Establishing Vicarious Liability Against Amazon in Delivery Driver Lawsuits

Recorded Live on March 24, 2026 

Karen Koehler and Mo Hamoudi bring their Velvet Hammer Podcast style to another important CLE. Learn why you should not take Amazon’s word for how much insurance is available in a delivery crash case. And why Amazon cannot insulate itself from liability by claiming its drivers are independent contractors.

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Hosted by Karen Koehler and Mo Hamoudi, trial lawyers at Stritmatter Law, a nationally recognized plaintiff personal injury and civil rights law firm based in Washington State. 

Produced by Mike Todd, Audio & Video Engineer, and Kassie Slugić, Executive Producer. 

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Transcript

Welcome And CLE Ground Rules

Kassie Slugic 0:09

Good afternoon, everyone. Thank you so much for joining us today. Uh today we have something a little different uh from our usual CLE format. Uh for the CLE, you're getting a live Velvet Humor podcast recorded episode. Uh strip from our studio here at StripMatter Law. Um so welcome to the Velvet Humor is not the various liability against Amazon and delivery driver lesson. I'm not into director of origin marketing here at Strip Matter Law. As many of you know, StripMatter Law is licensed by the Washington State Bar Association at the CLE sponsor into the approved for one law in legal credit. Thursday credit leads to until the end of the presentation, at which time I will push through the tool for you to write your bar number. Uh feel free to submit QA or questions to the QA bar. Our presenters are Karen Kohler and Mohamudi, co-host of the Velvet Hammer Podcast, available on all major platforms. This year they also launched their show on YouTube, actually last year, with the help of sound and audio producer Mike Todd. So um you will notice that he is here today as well. Uh please join me in welcoming Karen, Mo, and Mike.

Karen Koehler 1:22

Thanks, Kathy. Kathy.

Mike Todd 1:24

Yeah. Why am I wearing green?

Karen Koehler 1:27

Wait.

Mike Todd 1:27

Okay. It's not green, you're wearing yellow. Yeah.

Karen Koehler 1:29

Okay, first of all, this is open to the public. We did not limit it to plaintiff lawyers only.

Mike Todd 1:34

Yes.

Karen Koehler 1:34

That means that there's going to be an Amazon spy here. So we got to talk about everything we can't talk about. No money.

Mo Hamoudi 1:41

No technology. No, no, no.

Karen Koehler 1:43

How much money?

Mo Hamoudi 1:44

No, we can't talk about money. We can't talk about how much money. No money.

Karen Koehler 1:46

No money. Money, money, money, money. We can't talk about it.

Mo Hamoudi 1:51

More money, more.

Karen Koehler 1:52

Oh, we don't know.

Mo Hamoudi 1:53

Okay, no problem.

Karen Koehler 1:54

No, there's no money.

Mo Hamoudi 1:55

No money that we know of. You can say they have a lot of money.

Karen Koehler 1:58

What?

Mo Hamoudi 1:59

Well, they're bigger than these. No, we can't. Stop. We can't. No. No. Okay. Okay, nothing.

Karen Koehler 2:06

All right. And let's focus. We're gonna not use names. No names. The names shall remain innocent.

Mo Hamoudi 2:11

Innocent and hidden and protected. Because they're all in a witness protection program.

Karen Koehler 2:15

They're wonderful people.

Mo Hamoudi 2:17

Fantastic.

Karen Koehler 2:18

And this is a serious topic.

Mo Hamoudi 2:20

Yes.

Karen Koehler 2:21

So we have um been doing Amazon cases for a while. Before that, I want to uh just kind of start off by saying that we the the really first I can't say money. Can I say big?

Mo Hamoudi 2:36

No, just say first case.

Karen Koehler 2:38

The first case, non-big or money related, yeah. Uh was Lyft that I did with this e-commerce. I did a Lyft, I did it with other attorneys on the firm, um, Andrew, Lisa, and then we did moved on to um and and Shannon came on. Uh, we moved on to um Uber, and then we ended up in Amazon. And of all of them, Lyft, Uber, and Amazon, which is our favorite.

Mo Hamoudi 3:07

Amazon.

Karen Koehler 3:08

It's just like the best.

Mo Hamoudi 3:09

I love my Amazon.

Karen Koehler 3:10

There's just something about suing Amazon that is absolutely the best. Um, and the cases that we have in the firm are, you know, very serious. So uh while we're making light of it, this is not very funny at all. No people that were involved.

Mo Hamoudi 3:25

Seriously hurt, deaf, um catastrophic.

Karen Koehler 3:29

And everything that you've ever heard of folklore, such as do they pee in the Gatorok Gatorade bottles?

Mo Hamoudi 3:35

Yep. True.

Karen Koehler 3:37

True.

Mo Hamoudi 3:39

Yeah, it's true. It's it's uh yeah, it's the the the well the the there's a labor component to these cases that is a separate, separate CLE. Yeah. We're not gonna get into the labor aspect of it, but we may talk about angles having to do. There's a labor component.

