dan Kramer (: 00:16:02

Most human beings. I mean, Dale Carnegie had a whole industry based on just learning people's names

Ibiere Seck (: 00:16:07

And

Dan Kramer (: 00:16:07

People love talking about themselves, especially this, it is something that no one really thinks about that often, what gets me going every day. It's often your kids and all that, but it's a great place for the trial lawyer to be in and really disarm, take that barrier down. I love it.

Harry Plotkin (: 00:16:23

I just want to share with you guys the one I know, Dan, we've done this a couple of times in our cases before in jury selection, but the one little twist I like to put on this one because I know a lot of buddies like Bob Simon who's going to be joining us not too long from now. I know he loves to talk about what are your passions in life and things like that. Here's the twist that I've put on it that I really find helpful. I love to ask people, do any of you have a passion in your life, whether it's a hobby or activity or whatever it is that if you explained it to a stranger might seem silly or unimportant to them, but it means a lot to you. What is that? And then they talk about it and they talk about, yeah, and now you get they light up and they talk about those things.

(: 00:16:59

But the key, that last part of that question is that then you turn it around, you hear from a bunch of 'em, and then you say, now in this trial, you're going to hear about some of this plaintiff's passions in life. Can everyone here decide for yourselves how much those things meant to him or to her? Even if you're the kind of person who, let's say you're plaintiff loves ballroom dancing or marathons or something like that. And probably a lot of your jurors will be like, if you didn't kind of pose it this way, they'd be like, who cares? That's stupid. Whatever. He'll be fine.

Dan Kramer (: 00:17:26

We had dragon boating in that trial. We did dragon, dragon boating. I didn't even know what that was. It's canoe racing for those who don't

Harry Plotkin (: 00:17:32

Vote. And that was her thing. Yeah, that was the plaintiff's passion. So I love to say, can you decide how much these things meant to her? Even if you're the kind of person who, frankly, and this is always funny, you go, who would probably like, Hey Dan, I would pay thousands of dollars to never run a marathon in my life, or I'd pay you a hundred bucks to not have to dance or dragon boat or whatever. And they get it because you've talked about, you've already put that in their mind that strangers probably would hear your passion and think, that seems silly. That doesn't seem that important. But they think about those things is that's my version of whatever it is that I do. And I've heard, and you hear these charming stories from 'em, but I think that little twist is super helpful If you have a plaintiff whose passions are frankly something that a lot of jurors are going to at first might think like, oh, that sounds kind of dumb, or

Ibiere Seck (: 00:18:15

I think it's true across the board. I mean, I think

Harry Plotkin (: 00:18:18

It

Ibiere Seck (: 00:18:18

Doesn't matter even if it's some off the wall or out of the ordinary type of hobby, because what we're asking the jury to do is the value of the harm and loss to the plaintiff. It's not what that individual juror thinks it's worth to that individual juror, right? That's the key. It's not what you think it's worth for you. What is it worth? What is the value for the plaintiff? And so to your point, if we're talking about someone who restores antique cars or ballroom dances or we can think of any number of things to the individual juror, not such a big deal. But if I'm doing my job right in the trial, I am demonstrating that this is such an important part of that person's life, their identity, their existence. It is directly connected to their happiness and their purpose. Then that has incredible value to the plaintiff. And your job is to appraise it, not what it's worth to you.

Dan Kramer (: 00:19:31

That also does two things, because inevitably, I mean in every single verdict, decent, good verdict, whatever I've had, the appeal always has some about golden rule in there.

Ibiere Seck (: 00:19:41

And

Dan Kramer (: 00:19:41

Then this helps you protect because I guarantee you're going to say the same thing you've preempted in jury selection, opening, and then you're closing. You're going to say, it's not about you, it's about the plaintiff that protects the record from look, your Honor, mean, or the appellate justices, whoever I was literally telling them they can't consider it for themselves.

Ibiere Seck (: 00:20:00

It

Dan Kramer (: 00:20:00

All is about the plaintiff. So it's another good reason to do that, I think.

Harry Plotkin (: 00:20:04

And I think too that jurors will come up to 'em and talk about their, Hey, now, I had one recently where this guy's passion was like RV camping, and they're like, you're going to get the most amazing dope rv, million dollar RV and everything. And so they're super invested in whatever that is the plaintiff loves and what their passions are. But I wanted to ask you this. I used to hear this more often. Jurors would just in the past 10 years ago, they would bring this up on their own. When you talk about things that someone can't do, I don't hear this as much, but I'm wondering if you ever asked this, do you ever turn around and ask him, does anyone feel like just because you lose the ability to do one thing because of an injury, you should just kind of pivot and find something else? I used to hear jurors on their own say that they used to say, well, if somebody can't play golf anymore, suck it up and find something else that you love. I mean, my uncle was paralyzed in a crash and he loves something else, and now he fishes all the time and he's just as happy. And I don't know if I would want to necessarily plant that seed in their minds or not, but do you ever deal with that or do you just leave it? Yeah,

Ibiere Seck (: 00:21:04

I do. I don't ask it, but it almost always comes up. If I'm curious, I might go down that road. But we have to understand that people are thinking those things because we're resilient humans. We're resilience, we're solution oriented. We're always trying to find a way to do make things work. So if you can't do one thing, the expectation is find another way to do it or do something else. So for example, I might have a client, I can think of so many examples, but this is the first one that comes to mind. A client who, because of her husband's injury, I represent plaintiff's in loss of consortium cases, usually the so-called non-injured spouse, the non physically injured spouse. And so say for example, the issue is the couple is not as intimate or can no longer be intimate, which means that they cannot pursue their family planning goals.

