The Velvet Hammer™ Podcast

Amazon's Dirty Discovery Tactics

Karen Koehler and Mo Hamoudi Season 5 Episode 25

Episode 25: Amazon's Dirty Discovery Tactics

Amazon dropped a steaming pile of objections to discovery responses and Karen and Mo are not having it. In this episode of The Velvet Hammer™, they unpack Amazon’s absurd responses to basic discovery requests, like refusing to identify their experts or disclose insurance. Karen compares it to getting “pooped on from the sky,” and Mo brings out his alter ego, Ruthless Mo, to call out the obstruction for what it is: a total waste of time and a deliberate attempt to bury the truth. 

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Mo Hamoudi :

Yeah, so Monday, beautiful day so sunny come to office and guess what you get pooped on? Yeah, pooped on by Amazon. Amazon poop.

Karen Koehler :

It is like bird poop. It drops out of the sky, it goes splat. It's totally ugly, stinky and amusing all at the same time.

Mo Hamoudi :

Okay, what I call disclosure. We do not have an anti-disparagement agreement with respect to this case that we're going to talk about with Amazon, and why don't you tell us what we're talking about today, karen?

Karen Koehler :

Okay, so they sent us poo-poo. As I already said, we served in a row. Well, okay, start at the beginning. A different lawyer had this case and realized that they were being taken advantage of and brought it to us to handle. So we got involved and Amazon was very unhappy with that.

Mo Hamoudi :

They were very unhappy with it.

Karen Koehler :

And we filed a minute complaint, which they were very, very, very unhappy. And then we served a discovery on them. So, so unhappy Very much, so Very, very, very the case had been going on for a couple well, for a year at least, before we got involved. Yes, we turned everything around. So then they got the discovery. And then what did they do?

Mo Hamoudi :

They didn't give us that. They gave us 11 pages.

Karen Koehler :

No, they asked for a continuance.

Mo Hamoudi :

Oh wait, that's right. They asked for one extension and we were courteous.

Karen Koehler :

And then what did they do after the first extension?

Mo Hamoudi :

They asked for a second extension.

Karen Koehler :

A second, because they're working so hard on this discovery. I mean, amazon has layers and layers and layers of administration. They have about a thousand lawyers on the case, in-house and out-house, and what did we get?

Mo Hamoudi :

Bubkis A poo-poo Bubkis. We got nothing, man.

Karen Koehler :

It's so bad and I know you guys don't believe us, so here we go. This is just.

Mike Todd:

We should like start having a star system for who can do good or who can't I mean this would be a minus, okay.

Karen Koehler :

So question number one tell us who your experts are. Now there are new court rules that say if you have an expert or any information you can't say well, we'll give it to you when the case schedule, when the time that the judge sets is right there is no time that the judge set that's right for discovery other than timely. So it says identify each person you expect to testify at trial as an expert. Okay, answer.

Mo Hamoudi :

Amazon has not yet determined which experts it expects to testify at trial. If and when such experts are retained, appropriate disclosure in accordance with the case management order will be provided.

Karen Koehler :

Okay, do they have experts?

Mo Hamoudi :

I don't think they have experts.

Karen Koehler :

They could have experts. They could have experts. I don't know.

Mo Hamoudi :

Well the case is so old For them to say they don't have experts. They could have experts. They could have experts, I don't know. Well, the case is so old For them to say they don't?

Karen Koehler :

have experts? This says no, but they don't say that. They say they've not determined which experts will be testifying at trial.

Mo Hamoudi :

That means they have them.

Karen Koehler :

Thank you.

Mo Hamoudi :

And they just don't want to tell us.

Karen Koehler :

They're not going to tell us until the case management schedule says but that's against the rule.

Mo Hamoudi :

That's not the rule. Okay, rule breakers.

Karen Koehler :

Okay, so when they're bad and they do stuff like this, who follows up?

Mo Hamoudi :

Kristen does, and then I do.