Why Amazon Delivery Cases Matter

Karen Koehler 3:57

Okay, so if you can see Mo right now, you might be wondering, like, what what what is he doing? And he's wearing one of the vests that we wear when we go to site inspections, and we we we go we go right to the Amazon warehouse. If you've never done it before, I highly recommend it. Um and also so that when we do scene inspections, we don't get hit. But this whole seminar is focused on Amazon, in particular delivery driver cases. Um we're not gonna be talking very much about product liability.

Mo Hamoudi 4:31

No.

Karen Koehler 4:31

Um there's um Andrew in the firm does loves doing uh uh that and and he should talk about it, but he can't talk about it here because he can't. He's not allowed to.

Mo Hamoudi 4:41

Yeah. Not that he's prohibited from being on a podcast. For other reasons, he can't.

Karen Koehler 4:45

Yeah, he's prohibited. Well, not by us. No, but not by us.

Mo Hamoudi 4:48

By somebody else.

Karen Koehler 4:49

Yeah, by somebody else.

Mo Hamoudi 4:50

Um yeah. So the what you're talking about, the delivery cases is like the proper term is first, middle mile, last mile program. And we're gonna talk about the last mile program.

Karen Koehler 4:59

Yeah. So Amazon is one of the biggest transportation companies in the world now, certainly in the United States. Um, planes, trains, automobiles, vans, cargo ships, everything. Um but what we're talking about here in particular is what's called the last mile program. So they get once they get to the general destination, they have established key warehouses, and it's getting things from those warehouses to the surrounding customers that has caused them to pretty much take over the public streets. I mean, especially here in the Seattle area.

Mike Todd 5:43

Yeah, I mean, it's just when's the last time you were driving on the street and you didn't see an Amazon van.

Karen Koehler 5:50

Everywhere. I can remember, I mean, I was late to go somewhere, which I typically am, and I was in Queen Anne, I was trying to get through, and everybody was stopped. I'm like, what the heck? And what had happened was of course, Amazon had just stopped in the middle of the road. And in Queen Anne, cars can park on either side. We could not get around, and we either and just taking their time to not, I mean, obviously they're in a rush, but all the rest of us, some people were able to back out and then go a different direction. I wasn't one of them because we were just kind of one at a time trying to back up and get out of there. There is an ownership of the roads that is very irritating. We are not here to attack the drivers. The drivers are trying to make a living, and this system has been set up for them. We're not here to try to change labor and industries systems, like in California, uh, or to say, you know, that they should have more rights. And, you know, we're we're not here. What we're they should. They should. What we are here to say is when you kill Mamor injure someone because you are on such a tight rope to have to deliver so many packages, 250 or more packages, in a certain particular time, in a certain geographical per their particular setup and their apps and their equipment. And if you're in a branded truck or not in a branded truck, or if you're in the flux program, or if it's some DSP or whatever this stuff is, when your job takes life mows down people, uh you're uh you need to take accountability. You being Amazon. That's what this discussion here today is all about. Is if you have had a case, so let me let me tell a story. Um, their plaintiff attorney had a case. They had heard that we did Amazon cases and came to talk to me because I'd worked with him before. What had filed a lawsuit had happened almost two years ago, they were going into mediation. And I said, What? Don't go into mediation and then had to rewind that. Now, if you're going into mediation and you have filed a lawsuit and you have a big case, and they say that there's a million dollars in coverage, and you think that that is their policy limits, you're wrong. We are not talking about money.

Mike Todd 8:27

No.

Last Mile Delivery And Public Road Risk

Karen Koehler 8:28

Other than that, just limits. That limit that they tell you that is not correct. If you look at agency, vicarious liability, responsibility, justice, fairness, and equality uh in our society. So that's what we're looking at and focusing on during this CLE program is why did I tell them no, do not do that? And how did that work out?

Mo Hamoudi 8:57

Yeah.

Karen Koehler 8:58

Or in the cases where we start from the very beginning and we say, we don't care about that first layer of code. That's like that's like in one ear, out one ear. No, like what? Don't talk, don't lie to us, don't talk to us about it. We don't care. That's not what this is about.

Mo Hamoudi 9:14

No. Well, I could tell you, like, I think it's important, but a little bit about the story of Amazon, all of this is public information, is that the company at some point decided that it needed to be directly involved in delivering its packages to its customers. Because historically, what was available is your traditional models, which are UPS FedEx. And what happened is Amazon set and US and the United States Postal Service. And what they said was we're gonna create this arm of Amazon.com, which is its what I call the mothership called Amazon Logistics. And then what they did is say, we're gonna create this logistics model, but we're gonna do is create business opportunity for independent uh business owners to run vans and be able to deliver our products directly as we deliver it to our warehouses and come out of those warehouses and deliver them. This logistics model right now has a significant footprint, not only for what you just described, which is collisions, but environmentally. Like you're talking about lots of vehicles on the roads being used, and like environmentally, I mean like traffic.

Karen Koehler 10:22

Um you don't even know half the time because they have the flex program, which are That's a separate program. You don't, but it doesn't say your the vehicle won't say Amazon on it. No, so you don't know. And then even for the DSPs, the delivery service providers, some of them are branded and they use the Amazon stuff, and some of them are unbranded.

Mo Hamoudi 10:41

So the last mile program she just described is one is the flex program, and the other one is called DSP, which is the delivery service providers. Delivery service providers traditionally have an Amazon logo on it. They're they're under an independent model. And the flex, the the flex, but that's what they but well, what I would say is contractually they're under an independent model, just as the flex is, and you can talk about what vicarious liability does with contracts.