(: 00:22:01

They're not probably going to have children or anything like that. So jurors might say it could be anything like that. The argument might be, well now they can no longer have children either because they physically cannot procreate because of the injury or they just are no longer, they don't have the intimacy. Jurors will think, well, if you really want to have a family, there are ways to have a family you can adopt. There's surrogacy. They come up with all sorts of things and I have to anticipate that. And so oftentimes I get ahead of that before they can start giving me other examples of how you can achieve a family. I'm thinking about, let's talk about what it means for this couple to have a family together in the traditional way and be able to say that this is my child that I conceive with my husband, my wife, and look at that child and know that they had a healthy journey into this world.

(: 00:22:53

All those things, and they're coming into the world that's with parents that are healthy and happy and that's being taken away from them. I have to build it up. So for this purpose and this purpose alone, that there is no alternative that will come close to the original plan, no alternative that will come close to what you believe was part of your destiny and now you have been robbed. Do you know what it feels like to be robbed for someone to snatch something from you or to thrust something on you that you never, never expected and in no way deserved? I want the jury to feel outraged and not even talk about an alternate or alternative. It doesn't count, nothing comes close. And if you're going to give me a plan B, pay my plaintiff for the humiliation, the inconvenience of having to endure a plan B. Does that make sense?

Dan Kramer (: 00:23:52

Yeah, but how are you doing that? You're obviously not saying all this in jury selection, so what do

Ibiere Seck (: 00:23:56

You mean? Oh, I'm not saying it in jury selection, but I'm thinking it. And so I am prepping them. I'm priming them. So I'm talking about what it means to them to be able to have a goal. We can just talk big picture generally, because really these concepts, and Harry knows this, we're introducing these concepts into jury selection, these ideas, these hypotheticals into jury selection so that we can then argue them effectively in closing arguments. Remember when we talked about jury selection? So in terms of the alternatives as Harry laid it out, why can't you do X, Y, Z? That might come up and I would say, well, what do you think about if someone can't have children just adopt? I guarantee you there will be a person on the jury say, no, not the same thing. Why isn't the same thing? And someone will give it to you.

(: 00:24:49

This is the beautiful thing about a jury. Someone will always save you. Someone always has the so-called right answer, why isn't that the same thing? Juror number seven, tell me more. Juror number seven, because anyone else feel the same as juror number seven. Yes. And they continue to give you answer upon answer and they go deeper and they go deeper. And you take that little thread and you go to someone else. That's all it is. And I'm just listening. I'm listening. Or I might say, what is it? Does someone feel differently? Someone, another juror will always save you. The important thing about jury selection, you have to know where you want to go. You have to know what you want people to talk about, what you want people to feel, and you have to somehow get them there. And if you can't get them there, then you have to be very explicit. You have to ask the question that Harry posed and I would pose it just like we talked about here. You know what? Lemme give you an example. Someone can't have children. Some people might think, no big deal, adopt surrogacy. Someone might say, no, that's not really what I signed up for when I chose my partner and got married. Okay, where do you fall? Let's talk about that. That's it. It's that simple.

Harry Plotkin (: 00:25:56

It's not that different from, so I pick a lot of juries in sex abuse cases, and one question I think is always important to ask is, has anybody ever seen someone who was the victim of sexual abuse or molestation or whatever, sexual assault, whatever it is in the case and kind of rebound and live a totally normal happy life, or do you feel for the rest of you, anyone feel like that's something that's relatively easy to do because those jurors are just dead. They're like, oh yeah, this happened to them and that's terrible, but why are they damaged now? I mean, you could ask that question for any case. You could ask it for a personal injury case just about basically what are your thoughts on whether somebody's passion is taken from them because or ability to have children or whatever it is, should just be able to rebound and find something else and live just as good a life or not.

(: 00:26:40

I guarantee you, especially these days, you'll get a lot juror saying no, and let me tell you why. And giving probably angry speeches every was just giving in her closing and be like, and everybody's writing it down. This is a great closing or that's actually what I was going to say in my closing. But you do want to find those people who are just, people are so resilient that nothing should phase you. There's always a plan B that's just as good. We don't want those jurors who think because that's not true. Maybe this is an LA thing. I see a lot of people on the journey. Anytime I see someone who's like a life coach or something like that, and I've seen it a bunch of times, they think that they're giving someone money for emotional distress is actually harmful to them and somebody can get over.