Karen Koehler :

Wait, you got to do the Ruthless Mo thing.

Mo Hamoudi :

Oh it's.

Karen Koehler :

Okay, when we follow up with this, who will be following up? Ruthless Mo? Ruthless Mo will be following up.

Mo Hamoudi :

Ruthless Mo. Ruthless Mo will be following up.

Karen Koehler :

And what will Ruthless Mo be doing?

Mo Hamoudi :

Be ruthless.

Karen Koehler :

Okay, but you've got to show how ruthless you are.

Mo Hamoudi :

I'm going to tell him give me my discovery, give me my documents. I want it and I want it now. That's what I'm going to do. He is too.

Karen Koehler :

All right, I'm going to do he is too. All right, it's going to be worse than that, though.

Mo Hamoudi :

It is going to be worse than that. I'm in a good mood, it's sunny outside and you're asking Ruthless Mo to come out. It's going to take a little bit, but I've got to read more of these and I'll get angry.

Karen Koehler :

All right. Number two identify and describe all the facts upon which your denial of liability is based. Okay, let's stop here Now. Liability means cause of the incident.

Mo Hamoudi :

Okay, yeah.

Karen Koehler :

I think that the Amazon driver was going the wrong way down the highway.

Mo Hamoudi :

Yes, yes.

Karen Koehler :

Okay, yes, right, yes, there shouldn't be too much dispute in that. Going down the wrong way of the highway yes, all right, there's a little bit more, because there's also vicarious liability. We just asked for liability, okay, so remember their driver was going which way down the highway Wrong way. The wrong way down the highway, and so it should be pretty simple, right? Yes, okay.

Mo Hamoudi :

But it's not simple. There is a complete paragraph of.

Karen Koehler :

No, you've got to read it because it's so bad. Okay, as fast as you can.

Mo Hamoudi :

Amazon objects to this interrogatory as it is overbroad, unduly burdensome and not reasonably calculatedly the discovery of admissible evidence. This interrogatory impersonally seeks to obtain impressions, conclusions and opinions of counsel. As it seeks information protected by the attorney, client privilege and work, product doctrine, discovery exemptions afforded consulting experts, trial preparation materials and our information afforded any other applicable protection or privilege, plaintiffs refer to the general denials and Amazon's answer to plaintiffs' amended complaint and to the affirmative allegations and our affirmative defense and so forth. Therein Amazon further objects to the extent this interrogatory's premature discovery is ongoing and calls for investigation up to and including in the time of trial, subject to and without waiving.

Karen Koehler :

First, of all, you did that really good. Okay now. So they make this huge objection and now they're. This huge objection, yes, and now they're going to answer, are they?

Mo Hamoudi :

Kind of this is so silly. Amazon responds that it did not employ the defendant. The defendant was an independent contractor under the terms of his agreement with Amazon. Amazon did not employ or control any person involved in the accident, nor was Amazon present at the scene, nor does Amazon have any personal knowledge of the accident. Any damages sustained by plaintiff as a result of plaintiff's own contributory negligence and or the unforeseen superseding intervening acts of defendant over whom Amazon had no control, additional affirmative defense is pled in the case other than superseding negligence, or apportionment were pled to preserve them on the basis that facts would come in light as an investigation and a discovery process gives rise to the basis. Such affirmative defenses are from allegations. In the absence of completion, pretrial discovery and additional information that should be revealed by discovery proceedings, including depositions, amazon does not possess sufficient information to fully respond to this interrogatory at this time.

Mike Todd:

Amazon reserves the right to supplement its response to this interrogatory.

Mo Hamoudi :

I think you're ready to do a side job as an auctioneer? I think so. Sold, sold for $5.

Mike Todd:

Sold for $5.

Karen Koehler :

There was nothing said in this whole answer.

Mike Todd:

No.

Mo Hamoudi :

What? No, there wasn't.

Karen Koehler :

Wait, wait, Mike. What happened in this accident?