Karen Koehler 11:08

Well, don't use the word independent.

Mo Hamoudi 11:09

Well, that's how that it says you're an independent contract. That's a fact. And so part of what we are going to talk about is how to confront these facts. Because that's the that's the facts. That's what the contract says.

Karen Koehler 11:19

That doesn't mean that that's what it is.

Mo Hamoudi 11:21

I understand, but that's the fact that we're that people are like dealing with. Um No, it's not a fact. It is a fact. It is in the contract. You are an independent contract.

Karen Koehler 11:30

That is that is a that is a it's a label that's inappropriately attached.

Mo Hamoudi 11:39

Well, I understand, but it's a fact, and you have to find saying it's a a fact. Well, I mean it's not a it's not an undisputed fact, it's a fact. We dispute it. What it means. It's a disputed fact. I'm gonna do that. Okay, fine. And then so the so so so what what what ends up happening is is that um when you create small independent contracting models, or like, you know, you have drivers just having their cars the flex driver or the SP, you don't have oversight like UPS or FedEx does, because all those drivers work for UPS and FedEx and United States Post Office. Amazon is saying, look, we want to deliver our packages super fast, but we don't want to be responsible for the day-to-day employer-employee responsibilities. Because why? Because the regulatory and cost burden or getting yourself involved in that is crazy. Like it costs a lot to have employees. But I'm not allowed to talk about money, so I'm not gonna say anything right now. Yeah, but but that's a regulatory thing. But they also flip it if you read, you know, it's public. They talk about being independent and earning your own way. Because independent business ownership is a good thing, right?

Karen Koehler 12:52

Okay.

The Coverage Limit Trap In Mediation

Mike Todd 12:53

So that's the that's the course it is when it's manipulated by a corporation.

Karen Koehler 12:57

I gotta stop. I gotta stop you here because that's the that's the company line. That is the maybe that's the company, but the company maybe that was written by a publicist somewhere.

Mike Todd 13:06

You are correct.

Karen Koehler 13:07

Maybe, but but in in reality, in my opinion, allegedly, allegedly, um the DSP model basically is designed to basically be kind of a ma and pa shop, people that don't know anything about delivery. Um, and if you will come and be our straw man, straw woman, straw person, and we will tell you how to do all this stuff, and then you will hire these people, and we will be completely insulated from liability when they screw up. That's that's that's what that is about as big of a driver as anything is their insulation from liability. In their quest to be dominant and fast, they do not want to be responsible for all the bad stuff that's gonna happen. They do not. And case in point, oh no, okay, wait, I can't say case in point. You can't say case in point. A potential case in point, or I can't say case in point. Let's say, for example, hypothetically, someone is a bar owner and they decide I can make a lot of money being a DSP. This is what they told me. So they sign up to be a DSP. They've never ever run a delivery service provider before, or anything other than a bar, which is still a business, but it's a completely different model now. They're told how many people they can hire, they're gonna be given assignments of what they can do, they're gonna be given the trainings, they're gonna be giving all this stuff, right? They're gonna be given everything that they supposedly need to succeed. And they're gonna potentially make X amount of dollars per year.

Mo Hamoudi 14:48

Yeah, right? Yeah, as a business owner.

Karen Koehler 14:51

Right. Oh so my question hypothetically is how much does it should it cost someone to buy into a business that is going to generate supposedly a whole lot of income and and a whole entire business? Don't you think it should be considerable?

Mike Todd 15:13

Yeah, usually it is. I mean, like that's what happens when somebody becomes a partner in a firm, right?

Mo Hamoudi 15:17

Like they've got to be a considerable doesn't what it's well what you're describing, I that's called potentially the franchiser or franchisee model. Yeah. Where you pay a franchiser's fee, like uh seed money, and then you have to then capitalize the business investment, you know, like subway sandwiches or McDonald's. You get the right to use the label, you get the right to use, but you know, I don't know if that's a perfect fit because those are those are really real estate.

Karen Koehler 15:44

Yeah, but all I'm saying is if it's too good to be true, it's too good to be true.

Mo Hamoudi 15:50

Well, if it's too good to be true, it's too good to be true. I want to focus on Amazon, as Amazon is unloading risk.

Karen Koehler 15:57

Correct.

Amazon Logistics And Offloading Risk

Mo Hamoudi 15:57

That's what it's doing. It's unloading risk. And so I think that we're we're where liability or vicarious liability comes in, vicarious liability is a legal mechanism that says you can't always unload risk onto somebody else. You can only do it under very distinct circumstances. And if you still have a right to control the person you've unloaded the risk to by way of a contract, you're still on the hook because otherwise, people could contract away risk and create shells, and that harms the public.