(: 00:27:20

There's nothing you can't get over and just be just as happy and strong. If you think that way. They're not going to give any money and you think you're going to be doing the plaintiff a gift by giving 'em nothing for future, but other people feel that you don't have to be a life coach to feel that way. But that's a great line of questioning and getting, inviting them to tell you whether you agree or not with that feeling like you could just bounce back from anything. Or do you think, no, not really. There's nothing wrong from hearing from those jurors who are good for you. The defense is going to be hearing from a lot. It's not like it's going to be one or two people and the defense can just strike 'em all right? When you're asking those questions, is it usually just one or two people or is it like a lot

Dan Kramer (: 00:27:55

One or two? And then you pivot to find out who feels the opposite chart foot.

Ibiere Seck (: 00:27:59

And then sometimes it's a really important issue in the case you have your can't get over issues. Those issues in the case that are critical, I think they're deal breakers for the case. It's an issue that you need jurors to really understand. I will go through each juror. I will say, this is important, so I want to hear from each of you. We're going to take our time. It's really important. I want to hear from each of you and we'll go down the list or go down the row on the same. When we're talking about just your hobbies, I want to hear from each of them. I want them all kind of thinking about those things. I don't do that for every question. It's just those really important issues because I do want to know where people stand

Harry Plotkin (: 00:28:34

And that way the defense can't strike. They're like, okay, if we are going to strike everybody who kind of agreed with Ms S, that's like 19 of 'em. So good luck. Get rid of all those folks. It's not like, so you don't just talk to just one or two people just to kind of get other jurors thinking. You talk to all of

Ibiere Seck (: 00:28:48

'em. I talk to all of 'em. I

Harry Plotkin (: 00:28:49

Think lawyers, that's one thing that lawyers, one of the things that they don't do enough is talk to at least whatever question you think is really important, talk to all of 'em. Don't just talk to one or two people and don't have anybody in there that you haven't heard something from. That's important. Yeah.

Dan Kramer (: 00:29:04

I'm interested in how you say you got to have your plan, right? What's your approach? You come into a case, you have a case you've had for a while, you're gearing up, you're two weeks away or whatever. Just what is your system? Because every attorney has their own system on how you prep your jury selection. What is your method?

Ibiere Seck (: 00:29:22

Because I'm coming into cases on the eve of trial now. I'm not litigating cases. I'm trying cases with other firms.

Dan Kramer (: 00:29:30

So is that kind of a hundred percent your practice

Ibiere Seck (: 00:29:31

Now? Yeah, a hundred percent my practice. I do not. If you came into my office in downtown LA, you will not

Dan Kramer (: 00:29:37

See. You don't have form rocks sitting out that you've been working on all night.

Ibiere Seck (: 00:29:40

Nope, nope. Not a single case file.

Dan Kramer (: 00:29:43

God, you're lucky.

Ibiere Seck (: 00:29:44

So yeah, those days are gone. Not to say I won't revisit that at some point, but right now I'm having a ton of fun just trying cases and so I don't have the benefit of living with the cases for years and really focus grouping and thinking about it. Really what my process is. When I hear the facts of the case, what emotion does it stir up? What do I feel? What issue is glaring? What are the red flags? Setting aside what my colleague might think about it, I'm thinking when I hear those facts, this troubles me and I'm going to tell you why. And then that's my jury selection. My jury selection is what are the issues that are central to this case? The things that when you hear it for the first time, that elevator pitch, that mini opening that the juries are going to go and you can't wait until closing argument to convince them otherwise. You've got to deal with it head on. That is my jury selection.

Dan Kramer (: 00:30:43

I love hearing how they exactly break it down. So case comes in, attorney calls you say, Hey, Eby, I need you

Ibiere Seck (: 00:30:49

To give me a fact. Give me a fact. Daniel, anything you like, throw something out here, throw anything out me anything, make it crazy, whatever.

Dan Kramer (: 00:30:56

All right, cool. I'll do what I got coming up.

Ibiere Seck (: 00:30:58

Okay. You're so excited. I love it. This is free eary advice

Dan Kramer (: 00:31:04

We're getting here without having to affair. I love it.

Harry Plotkin (: 00:31:08

How about let's do a loss of consortium. I know you're better than anyone in the country at that wife of a person who was smashed into by a truck driver who fell asleep because the trucking company was pushing him to make a delivery and he skipped one of his required breaks or something like that. And the husband does a lot of things. He just can't do chores around the house.

Dan Kramer (: 00:31:31

You gave her a softball, dude, that's a softball. You went, oh, come on. That's not a hard one. That's easy. Go ahead, Evie. Anyway, that case comes to you. The referring attorney or co-counseling attorney says, here are the facts. You're just sitting with those facts and you're already thinking, okay, what are the,

Harry Plotkin (: 00:31:46

Well, lemme throw the curve ball in there. This is a couple that is like 78 years old. Obviously they already have kids, they already have grandkids, and he was already at an age where how much could he physically do? I mean, it's like activities that you're going to say they can't do the things they love, he can't help around the house. But on the other hand, you have probably jurors who are going to be like he was already 78 years old, is not, he wasn't super active

Dan Kramer (: 00:32:09

Because he really likes bad fact and he was on meth at the time.

Ibiere Seck (: 00:32:11

He was in meth. Yeah. Wow. You guys, 70-year-old couple man is on meth.