Mike Todd:

I don't know I just told you, we told you oh, the guy was driving the wrong way down the freeway. Yes, okay, say that right.

Karen Koehler :

I mean, uh, yeah, yeah, I, that's an easy one I I'm confused as well.

Mike Todd:

I I feel like if you're driving the wrong way down the freeway, we're not just talking about like a one-way alley or something like that, we're talking about the freeway.

Karen Koehler :

Okay, we go to interrogatory number three and now what they're going to do. See, remember that answer we just read.

Mo Hamoudi :

Yeah.

Karen Koehler :

They're going to invoke it, so Are they wizards? Like the next series of questions, will just say hey, see our answer to that one that we just did.

Mike Todd:

Yeah, exactly. They're just going to keep saying go back to that long answer. That meant nothing.

Karen Koehler :

So we ask number three, we ask if someone else is involved, and they say hey, go back, we invoke it. They say specify all facts upon which your affirmative defenses are based. They invoke it. Okay, oh my God, okay.

Mo Hamoudi :

You know, okay, I'm going to have a discovery conference with these guys and I'm going to tell these lawyers why are you wasting my time? Now I'm getting angry. I am reading this. This is an entire waste of my time, entire waste of my time. Why did they do this? Why?

Karen Koehler :

did they do this? This is why Amazon lawyers say that Mo is not cordial, of course.

Mo Hamoudi :

This is an entire waste of my time.

Karen Koehler :

Why are?

Mo Hamoudi :

you making me read these words.

Karen Koehler :

After two requests for continuances. Who does this?

Mo Hamoudi :

What kind of professional drafts responses like this? This is an entire waste of my time. This is an entire waste of resources. This is worse. The denials here, the denials here. These people are untethered from truth, from reality. They're irrational. He's going off. No, I am. This is pissing me off because, okay, all right, stop, all right.

Karen Koehler :

All right, ruthus Moe, I backed you off.

Mo Hamoudi :

Okay.

Karen Koehler :

Okay, interrogatory number five this is one that the courts have drawn up. This language, by the way, is all kind of form language. The questions, and this one is a form question. It's basically regardless of whether you agree that you're faulted or not, tell us all, each, identify, each and every policy of insurance maintained by you that may apply to the claims or may be liable to satisfy, or any part of the judgment, and that includes the name of who's insured, the entity who issues a policy, the policy limits, the policy periods, any exclusions, any decisions affecting coverage, and go on and on and on. Now, again, this is basically a court-based request.

Mo Hamoudi :

Like do you have insurance? Do you have insurance? Do you have insurance? Not a trick question and just to clarify for me.

Mike Todd:

This is the insurance that amazon has, not their third party. Yeah, this is this.

Karen Koehler :

These are responses to amazon just amazon.

Mike Todd:

This is only there's a whole separate set of attorneys that are dealing with the other side.

Mo Hamoudi :

Okay all right okay amazon objection is in their octagon grounds it is overly bought and duly burdensome, seeks irrelevant information and is not reasonably calculated to lead to the discovery of admissible evidence. You under breath and scope of Amazon's insurance program and the circumstances of this accident render this interrogation excessive, given the facts and claims in this litigation, amazon further objects to this interrogation on the basis that it seeks sensitive and confidential proprietary business information yeah, sensitive and proprietary business information as to its insurance.

Karen Koehler :

Sensitive like emotional, they might cry.

Mike Todd:

I think they are crying.

Mo Hamoudi :

Additionally, Amazon objects to this interrogatory misleading, assumes facts not in evidence, as Amazon did not employ or control any person involved in the accident, nor was Amazon present at the scene, nor does Amazon have any personal knowledge of the accident. Further, Amazon objects to this interrogatory to the extent it requires Amazon to make a determination as to available insurance coverage.

Karen Koehler :

Subject to Okay so.

Mike Todd:

Wait, they just said that they don't have any awareness of the accident.