Karen Koehler 16:33

So we put um in one of our cases, it's on our website, um, we put the complaint in that case, which was amazing. I loved that. I loved uh drafting that complaint. Um and I'm I think I come I think I drafted it with with um for Hod. It was very uh interesting to go figure stuff out. And the complaint, we did it mainly off internet and things, you know, where is Amazon and who and who, and we looked for CEO statements and what are their priorities, and our priority is to always be bigger and faster, and they're never satisfied. They always want to be bigger and faster and faster and faster. And that is built into the delivery model, the fastness, the speed, the amount, um, with human beings. But that complaint is um on the website under uh Bara versus um Amazon. And I have to say, at the end of the day, when we were done doing discovery um before that case resolved, we never needed to mend that complaint. I mean, what they do is not a secret. It is very controlled, it is highly tailored, it is very specific, it is very well thought out, it is they do have these entities that they try to shift the responsibility for when something goes wrong, which is going to go wrong when you're going that fast with that much of a burden. Because if you do not make all your deliveries, if you do not maximize, if you are not fast enough, because you're competing with everybody else, if you don't make these metrics work, then what happens?

Mo Hamoudi 18:11

You lose your job. Well, you can't. You're not being profitable. And so if you if you lose your assignments.

Mike Todd 18:17

No, that's what I mean. The people that are working for them lose the ability to do their job at that point. It's so whether or not you're saying they've lost their job, they aren't working anymore.

Mo Hamoudi 18:27

I think what like I mean, if you want to you got to look at I always started to look and see what the other side's position, rationalization for doing this. This is public information. This is their Amazon's leadership principles, customer obsession, focus on customers, work backward and build trust. These are just three of them that I think are relevant. Bias for action, value speed, recognizing that many decisions are reversible, two-way doors, and frugality, accomplish more with less, as contraints as constraints breed resourcefulness. These kind of concepts that are like what I call core company principles that drive the business. What they're thinking is like we gotta make m we gotta deliver a product to a customer as cheap as possible, and then we gotta make sure our shareholders are making as much money as possible. Now that's that's just corporate. You forgot one part of that. Which part?

Mike Todd 19:17

As fast as possible.

Mo Hamoudi 19:18

As fast as possible.

Mike Todd 19:19

Amazon tries to be the fastest delivery service in the whole world. Yeah, but but remember And that is what's causing those delivery drivers to go too fast and end up in accidents. Okay, I I'm hearing you. What I'm saying to you is that I think And I don't believe their corporate speak that says all this stuff. I think that that's what they put out in the public to make themselves look good.

Mo Hamoudi 19:39

No, but I think that they've made an economic decision.

Mike Todd 19:41

Of course they have. That's been their that has been what they've been doing since they started as a company.

Mo Hamoudi 19:46

I know it's good, but they made an economic decision to expose that risk, to create that risk. Is what I'm saying is that these are not naive people, these are some of the most smartest people in the world that are at the end of the day. I'm saying you don't run a you don't run a near trillion dollar wrong. I'm gonna say wrong on that one for sure. Okay, but we're talking about vicarious liability. All right.

Karen Koehler 20:10

This is a CLE. We have to be legal.

Mo Hamoudi 20:11

We are being legal. Okay. Facts matter.

Karen Koehler 20:13

Principles are we got this setup. Okay, we got this setup. People can tell. We feel very deeply about this. Now, what exactly happens? Let me just tell you about how this story works. First of all, you get Amazon Lawyer Group One. These are not the top of the lawyers list. These are like, I hate to say it, Mo believes in everybody's wonderful and it's all Amazon's fault. I do not I believe I do not believe that. I believe I believe you are a reflection of who you work for. Now, the first level of lawyer, I'm not saying that they're bad lawyers. I'm just saying that they are the lower-tiered lawyer, is the first round of lawyers that you're gonna face.

Mike Todd 20:57

And those are the lawyers for the DSP, right?

Karen Koehler 20:59

Well, no, you have to sue the DSP and Amazon.

Mike Todd 21:02

No, I know, but I mean which one's the first that you get? Are you doing the Amazon?

Discovery Stonewalling And Sanctions Strategy

Karen Koehler 21:06

The Amazon, just of the Amazon, even if it's flex, you know, the Amazon, and they're gonna not give you um what you need. You're gonna send out discovery, yeah, and they're not gonna give it to you. And they'll say, Well, Amazon didn't give it to me. And Mo will go, Oh my god, it's not your fault, it's Amazon's fault. And I'll go, it's their fault too. And we'll and he'll go into court and say, Yeah, it wasn't their fault. It was Amazon's fault. And I'm like, What are you doing? You gotta blame the lawyer too. And he goes, I don't want to. And I said, Okay, fine, don't. And then the judge gives them like $100,000 in sanctions because that um against Amazon. So there's that thing, right? Then that will be replaced.

Mo Hamoudi 21:45

Yeah.

Karen Koehler 21:45

Depending upon your the level of case. Then another law firm will come in and they'll say, Oh, yeah, that first law firm, they didn't really know what they were doing. They'll always throw them under the bus. This is like textbooks.

Mike Todd 21:57

Sort of a tactic, baby.

Karen Koehler 21:59

Oh, yeah. And then they then they pretend, oh yeah, well, we're gonna take care of this and we're gonna make things better. And then Moe's gonna go. The court and say they haven't given us stuff again. Um, but it's not these lawyers' fault either. It's Amazon's fault. And I'm gonna say it's totally these lawyers' fault.