Dan Kramer (: 00:32:19

So that's there for you and you're prepping your jury selection. What do you do? How do you do it?

Ibiere Seck (: 00:32:22

I look at those issues. I look at the plaintiff. What is it about the plaintiff? That is what I like to call flawed. What about them would a juror think I'm not really a fan of. So of course the easy ones are drugs and alcohol. Anytime you have a, that was under the influence of any substance, that's an issue you need to address anytime your plaintiff is breaking a law, no matter how minor an infraction, it doesn't matter if they are not pristine and perfect, you need to address it. If you have a plaintiff that is terribly injured but didn't treat, I have my colleagues say this all, oh, it's okay. They worked through the pain or they eventually got treatment or they couldn't, all these excuses. It's like I have to address that. I mean, I'm thinking how our cynical person would think, or my life, my family members, Evie, why do you do this kind of work?

(: 00:33:20

This is what's wrong with your case. So I'm thinking about those facts. I'm thinking about what is it about it? We do this for a living and we drink the Kool-Aid. I don't drink Kool-Aid. I make it my job not to drink the Kool-Aid. I'm looking for what is the average person going to think about me, you the client. And then I'm thinking about what are the things are reasons why a potential juror would get a defendant a pass? So you're talking about truck driving example. What about the truck driver makes the truck driver empathetic? What about the truck driver? Could a juror also see themselves doing as well? Right? So you talk about medical malpractice cases, cases involving poor treatment in a hospital. Do you know how sympathetic jurors are to nurses? Do you know how sympathetic jurors are to teachers? Do you know how sympathetic jurors are to young inexperienced drivers or elderly drivers?

(: 00:34:23

Come on. There's all sorts of reasons. I have to think about not only what is it that I concerned about with regard to my plaintiff, but what is it that I really like about the defendant? Because in my line of work, in our line of work, we have to find a way not to villainize. We have to really expose the defendant and show the jury that they had choices, people have choices, and that they intentionally made the wrong choice. Jurors do not forgive people who lie, who cheat, who steal, even if the jury pool is full of people who lie, cheat and steal because they judge other people.

Dan Kramer (: 00:35:06

I love that. I really love that approach. It's like your initial approach is what are the things that I may love about the defendant?

Ibiere Seck (: 00:35:13

And

Dan Kramer (: 00:35:13

Then figure that out. And then that's how you kind of start. I think if you came from that, I've never really thought about it that way, but starting your jury selection, planning from that perspective really get you to a good place, I imagine, because then you're crafting your questions and then, yeah, so explain how you get to the point where you've got your questions that you're going to,

Ibiere Seck (: 00:35:34

Once I start figuring out what these issues are, I mean I have a pretty kind of matter of fact approach. I like Harry's approach too because he kind of gives you these really detailed

Dan Kramer (: 00:35:45

Questions

Ibiere Seck (: 00:35:45

And he sets it up and he's like, you tease it up. And then he's like, okay, there's the question. And depending on my mood, I'll do that. I'll kind of like, okay, let's slow walk into this. Let's dance into this. And other times I'm just to the point, Frank, listen, I saw this case when I first saw the facts, or it could be any issue. Sometimes I'm a little careful about talking about the specific facts of a case, but if the issue is a nurse who is caring for someone in a hospital and she makes a mistake, we're talking about people who have to take on jobs that are challenging, they're under a lot of pressure and they're doing their best. I want to talk to you about do we give people passes when they're simply doing their best? Something like that. Sometimes I just throw

Dan Kramer (: 00:36:33

It out. Do you say we or does anyone feel like

Ibiere Seck (: 00:36:35

No, I say we. I'm part of, we

Dan Kramer (: 00:36:37

Explain that I'm

Ibiere Seck (: 00:36:38

Part of the jury. We're talking, we're all on the same page. We're having the conversation. We are a part of the same community. We're thinking we might have different experiences, but we as a people, as a society, as a community, we're together in this. So I'm a part of it. I might not be able to tell you explicitly how I feel, but don't we all agree?

Dan Kramer (: 00:36:59

Don't

Ibiere Seck (: 00:36:59

We all agree? That's really what I'm trying to do when I'm with the jury selection. In the jury selection. And then another thing, I mean, this is something we haven't really talked about. One of the reasons I'm so frank and so plain in jury selection because I think we lose sight of the fact that we are just talking to people. We are just having simple, I would hope, simple, honest conversations. And when I'm thinking about my jurors, I'm thinking about if we're in my living room or sitting together on the couch, either you next to me or you across from me, how would I talk to you? How would I want you to talk to me? And really just focusing on that. If I'm doing my job, the jury is comfortable enough with me that they forget that there are 40 other people in the room, they will forget. There are 40 other people in the room and a judge with a black robe on and they're just talking to me. And I'm hoping that they reveal parts of themselves that they would not normally reveal to someone else, a stranger or in the company of strangers because they're comfortable enough with me to know that I'm not going to judge them. I'm inviting this and it's easy. So that's how I kind of approach it. And I hope I answered your question.