Karen Koehler :

Yeah, Because, they weren't present at the scene.

Mo Hamoudi :

Well, they were present at the scene. You know how they were. They're tracking those things Digitally present.

Mike Todd:

The scene. Might they track all those? I mean because it's an Amazon branded van that they were driving right.

Karen Koehler :

No, no, this is different, not this one. This is the Flex program.

Mo Hamoudi :

This is the Flex program.

Karen Koehler :

Yeah, but they still have their little phone to carry around, so they know where they are, they know what they're doing. All right, okay, or I assume? All right, we're not going to like we don't have to say who their insurance companies are? No, I won't say okay. However, it says after laying out a certain amount of coverage. It says a certain amount of coverage.

Mo Hamoudi :

It says Well, it says that After laying out a lot of how much their limits are, it says the part where it says any policy beyond this scope, beyond this yeah, any policy beyond this is beyond a reasonable scope of the present case and therefore not relevant here, given the nature of the facts and claims that issue in this litigation. If plaintiff's counsel believes disclosure of higher levels of the insurance tower is necessary in this case, counsel can schedule a CR26I conference.

Karen Koehler :

If we think that we're going to get a lot of money, then they might have to give us more information.

Mo Hamoudi :

More insurance. So they're basically telling you how much the claim is worth. Okay.

Karen Koehler :

They think it's worth, then they have to sign a certification.

Mo Hamoudi :

Why do they do that? Why do they have to sign that one and not the other ones?

Karen Koehler :

Well, they're supposed to sign all their objections. You know, supposedly that was the old school.

Mo Hamoudi :

Yeah.

Karen Koehler :

But in this one they're supposed to write down the name and sign it of who is making the special certification, Because, shocker, we've had so many cases where they've lied about how much insurance is available.

Mike Todd:

Not they, not just.

Karen Koehler :

Amazon.

Mo Hamoudi :

Yeah, not Amazon.

Karen Koehler :

Other, other people. So for all of these defendants, we always put the special certification. This is not a special Amazon provision. Okay, all right, so I want to. We've got two, and we already talked about the sanctions certification. This is not a special Amazon provision.

Mo Hamoudi :

Okay, all right, so I want to. We've got two and we already talked about the sanctions orders. We did.

Karen Koehler :

From the case where they signed certification and lo and behold, there was way more insurance.

Mo Hamoudi :

Okay. So now I want to talk to you about and get some insight. We have these two particular interrogatories that they have not really responded to, interrogatories that they have not really responded to. What's the process of going through and scheduling a 26I conference and talking to them, and how would you approach that conference with answers like that.

Karen Koehler :

Oh, I still want to go through all of them. Oh, you want to go through all of them. Okay, wait, okay wait, we'll pick another one because you know because. They're very similar.

Mo Hamoudi :

They're all very similar. All of them tell us to basically go pound sand.

Karen Koehler :

But in addition to the interrogatories, of which, again, none of them.

Mo Hamoudi :

And an interrogatory is A question Okay, a question, that's all Okay.

Karen Koehler :

But they include the discovery request, includes request for production, meaning. So we're asking for documents, yes, so let's see which one do I really like here? I think well, they don't like any of them.

Mike Todd:

None of them.

Karen Koehler :

None of them. They're all the same objections. So pick whatever your favorite question is and read it to us.

Mo Hamoudi :

Tell me which number I would say Okay.

Karen Koehler :

Which one?

Mo Hamoudi :

I'm looking, I'm looking, I'm looking. Uh, I would say request for production number 14 oh my gosh, you really went down yeah, because I think that's an important one okay.

Karen Koehler :

Quest for production number 14 all documents related to the amazon flex program, including policies, procedures and guidelines applicable to drivers. Okay, that's the shortest subject of all of them. Yeah, okay, go ahead Well just for our sake.