Mo Hamoudi 22:14

Can I just say when I say that it's Amazon's fault? I just need you to know that before I came here, when I was at the Federal Public Defender, I tried one of the biggest data breach cases, and it was over three years and several week trial, and Amazon was involved in the case. I have like a ton of experience with working and understanding how the company operates.

Karen Koehler 22:36

I'm I'm using this facetiously because every time I'm telling people, like I always say, would you quit quit quit not blaming the lawyers? But he won't blame the lawyers, he blames Amazon, and he gets another hundred thousand.

Mo Hamoudi 22:46

Oh, you're saying it that way.

Karen Koehler 22:47

Yeah. Yes, I've been saying this this way. So that here's the difference between um practicing the way that it's very exhausting, is number one, is what I want to tell you. Like this is not easy. Um, because you have to look at their discovery and you have to see what they didn't give you. And and you have to follow up immediately, and you have to have 26 eye conferences. And in one of our cases, he had 33 26 eye conferences, right, with with Kristen.

Mo Hamoudi 23:18

Oh, 33, yeah.

Karen Koehler 23:19

33, 33 26 eye conferences. Now that resulted in like $180,000 in sanctions, and the judge was not happy with Amazon.

Mo Hamoudi 23:28

No.

Karen Koehler 23:29

But the amount of work, that's 33 of them. So it's not rocket science. You have to have, you have to go through, you have to ask for the right stuff. If you need a set of, you know, discovery. I think I don't know if that's on the internet, but we it's not, you know, privileged for us to give you just a discovery, but it's it's what you would think it is. Give us your policies, practices, and procedures. And we do dial down a little bit. We can't talk about all the details. Um, but it's that follow-through of relentlessness because what they're gonna do is ignore, evade, and just try to gloss over constantly.

Mo Hamoudi 24:08

Well, that's what's material because it's not a big deal. But but I mean, like, if you stand back and you watch like Amazon is very the I know you don't agree to that, they're very sophisticated in how they've designed a company. What they've done is they've created little like compartmentalized infrastructure within infrastructure apart from itself. So, like, the best example I can give is like before before 9-11, part of the reason that 9-11 happened is that agencies were not talking to each other. Amazon has done a very good job of isolating it, organizations within it. So then what they do is they send a lawyer, a defense lawyer, literally on a wild goose chase to try to find information because they don't have a structure in place to actually provide the documents. So this is what the 3326i conferences are for. A lot of this that we learned over the last current two years, two and a half years, we've been working on these cases. Oh, it's been a lot of institutional knowledge about really understanding.

Karen Koehler 25:12

Like we didn't even know who to sue initially. Yeah. Amazon, Amazon Logistics, the DSP, the driver, like, and then there's other entities within that. Like, and then you're thinking, okay, Amazon and Amazon Logistics, but there's not two Amazon lawyers. There's one Amazon lawyer. Yeah. Represents both. But there's two different entities. Like it is, it is a bureaucrat, they they make it complex because they're trying to hide stuff, obviously. Yeah. But let's talk about some. So other than getting these discovery requests out, yeah, which are very much based upon policies, procedures, you know, files, you know, who's in charge and you know, what where are all these documents, and then not getting them. Um, and then as soon as you do it once, then you know what you need to get, and then the next time it's easier and easier, and so on and so on. And you get narrow and narrow on what you don't know. And then what you don't know is very interesting.

Mo Hamoudi 26:05

A general case involving Amazon should produce 20 to 30,000 pages of documents. Okay.

Karen Koehler 26:13

Lots. So use use your uh use your search AI. Yeah, e-discovery. We use that.

Mo Hamoudi 26:22

You're gonna need to upload it there, you're gonna need to work with it. Yeah, you're gonna need to um really sit down and think about like the history. You you know, the one way to look at it is like big picture, like how did the death star begin? Like I always I compare Amazon to like, you know, they sold books. The Imperial are, you know, forces. Yeah. How did the Death Star begin and then where it is now? And then kind of go from the beginning and forward, and then drill down and find out how it got to that particular delivery service provider or flex person, and how did that relationship begin and and and bring it together?

Karen Koehler 27:00

So interestingly, there is a relationship between the DSP, the owner of the delivery service provider, and Amazon. And I can't remember if that's that's confidential or not. If it was you you're gonna have to get a protective order.

Mo Hamoudi 27:18

Uh and and so let me just say you can go online right now and go see what it's like to become a DSP, and uh and the requirements are written over.

Karen Koehler 27:26

Yeah, but that's all available on there. But what I'm saying is we have I have I, as a matter of principle, oppose all protective orders. And I lose always now. Like judges don't even seem to care. They just keep giving protective orders, but I don't care. I always say we're gonna go just go, you know, we're gonna fight them, and we always lose. Um, we try to keep them narrow and they're cumbersome and they're a pain in the butt. Um, so some things I can't remember, but and even if I could, I probably couldn't say it. The DSP provider does they are in an agreement with Amazon. There is a there's there's contractual agreements there.

Mo Hamoudi 28:09

Terms are confidential.

Karen Koehler 28:11

Let me just say this there are personal dynamics that happen that you can take advantage of in these cases, particularly with the DSP provider. If the D let's say that the DSP provider is involved in one of these crashes, or that they weren't fast enough, or as soon as they get in in in conflict, now you have someone that's gonna go and turn on Amazon. Amazon should have been smarter in one of our cases. They just they they didn't maintain that relationship, let's say. And let's just say that their the DSP provider like turned on them with fangs. That that was a perfect set set situation. Oh you want there to be confidence.