Dan Kramer (: 00:38:11

You answered it with even better stuff that we're going to explore a little more here. I want to thank quickly, thank our wonderful sponsors who helped us get this off the ground. And we think this is really going to help a lot of attorneys out there who are scared to try cases because frankly, jury selection is one of the scariest things to do. My first mini trials, it was like, oh man, you get a bad answer and you don't know what to do. So I want to thank the people who helped sponsor this to get this off the ground. KW court reporting. Cameron and Whitney, really wonderful people, great company. As I've said before, I don't go to trial without them. They are on it. Their court reporters are excellent. Give us real time dailies, everything we need till late at night. Really fantastic company. Cameron and Whitney.

Ibiere Seck (: 00:38:58

Oh, I love Cameron and Whitney and they love me. Hi Kia. Hi Whitney.

Dan Kramer (: 00:39:03

And then also want to thank Tory Owens. Tory Owens instruction settlements. Another guy, what's so important I think is a trial lawyer is you want the people you work with that you partner with that are going to be there all the time whenever you need them, frankly. And Tori is just, he's texting me this weekend. We're working on a structure. My client didn't want to a structure, but I want to structure a part of my fees to put away, and he's hooking it up. He's just working with me late at night. It was his birthday. He was helping me, texting me, just someone that's always available. And Torrio Owen is always there. I know he's a friend of yours too.

Ibiere Seck (: 00:39:34

I'm a fan. He structured my cases as well. I remember being Tori when he first started out, came to my office when he hit the ground running, and I remember just thinking, wow, this guy is young and I love the ambition and I've been working with him ever since. He's a great guy.

Dan Kramer (: 00:39:51

And then last but certainly not least is Verdict video. Harry, let's talk about Kelly here.

Ibiere Seck (: 00:39:56

Kelly, I just saw Kelly. I just saw Kelly. She's doing some wonderful work for the Cali Gala. She does our videos and I've known her for years too. Gosh, you have all my friends here. I know all my

Dan Kramer (: 00:40:07

Friends

Harry Plotkin (: 00:40:08

Are. They heard

Dan Kramer (: 00:40:08

You

Harry Plotkin (: 00:40:09

Were doing it and they signed up. Only great people, only great guests, only great sponsors. The funny thing about Kelly and Verdict videos is that this is a podcast about trial lawyers and how to win your trials and pick a good jury. But it's kind of weird that Kelly's here because it's like Kelly's the person you call if you don't want to try. You want to settle a huge settlement. I mean, honestly, if I did not want to settle a case, there's no reason to call Kelly.

Dan Kramer (: 00:40:34

I mean Day in the life, she can get the evidence. I'm going to use her right now on a day in the life for trial.

Harry Plotkin (: 00:40:38

I'm half joking about it because the point I'm making is that her settlement documentaries that she does are so compelling and incredible and professionally done that. I just can't imagine an insurance adjuster watching that. Or some in-house defense counsel watching one of her settlement documentaries and thinking that they have any shot at winning these cases because she just makes these incredible settlement documentaries that increase the value of your settlements by 10 times easily. And so it's dangerous though. I mean, if you don't want to settle a case, just someone as good as Kelly get someone terrible. But Kelly is amazing at her. But yeah, you're right. I mean she does amazing day in life videos for cases that really can give them jurors an insight into what the, it's one thing for a plaintiff to tell what their life is like or what their loved one's life is, is another thing to show. So yeah, 100% you should be doing more. I don't see nearly enough day in the life videos, frankly. Jurors do not respond well. Every time I prep witnesses to when somebody says, my husband's not the same person anymore and he's just this or that, and then they're like, jurors are like, well, why should I listen to you? I mean, you're not totally objective and it's easy to say that, but if you show it, it's a whole different story. And so if you're looking for something like that, call Kelly Deutsche verdict videos. They're just incredible.

Dan Kramer (: 00:41:49

Yeah. Iberia, I want to talk about, I mean, you're obviously very smooth, extremely charismatic in the courtroom. You could tell. I've seen you spoken on panels with you. It's really inspiring. Were you always this good in your first new trial for the rest of us, give us some hope that we can to your level. But I mean, what are some of the things you used to do different that you're like, I don't do that anymore, that you've kind of just really evolved?

Ibiere Seck (: 00:42:16

So I used to be talk about myself if I could. I was more interested in getting my point across than I was hearing the perspectives of the jurors. And I see this, it's a very common thing in our profession, people just wanting to talk and talk and talk and not enough listening. I shifted many, many years ago to a place where I really am just interested in hearing what my jurors have to say first and foremost, and then trying to discover or pull out or tease out what it is that they don't want to say. So I am listening now from a place of curiosity. I don't have an agenda. That's the difference. I don't have an agenda. I think the reason I was talking so much is because I was trying to persuade or convince I was trying my case. Now it really is about understanding the jurors and what they think. I also was very judgmental. We do this bad juror, good juror, bad person, good person, Democrat, Republican, black, white man, woman engineer.

Dan Kramer (: 00:43:44

I was just going to say that engineer school teacher. It's a nurse.