Mo Hamoudi :

The Flex program is a program where you can take your personal car and then you can enter into an agreement with Amazon and use your personal car to deliver Amazon packages.

Mike Todd:

It's like being an Uber and are you an independent contractor when you're doing that?

Mo Hamoudi :

By contract, you are.

Mike Todd:

Who then? So you individually are, you're not under the umbrella of a third-party company.

Mo Hamoudi :

No, you're not. You're an individual contracting with Amazon. Now, Karen can educate you right now about vicarious liability very quickly.

Karen Koehler :

If Amazon controls you while you're doing the job, enough, then you are in a relationship with.

Mike Todd:

Amazon. That was my question. Is you're actually working for Amazon?

Karen Koehler :

Happens all the time in our Uber cases and our Lyft cases.

Mike Todd:

It's the same with Uber and Lyft. They try to play that same game and they've lost that several times now, right.

Mo Hamoudi :

So what we're asking for is documents related to that program and policies and procedures and guidelines that Amazon imposes on their drivers.

Mike Todd:

And they're objecting to that.

Mo Hamoudi :

Well, yeah, they're objecting to it. Well, yeah, they're objecting to it. No-transcript. In this litigation, amazon also objects to the extent this request seeks information and or documents protected from disclosure by the attorney-client privilege to work, product doctrine or any other applicable protection protection.

Mike Todd:

Yeah, that's a lot of words and I'm just going to say no, because all of that to that I heard is them trying to say our policies don't affect us at all. But how can they not when they're saying that that person's not an employee?

Karen Koehler :

they do. They're just being being obstructionists.

Mike Todd:

Yeah, they're just trying to stand in the way and slow everything down, so it takes longer and longer.

Mo Hamoudi :

This is why I got angry earlier.

Mike Todd:

Oh yeah, I honked the horn Okay.

Mo Hamoudi :

Okay, so I want to.

Karen Koehler :

No, self-education, I'm going to read this.

Mo Hamoudi :

Okay, all right.

Karen Koehler :

It was my idea, dang it, okay, sorry.

Mo Hamoudi :

okay, I thought I was trying to back off.

Karen Koehler :

Okay, I'll back off okay, um, we are now going to role play. Oh, we are. Yes, I love it. Yes, we are. I sent a letter this morning to amazon that said dear amazon, did you see my letter? No, let me see the letter I said dear, okay, you can read my letter I want to read the letter and then we'll go from there okay, okay, and you sent him an Amazon response to this. I sent a note, an email. Okay, okay okay To Mr, I can't remember.

Mo Hamoudi :

Oh, dear counsel, our team just took a vote and agreed that these are some of the worst incomplete, over-objectedto, non-responsive answers to discovery we've seen. Please sign the verification page specifically regarding insurance PS. Disclosure of all insurance means all Mohammoudi will be taking the lead in shepherding you properly through the discovery process. Oh, you've tasked me already, karen. Okay, all right.

Mike Todd:

I imagine you in an Indiana Jones outfit, with the whip.

Karen Koehler :

Yes, so they already know what's coming If they've done their due diligence. Well, they have know what's coming If they'd done their due diligence?

Mike Todd:

Well, they have to because you just got done working with them. What, oh yeah.

Mo Hamoudi :

Well, okay, here's the fun part. They don't know what's coming on Friday and this is not going to be published until after, After they file the motion for a protective order and the objection I'm gonna file for the judge to enter the protective order. It's going to be a doozy. I've been working on it. It's going to be a big one.

Karen Koehler :

Okay.

Mo Hamoudi :

That's going to be fun.

Karen Koehler :

Stay back on track.

Mo Hamoudi :

Okay, I'm back on track. Role playing I'm role playing. Yes, okay, all right, back on track.

Karen Koehler :

So we're going to have our first discovery conference, in this case, yeah. It's going to be Mr Amazon. Yeah, is it?

Mike Todd:

going to be in person.

Karen Koehler :

No, they never wanted to be in person. Yeah, oh. First of all, what are you going to ask them?