Mo Hamoudi 28:59

I want to dig in on what you're saying a little bit here, because what you're saying here is that we when when when we file a lawsuit, we have to sue the driver, we have to sue the delivery service provider, and this is the DSP model, and then we got to sue Amazon. Yeah, right? So, like you're suing three people, and you're saying all of you are at fault, and then the theory is join several.

Karen Koehler 29:17

Can you just say Well, you gotta sue Amazon and Amazon logistics.

Mo Hamoudi 29:20

Amazon logistic. You're saying joint and several was that real quick.

Karen Koehler 29:24

No, I mean everybody taking this is knows what that is.

Mo Hamoudi 29:27

Knows what that is, okay. And then so effectively, you're they're gonna try to blame each other.

Karen Koehler 29:33

And so remember what they're saying to the public is No, they're not, they're gonna try not to blame each other, but your job is to make them blame each other.

Mo Hamoudi 29:41

All right. So your job is to make blame each other.

Karen Koehler 29:43

They're they're they're gonna try to stay in cahoots with one another, and you need to fracture that.

Turning Drivers And DSPs Against Amazon

Mo Hamoudi 29:48

Now listen, stay cahoots, stay cahoots, okay? Just keep I like that word cahoots. Let's let's put a pen in cahoots and put it up here. Cahoots, and then and then now they're telling the public on the public that this is an independent thing, right? This guy's an independent. Why is an independent and another independent than cahoots?

Karen Koehler 30:08

Well, let me tell you also, here is their here is here is their real weak spot.

Mo Hamoudi 30:14

Yeah.

Karen Koehler 30:14

Regardless if it's a DSP or only the driver, a flex program driver, right? Yeah, regardless, the driver is the easiest person to have poor feelings against Amazon. First of all, they were working for Amazon, yeah, which treats people like crap. I mean, we went to we went to Amazon, we put on the vests, you know, they made us, you know, the oh my god, the people that show up, like you're escorted through the facility like you are either a criminal or royalty, they're not sure which. And it's a huge posse of people, and you cannot deviate from the line, and you have to, you know, only you know, do not take a picture of that box over there. Yeah. That box is off limits. Um, and you're gonna go to, you know, the places that you need to go see, which we wanted to see where the DSPs were set up, where the vans were parked, how the delivery system is, you know, how where people were packing the carts. We wanted to see that. We want to see the education rooms, okay? We want to see the training rooms, we want to see everything. They're like, why do you need to be in here? And Moe's like taking pictures of everything.

Mo Hamoudi 31:24

Yeah. Um you know what it reminded me of when I was in there? Have you ever seen Willy Wonka's Chocolate Factory? It was like But not as fun. But not as fun.

Karen Koehler 31:32

No, there was like, but it was like it was all brown boxes. No, they had like images. There was like images and say everything like it's protected.

Mo Hamoudi 31:41

No, that's that's that's not protected. They're pictures of this. But it's like uh, remember, it's like, but I felt like it was like it was like I was being marshalled and I had to stay in the particular lane, you know, like in Willy Walker. And then Willie Wonka says, You can't go but when you can't go into the room.

Karen Koehler 31:58

But don't get distracted.

Mo Hamoudi 31:59

I know, sorry, I got distracted.

Karen Koehler 32:00

So that's kind of like so the driver has been done wrong. They will, they they so here's the problem for Amazon. Yeah, they're gonna always throw that driver under the bus because their whole thing is that well, we're not their employer. We're not their employer. So most likely that person's gonna have been terminated, almost always. Um and they will have and and they are not gonna have fun stories to talk about working for Amazon. The stories were gonna be the same. I had to I could not take lunch, I could not take breaks, I had to follow this app, I didn't know where I was going. Yeah, oh yeah, yeah, poop in someone's yard. I mean, yes. So it's never gonna be good. I if I didn't have enough boxes, then I would not get enough the next time I was really struggling, you know, blah, blah, blah, blah, blah, blah, blah, blah, blah, blah, blah, blah, blah. Um, and these are often people that are working other jobs too. So that because they it's and it's their own fault, because they treat the drivers like crap, or they assign someone else to treat the driver like crap, even though the driver is doing work for Amazon, the driver will turn on Amazon. So know where those points are in your case, who's gonna turn on who? Because it's not a love relationship that's keeping all these Amazon factions together. It's not a love relationship.

Mo Hamoudi 33:29

Which uh uh, you know, you the low-wage worker economy is an economy that is exploited across multiple industries. But you don't need to take our word for it. There are you can go look up national labor relations board complaints of attempts by Amazon workers to try to unionize, you know, like Starbucks, and and how the company um fights that, right? And so really, you know, the this is this is there's that that's this is that that's the angle, like there's a deeper angle.

Karen Koehler 34:02

You want to take the deposition of that of that person. You know, normally in a car crash case, you want to take the deposition of the defendant as fast as you can. You don't really want to do that here.

Mike Todd 34:11

Give them some time.