Ibiere Seck (: 00:43:47

Oh yeah. I mean, I was so caught up in that and I let that go. I leave that for the people who you pay to figure all that stuff out, whether or not someone actually is, thinks the way they think you think they think versus let them tell me. Also, when I say that I'm focused on what people are not saying. I really am thinking about, or I'm interested in finding out what people's values and beliefs are when someone says something, we have these conversations with the jurors and what we were so focused on and we're writing the things down. What they say, the facts, right fact. They say, I believe this, or I think this. What I'm focused on is not what they're saying, but where that comes from. What is that rooted in? What is that based upon? What in your life experience has brought you to this belief?

(: 00:44:48

Tell me about it. And then if they can't articulate it, this is why language is so important for me, is that I have to be able to articulate. So what I'm hearing you say, juror number seven is, please correct me if I'm wrong, but what you're saying is, or am I wrong to believe that you are saying this? I'm putting words to their feelings, their emotions, their beliefs, their values. Loyalty is important to you. Honesty is important to you. Accountability is important to you. I also study the words emotion, not just sadness and anger and grief and all these things, but I'm trying to figure out all the complexity of emotions. I mean, this is what we're doing. I also spend a lot of time and silence. We don't always have to feel the space with words. I have found that sometimes if you just quiet with the jurors, you give them time to think and you give them the space to speak up if they have the courage. And so I do that a lot more and it's worked well.

Dan Kramer (: 00:45:53

Yeah, I mean, I think one of the most important things that for all the listeners is just saying, don't come in there with an agenda. Harry and I have talked about this many times, probably my agenda too, like yours, I was probably fearful of the jurors of the jury as a whole. And I would think about them as a whole group and I'd be scared of them. They're going to hate my case and all that. And then that would lead me naturally to just try to get as many cause challenges as possible. And if I'm going in trying to rack up as many cause challenges as possible, what I've done is just kind of turned off, probably underselling my case, talking about all the bad shit in my case, and then not really giving the good jurors an opportunity to see the good in my case. And then sometimes I would get, and Harry and I have talked about this, good jurors maybe off for cause because they said something with the way I was kind of coming in with the way I was presenting my case. And so I think not having an agenda is also, it's liberating for the trial lawyer because there's kind of that less pressure on your back and you're just there to meet new people and get to know them. You have your plan. And I think a plan is different than an agenda, but

(: 00:47:02

I just can't agree with you more. And again, it's important. Always have a plan. Like Eber is saying, always you have to prepare, prepare, prepare. But an agenda is something different. Harry, what are your thoughts?

Harry Plotkin (: 00:47:10

Yeah, if your agenda is just to hear from everybody, introduce topics and not prejudge, maybe this jury's going to be great. You're going to like 'em all. Or maybe they're going to be a lot of bad jurors, but don't prejudge it. Just if your agenda is just, I want to hear from these people and assess 'em, and you're going to get a good jury, then you're really listening to 'em. And then you're really figuring out, is this okay? You're telling me this and that, but is this person open to what I'm saying? Or they, I've seen too many lawyers sometimes come in there and the first chance that they get, try to get someone for, cause they're like, one time my uncle, I think he got sued in small claims court and they're, they jump on it and they're like, so does that mean that you're not fair? You can't be fair. And then the person, and you get one or two things, you either get, I guess you're right. And then you just chased off somebody who isn't necessarily a bad juror because you sort of weirdly prejudged 'em. Or you get like, and they're annoyed at you. You're like, why are you attacking me? Why aren't you cross-examining me? So you just got to listen. And they'll tell you if they have a problem with something.

Ibiere Seck (: 00:48:11

And not only that, it has another effect. It has a chilling effect on the rest of jurors. It has a chilling effect. They're thinking, oh my gosh, if I say something, what if I feel the same way? I don't want to,

Harry Plotkin (: 00:48:23

Yeah, I'm here to jump on the things you say. And as soon as I say something, this lawyer is just, I've seen her do it two or three or four times now just somebody speaks up and then now it's cross examination time as opposed to someone who's listening and interested in what they have to say and not pushing them one way or another. And I love what every said was when you're telling them, is this kind of how you feel? But not putting words in their mouth in a pushy way. They're like, yeah, you're listening. I appreciate that. They like that you're listening. And if they say, no, that's not really how I feel. As long as you're not like, I've seen defense lawyers mostly say this, but how you say you're not, how can you say you'd be objective if you just said that? They literally yelling at 'em. If you're just going, my mistake, tell me more about it. Then you're just showing everybody on the jury, I'm not here to attack you. I'm listening to what you're saying and I'm interested in your thoughts, and I'm not going to judge you or attack you. The last thing you want to ever do is judge even give any impression that you're judging anybody no matter what they're saying.

Ibiere Seck (: 00:49:18

So what's interesting too about this jury selection, this art, the science and art of it both, is that there are so many different styles and so many different approaches. And I'm sure you all are going to see this and experience this as you're kind of talking to all of your guests over the next few weeks. But you can pick a good jury being very methodical and scientific. Absolutely you can do it. The odds are you can get it done and you might get a jury. I say it's 50 50 basically depending on the jury pool. I don't want to take that chance. I want the best possible opportunity to put together a jury that is going to come back with a verdict that is fair, that is right and exact for my client that is justice and that whatever I can do to get them there beginning a jury selection, I'm going to do it.