Mo Hamoudi :

What do you mean?

Karen Koehler :

Before we set up the call what do we want to do?

Mo Hamoudi :

We want to record this. Hey, do you mind if we record a 26I conference? Yeah, no that's not going to happen, okay, well, we're going to move to ask the judge to record it.

Karen Koehler :

On what basis?

Mo Hamoudi :

Judicial efficiency, transparency and the fact that you have obstructed discovery in another case. I'm going to attach the orders with the judge.

Karen Koehler :

Well, we disagree.

Mo Hamoudi :

Okay, great, fine, we'll go with that. Okay, fine, I went to.

Karen Koehler :

Harvard.

Mo Hamoudi :

Oh Harvard, yes, Harvard you Harvard. Oh Harvard, yes, harvard you went to Harvard. Go ahead, keep going. Okay, how about them apples? You went to Harvard. When are we going to get our discovery?

Karen Koehler :

Did I tell you I went to Harvard?

Mo Hamoudi :

No, you did tell me you went to.

Karen Koehler :

Harvard. Yeah, I just want to make sure you knew that.

Mo Hamoudi :

Okay, well, since you went to Harvard and you took probably civil procedure, you probably understood in civil procedure do you have an obligation to give me discovery, so why haven't you given me discovery?

Karen Koehler :

We did give you discovery.

Mo Hamoudi :

Okay, let me ask you another question. Do you know what happened to my client? Do you know how much injuries they sustained? Are you aware of that?

Karen Koehler :

You know I'm really sorry that the defendant driver hit them, but we have nothing to do with them. Okay, by the way did you know that I went to Harvard?

Mo Hamoudi :

All right, you say that one more time. All right.

Karen Koehler :

Are you threatening me, Mr Hummity?

Mo Hamoudi :

If you say that one more time.

Karen Koehler :

You are being uncollegial.

Mo Hamoudi :

If you say that one more time I'm going to talk to you about where I went to college I If you say that one more time.

Karen Koehler :

I'm going to talk to you about where I went to college. I don't care about where you went to college. You are nothing. You are a peon. I represent Amazon and I went to Harvard. Stop breaking character.

Mike Todd:

It's hard because you just keep saying you went to Harvard over and over. You keep saying Harvard.

Mo Hamoudi :

But I just have a simple question Are you going to give me the documents that I need to prove that your client is liable for this collision? Are you going to do that?

Karen Koehler :

We've already given you 11 pages of documents and if you want the rest, we need a protective order because everything we do is top secret. You don't understand. The whole balance of the world relies upon Amazon. We are so essential to every single thing in the whole wide world. And did I tell you that I went to Harvard?

Mo Hamoudi :

Yeah, you told me you went to Harvard.

Karen Koehler :

Anyway, we need a protective order and we'd like you to agree to that, and all that it'll say is that we're going to show you some documents and then we're going to take them away and you've got to pretend they never existed and never tell anybody about them, and we're going to hide them back where they came from. We might destroy them, but we might also hide them, and they should never see the light of day. But we really don't want to give them to you, because did you go to Harvard? I didn't think so. I mean, I don't know if we can do the pinky swear code.

Mo Hamoudi :

No, but I went to a non-ABA accredited school. That's where I went. Oh my God, I can tell you that I bartended at nights when I went to school.

Mike Todd:

Hold on just a second yeah. Hold just a second yeah.

Karen Koehler :

Rebecca, this guy did not go to Harvard. Can you believe it? I mean, what the heck? I don't even know how to communicate with them. Maybe didn't they say to do that on like a fifth grade level. Mr Hamoudi, let me repeat, we are very important.

Mo Hamoudi :

Yeah.

Karen Koehler :

These documents are very, very top secret, top secret. You know like I spy with my little eye, yeah, yeah, yeah. You cannot get them because you did not go to Harvard.

Mo Hamoudi :

I'm going to destroy your client. That's it.