Wait On The Driver Deposition

Karen Koehler 34:12

You want to get the file, you want to get any documents you can find, you want to figure out, you know, as fast as you can. They're gonna have cameras, they're gonna have the app. You want to get the app, and you don't want to just get the app. Mo got an order allowing us to have an expert take apart the app.

Mo Hamoudi 34:31

Yeah. Yeah.

Karen Koehler 34:33

Do you know, do you know how much they fought that?

Mo Hamoudi 34:35

They fought. I'm sure they fought it as long as they could. Because like there's one of the things that the like this is what's And why could we take apart the app?

Karen Koehler 34:43

Because our allegation is these people are ruled by the app. It's like, you know, it's like, you know, futuristic stuff. And they're they're watching the app. If you know, I'm sure that Amazon would rather implant the app into people's brains, but this is as close as they can make it. So, and they have this Nitrodyne, they have all these other systems. There's a system that runs the app, there's a system that runs the camera. All these different parts and pieces go together, and you need to get them before you depose the driver. Do not drive depose the driver until you get all the different pieces that you need.

Mo Hamoudi 35:16

The this idea about technology is like a layer of this that institutionally we've been able to learn a lot about because when you just are exposed to so many cases and you're working in the depths and the information, understanding datification of the employee. Like the employees are data points, they're not human beings. What you start to learn is that they've become it's like the matrix.

Karen Koehler 35:44

You know, it's literally like tell them, tell, tell, tell people about taking the deposition of the trainer. So we were getting ready, we really wanted to try this case, and I kept saying, okay, well, the first witness has to be the worst, the worst of the Amazon witnesses, of which there were numbers of Amazon witnesses.

Mo Hamoudi 36:01

Yeah.

Karen Koehler 36:01

Who's gonna who's the absolute worst witness that could testify?

Mo Hamoudi 36:06

Person who trains, you know.

Karen Koehler 36:07

And what happened in this case? Tell them the test results.

Mo Hamoudi 36:10

There were that that they failed.

Karen Koehler 36:12

Well, you gotta be more specific.

Mo Hamoudi 36:14

Well, I can't be more specific.

Karen Koehler 36:15

Okay, I can be more specific. Yeah. So, for example, there were like 11 Oh, I see what you mean. Yeah, there were three days of There were three days of testing. Day number one is to take some written stuff. He passed it like by one point. Day number two, more written part. Day number three was the driving part where you have to navigate in a parking lot, you know, through the cones, and I think it was a scale of one to eleven or one to nine. No, one to twelve or one to eleven. Something like that. And had failed all but three.

Mo Hamoudi 36:47

Yeah.

Karen Koehler 36:49

Now there was no training and retaking of the tests. There was just like, well, good enough.

Mo Hamoudi 36:54

Yeah. Yeah.

Karen Koehler 36:55

I mean that was gonna be our first witness because that was literally the standard. It was good enough. They powered, they just moved them forward. The the we'd focus group this, we knew people would be mad. It's the details that matter. And when you look at the details, they have all the systems in place that no matter all of the systems involved, the systems have to mesh to humanity. And they don't. Humans cannot function the way that they want them to for that level. When Amazon needs drivers, they want drivers. They're gonna get those drivers, even if they miss almost all of the tests, the driving tests, they're gonna still get them. Maybe, maybe sometimes that change, maybe, maybe some of it's changed since we even had the case. I don't know, but it was shocking.

Mo Hamoudi 37:41

Well, yeah, uh, so uh when you the right to control test speaks to this. It says that one of the things that gives you a right to control is if you train, even though if you're mighty legal.

Cracking The App And Camera Data

Karen Koehler 37:52

So quickly in case there's anybody here that's that that because we're this is a podcast, it's not a lawyer. Yeah. Um, so vicarious liability is a legal concept that says no matter what you call someone, an agent, an employee, an independent contractor, a volunteer, or whatever you're trying to call them, you need to look at what is the actual relationship and what are the elements of vicarious liability?

Mo Hamoudi 38:17

The elements is gotta look it up. I gotta look it up. Yeah, look it up.

Karen Koehler 38:21

The primary one is control. Yeah, it's and the control has to and what what are the elements of control? And so it goes through that. He'll look it up. But for example, our elements in Amazon cases are can you just show up when you want to? No. Can you just load whatever boxes? Can you choose your customers? No. You have to for an Amazon branded van, you're gonna wear that van. I mean, you're gonna wear that, you're gonna wear the the clothes, the hat, the vest, you're gonna use the van. You're gonna use, you're gonna be given a pouch with your stuff, the phone, the charger, anything else that they that's Amazon that you, and that's you're gonna put it up there on the console, and that's gonna be your app, and you're gonna follow it, and it's gonna tell you here's customer one, two, three, and it's gonna take you to there. You're gonna get your boxes loaded by Amazon in the order that Amazon wants them delivered by the Amazon people, and then you're gonna leave, and then you're gonna be monitored by the app, by the all the the system in the in the van that has all the internal and external camera systems and recordings. They're gonna be looking at your mileage and how you drive. If you make a sudden stop, they're going to report that. Um uh, it goes on to your file of you had you know so many incidents of you stopped too fast or you know, you you went over a yellow line, or it's it's just like you're driving the survey a vehicle that's surveilling not just outside, but you. Um and and they're gonna say that they can't get that stuff. They're gonna say that they can't get it in discovery. Well, Netrodyne's a whole different company. Well, this app company, yeah, no, it's it's a different amount app now. It's not called Rabbit. Now it's called something else. You know, it's they're constantly renaming and re-revising and redoing it and saying that they it's it's too hard. They can't find it. Well, yes, they can find it when a court orders them to do that.