(: 00:50:10

And so my approach isn't necessarily scientific, is very artful. And I have to think of it more as an exercise in some ways of conversation. And also of this might be a little bit unconventional, but of meditation and of acceptance and of forgiveness and of understanding. I literally take that approach. And an example is this, and I've seen a lot of people try juries and you'd be surprised just the energy, the energy of the trial lawyer can change the entire dynamic in the room. If they're aggressive, if they're judgmental, if they're argumentative, if they're manipulative, you can see something happening on that jury. It's going to be really hard to get a good jury versus someone coming in and being very much open and understanding. And even if you're not, say it like, hi here, I'm here to be opening understanding, but they sense it.

(: 00:51:13

If you ever walked into a room and you come in with bad energy and all of a sudden people are like, Ooh, that she's off putting because your energy is wrong. Their energy is wrong. So I have to go into the space with the right energy. I have mantras that I'm saying to myself, I am seeing every person as an individual. I'm looking there in their eye. I'm saying silently that I want to be close to you. I want to connect with you. I'm going to invite you to have a conversation. Please accept the invitation. And you'll be surprised how transformative that is. People sense it. And that is why when people see me during jury selection, like, gosh, how does she do that? How does she do it? It's because I think that's the energy that I come with. And I truly am. I'm coming from a place of curiosity. I truly am.

Dan Kramer (: 00:52:02

What are your mantras? Can you tell us, are they private?

Ibiere Seck (: 00:52:04

Oh, no, they're not private. I'm not a gatekeeper. I'm not a gatekeeper. Daniel Kramer.

Dan Kramer (: 00:52:10

I want some mantra. I need some new mantras.

Ibiere Seck (: 00:52:12

Well, this is interesting. And it is more or less like a way of life and just how I've kind, just moving through the world, just the way I see things. I really am trying to be more open and I want people to feel comfortable around me. And so there is a prayer that, or a mantra that I think some folks are familiar with. It's a Hawaiian, traditional Hawaiian practice and it's called Ho Oppo. No, I pronounce it sometimes incorrectly. And it really is just a few words. It doesn't involve a ton, but I say it to myself and it's essentially, I'm sorry. Please forgive me. Thank you. And I love you. Right? And when I'm looking at my jurors, I'm saying that to myself and to them, it's my eyes, it's my energy. It's how I move. It's my gestures. It's my tone. It is literally, I'm sorry. Please forgive me. Thank you. And I love you.

Dan Kramer (: 00:53:09

Wait. That's just basically what I tell my wife almost every day. You

Ibiere Seck (: 00:53:12

Tell her that and she's still with you. She gave you a couple babies. So it works.

Dan Kramer (: 00:53:18

I know this mantra sounds

Ibiere Seck (: 00:53:21

Very familiar. It does. But when we're talking about your conversations with people, I mean, what gets people to open

Dan Kramer (: 00:53:26

Up

Ibiere Seck (: 00:53:27

It is just genuine kindness and openness. And I say those things in jury selection sometimes out loud. I'm sorry, we might've gotten off on the wrong. Sorry, I misunderstood what you said. Or can we start over or thank you and maybe not. I love you, but I really appreciate what you shared with me. Oh my gosh, that took courage. That's the energy I'm moving with. And they're like, wow, give me more. And they give you more. I think that's really effective. I think we have to remember we're dealing with humans and people like to be around kind people. They like to be around nice people. So be nice and kind. Dan, this is good. Great advice for me. Was that targeted just to Dan with that question? That was, it was because Harry's got this. Gary doesn't have this problem. Wow. Harry doesn't have this problem.

Dan Kramer (: 00:54:22

No, but I do. On that note, I'm going to need some mental health. But I do think that your mindset going into jury selection is super. I mean, it's just overlooked, right? Attorneys don't treat themselves, they don't treat their mental health going into, or their mental wellbeing, mental whatever. Your mindfulness, whatever space you're in going into that first part. Because once you got a jury, you're warmed up opening statement, you're kind of in it, right? So your mindset's in the trial and you got everything else is scripted, planned, what's happening, generally speaking. But I think your mindset, those that hour before the five minutes, 10 minutes before is so important that we overlook because we're stressed about, okay, did I have the exhibit binders? Do I have this? The judge is yell at me. But if you get to that place where you're centered, you're in a good place. That's how you're going to present yourself to the jury. That is often overlooked. Harry, I think

Harry Plotkin (: 00:55:20

It is tough to do. I mean, because yeah, you're worried about your opening statement and you're worried about what are these people going to say? There's a lot of stress in jury selection. So, but just that, not that you're putting the stress on the jurors, but take that stress off your shoulders. And I'm just here to hear from these people not on, you have some topics that you want to talk about, but you're not having to give a speech and you're not having to do anything special. You're just hearing from 'em. And when they give you something that tells you, you struggle to be fair, what I'm hearing you're saying is that you really would struggle with this idea of punitive damages. It just doesn't seem fair to you. Is that what you're telling me? It's not like you're not hitting 98 mile an hour fastballs. You're just there talking and listening and just being a human being. And so practice being a human being, I guess, is the best way to

Ibiere Seck (: 00:56:05

Practice. And also let go of fear. We're so afraid of what a juror might say. I would tell myself, what's the worst thing someone can say to me? I hate lawyers. Your client sucks. You look fraudulent. Now, my biggest fear is what if they don't say anything at all? What if I walk into the jury room?