Karen Koehler :

Mr Hamoudi, that's not very polite.

Mo Hamoudi :

I know it's not Because I'm done being polite.

Karen Koehler :

You are mean Mr Malou, mr Hamoudi?

Mo Hamoudi :

yes, I am done I am finished. I am finished with you. Okay, I am going to extract accountability out of your client one way or another, and that's what I'm going to do. I don't know.

Karen Koehler :

Mr Hamoudi, that's not how we act in Harvard.

Mo Hamoudi :

I don't care, I need you to respect me. I am not a Harvard student.

Karen Koehler :

I am a big bad lawyer, way bigger than you. And see, there are 20 lawyers over here sitting here and we're all taking notes of your behavior.

Mike Todd:

I think we need to record this conference then yeah, I was going to say, if they allowed it to be recorded, they'd have a lot of proof and had you agreed in the first place, you would have had really good evidence to tell this judge.

Karen Koehler :

All right, this meeting has to be concluded because you're mad and mean and we don't play that.

Mo Hamoudi :

That's just the way I am. That's literally kind of how it goes. I believe you.

Mike Todd:

I'm sure. I'm just curious. Can you ask them if it's?

Mo Hamoudi :

a policy for their drivers to go the wrong way on the freeway? Yeah, you could ask them that. They're just not going to answer it.

Mo Hamoudi :

Oh, I'm sure they're going to say they're not their drivers the way they're, they don't know the way they've designed this is that you have amazon and you have lawyers that work for amazon okay, then lawyers that work for amazon hire law firms okay to do their work, and what they do is these lawyers are not, they have no power. They go to lawyers for Amazon. We have a discovery conference, it's strip matter firm again, and what do we do? And they go. You do nothing. So they come in and go. My hands are tied, I can't do anything. So what we're going to do is we're going to reveal that dynamic to the judge that these guys are nothing, they have no power, they have no say, and what you're dealing with is a bunch of lawyers sitting down here on Terry Avenue in Seattle, too cowardly to show up in the court and step up and defend their client.

Karen Koehler :

Ruthless Mo go away.

Mo Hamoudi :

Okay, I'm going away.

Mike Todd:

Sorry, I'm winding him up, you wind me up, but, karen, it's the truth, karen.

Mo Hamoudi :

Okay, I'm going away. Sorry, I'm winding him up, but you wind me up, but, karen, it's the truth, karen.

Karen Koehler :

Okay, okay.

Mo Hamoudi :

It's the truth. Okay, it's the truth. It's gone, but you summoned him and then now you're saying go back His eyes got really dark when he was talking to me.

Karen Koehler :

He really hated the you know, oh, you were firing me when I talked to him in little boy language.

Mo Hamoudi :

But the thing is is that she was playing the part and then I love her so much I can't get angry at her. You did, though I just was starting to get a little and I was like what is she?

Mike Todd:

doing. She did good by just bringing up Harvard that many times, because that can wind you up for sure. That winds me up for sure.

Karen Koehler :

Although I am very proud of Harvard right now. Oh, that's the thing I was going to say.

Mike Todd:

Politically, it's a play on the fact that a lot of hoity-toity lawyers do that, but really Harvard does good work.

Karen Koehler :

They went and bowed to the king and so I'm happy with them. So maybe I should have said, yale, we'll do that next time, next time, say Yale, say Yale, we'll do that next time, next time, say Yale Say Yale, Don't say Harvard Anyway this is the story of our lives.

Mo Hamoudi :

Yeah.

Karen Koehler :

Going about our way, just trying to do our job.

Mike Todd:

Just asking questions and getting the same answer over and over again After two requests, because you know they needed more time to write these objections. Of course.

Karen Koehler :

They didn't.

Mo Hamoudi :

Well, because they have to have meetings with the other firms that they've hired, so they can tell them not to answer, all right. All right, okay, we're done, okay, yes, bye, bye.

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