Dan Kramer (: 00:56:26

I can be fair. Yes. And

Ibiere Seck (: 00:56:27

I start and they don't tell you any. That's scary. What do I do to prepare for that? I found ways to get people to start talking. I am not afraid of a jury never talking. That will never happen again.

Dan Kramer (: 00:56:39

So they are, and you've done all your great stuff and they're still just kind of like, they're just not really opening up. What's your move?

Ibiere Seck (: 00:56:45

My move is someone please talk to me. This is hard because I have one job. I have one job In this moment. In this moment right now it is to find out whether or not this is the right case for you. And I can't do this without your help. Will someone please help me? Someone please help me. And then if they don't, juror number one. This is hard. You're the first, but let's just have a conversation. Can we talk

Dan Kramer (: 00:57:13

To me? Yeah. I love that.

Ibiere Seck (: 00:57:14

No, really, I just in the same way I do. If I were out, talk to me. I believe in my heart of hearts, every case that I try, the jury wants me to win. They're rooting for me. They are rooting for me. And so as I'm looking at these people, help me win. Help me. I do believe that most people like me, most people want to be around me. Is it true? Doesn't matter is what I believe. And so I move with that energy. And what I have found is that yes they do. Nobody wants to see me struggling. And you don't want to lie to me. I don't. Not lying to you. I'm honest. Can you be honest with me? It really is that. And so I have found that we have to just explore what it's like, just being around people, being comfortable around people. If you can't talk to people, why are you trying cases? If you can't talk to people, why are you trying cases? Give it to someone else. I do this because I love the work. I believe it is righteous, good work, and I genuinely like people, and I think that people genuinely like me.

Dan Kramer (: 00:58:27

So we do have to wrap up. My final question, Eby, are you going to run for president

Ibiere Seck (: 00:58:30

20? No.

Dan Kramer (: 00:58:31

No, I'm not. Right. We need you. This country needs you. This country. Yeah. We need you now more than ever. 2028. We don't call it now. No, I'm calling it now.

Ibiere Seck (: 00:58:41

Please. Will you be my running mate?

Dan Kramer (: 00:58:43

I don't think you want that.

Ibiere Seck (: 00:58:44

I know.

Dan Kramer (: 00:58:45

Don't.

Ibiere Seck (: 00:58:45

Especially not. No.

Dan Kramer (: 00:58:47

Yeah, yeah, yeah. I don't think you want that. I think we'd be screwed for another eight years.

Ibiere Seck (: 00:58:52

No, but this has been fun. I love talking with you all. We could do this all day. Harry, I'm super proud of you. You've been doing such good work. I love the verdicts that you're getting with our colleagues. I can't wait to do some work with you in 2025, Kramer. I'm on the fence about whether or not I'm want to try a case with you, but we can talk all day. You can edit. We're going to edit that out. AI

Dan Kramer (: 00:59:16

Is pretty good. And we got your voice recorded. I send all cases to Dan Kramer. I love trying cases with him. That's what it's going to say.

Ibiere Seck (: 00:59:26

Good stuff. Good stuff. Well, I'm proud of you both. Good job with this podcast. I'm with you. Tons of success. Tons of success. I'm really happy you doing this.

Harry Plotkin (: 00:59:33

Thank you. Thank you for being a part of it. Wouldn't want anybody else to be one of our first ones today.

Dan Kramer (: 00:59:37

Yeah, no, we're honored to have you. Someone like you. I can't wait to see what you're going to do in 2025. Thank you. And shout out to Law Pods. Thank you for doing this. Getting the word out, educating attorneys out there through podcasts that are directly for attorneys. We hope this helps a lot of people. We got some big guests coming up. We have Claire Plotkin, the better. Half of Harry a ur, Bob Simon Lordes to Armes, Natalie Weatherford, Gary Dordick, Courtney and Nick Rowley. We got a bunch ebi

Ibiere Seck (: 01:00:09

Oh, fun for the

Dan Kramer (: 01:00:09

First of

Ibiere Seck (: 01:00:10

Many. All friends. All friends.

Dan Kramer (: 01:00:11

Great trial lawyers. Yeah, so thank you all. We'll see you next episode.

Ibiere Seck (: 01:00:16

Thank you. Thanks.

Dan Kramer (: 01:00:18

Take

Harry Plotkin (: 01:00:18

Care.

Voice Over (: 01:00:20

If you're enjoying the podcast, the best compliment you can give us is sharing it with a colleague who would find it valuable. For all the best clips from the podcast, follow us on social media. You can find those links in the show notes. Have a jury selection story to share. Email us at podcast@pickingjustice.com, and we may address it in a future episode. Until next time, remember, you're not just picking a jury. You are picking justice produced empowered by law pods.