Mo Hamoudi 40:27

Yeah, so the it's the restatement of tort section 220, that lays out the factors. There's multitude of factors. And just give us the bottom, the basics for people that are not lawyers that are listening to the basics are the extent of control which by the agreement the master may exercise over the details of the work, whether or not the one employed is engaged in a distinct occupation, the kind of occupation with reference to whether in the locality the work is usually done under the direction of the employer or by a specialist without supervision, the skill required in the particular occupation, whether the employer or the workman supplies the instrumentalities, tools, and the place of work for the person doing the work, the length of time for which the person is employed, method of payment, whether by the time or by the job, whether or not the work is part of the regular business of the employer, whether or not the parties believe they're creating the relation of master and servant, and whether the principal is or is not in business. So these are the factors that you have to look to.

Karen Koehler 41:23

There's some of them. Some of them we can get more dialed down and more specific.

Mo Hamoudi 41:28

More dialed down, but they drive the inquiries. Like one thing I would look at is training, tools, uh control over like where you are.

Karen Koehler 41:36

They train them. You have to go through Amazon School, yeah, via Flex Driver, I mean, to be a DSP. That you know, where where are they located?

Mo Hamoudi 41:45

Yeah.

Karen Koehler 41:45

The DSP is located inside of Amazon warehouse. I mean, they have a mailing box address. I remember looking up, like, where's this DSP located? I was like, oh, here's the address. And then I went to go find out what that building was, and it was a post office box. I mean, it was a postal. It didn't say post office box, it was just an address inside of a post office building. Um, because yeah. So you have to just look at these things to see is this what kind of relationship is this?

Training Failures That Prove Control

Mo Hamoudi 42:18

And then the so we've talked about last mile. I want to speak briefly about middle mile. Middle mile is the long haul drivers, which is the trucks, because done a couple of those cases. And they have to go get the trucks that come off the ships or the freight or whatever, and then you have long-haul truck drivers attack grab the freight and haul it to a particular location, which is then by last mile, the van or the guy, they're distributed to the customers. That model is just similar, is that you know, people go onto a system, and this is the middle mile system, they go onto a relay system and can hop on and say, Oh, I'll go pick up a freight, I'll take this freight, and there's a relationship, same structure. You're an independent hauler, you're just carrying my freight, and they do the same thing. So it's the same model, Mike.

Vicarious Liability Factors That Win

Karen Koehler 43:05

So I want to like talk a little bit about the extraordinary level of nastiness involved in this litigation. Um, and they so you're dealing by the time you're done, because they don't really fire that first law firm, they're still there. And then they got a second law firm involved, and then you got the DSP law firm. Like there's a lot of lawyers involved, and they will take depositions of like all the lay witnesses. They they are it is intense. And um, meanwhile, you're trying to get the liability. What we do here is um well, several things. Number one is we start going as hard as we can on damages as they are going on liability. And so, for example, I start taking because a lot of times they get so distracted on trying to prevent us from getting vicarious liability that they don't do enough of a workup on damages, or they send out the most Junior attorneys to take damages depositions. Um, I was uh Steve Fogg typically shows up later on in these cases. I'm like, why, why are you why are you doing this to me? And he just smiles. He's like, Yeah, why are you taking these depositions? And I'm like, because I'm gonna kick your butt in trial. Um, but I have been taking, starting to take the treating doctor's depositions because they don't do it. Like, I'm gonna do it. I'm gonna take them. I'm gonna start taking the treating doctor's depositions. And so we are going mad. We are going mad and fast as heck in these cases, just liability damages, everything is going full stop litigation with the team of lawyers that we have have here in the law firm, which, you know, I can name all of them that are involved in these cases, but it's we're just big teams. It still doesn't account for the level of cruelty and meanness and nastiness that we have in we have experienced here. And I want to tell just tell one story about a client who survived, um, and he was ended up being fused. He did have a pre-existing condition uh that didn't cause the need for the fusion, but he was fused from C2 in his spine, so cervical vertebrae number two, down to T2. So it was a seven-level fusion. Basically, almost half of his spine was fused. This is pretty objective. Like you can see the scar, you have an x-ray, you can see the rods in his spine. Um, you can see if you meet him that he can't, he can't literally do anything other than, you know, move his whole body when he turns his head. They wanted him to go see a medical examiner. Okay, fine, go waste your time, right? Go go for it, go for it. So it turns out that it's on Martin Luther King Jr. Day. We agreed to it because honestly, there was a little mix-up during the first schedule, the paralegal that was supposed to accompany him from another office, just fell asleep and missed it. So we were trying to accommodate it, and it turned out to be on Martin Luther King Jr. Day. Our client was from Ethiopia, and so is a paralegal. And we had already gotten into it with the lawyer, one of the lawyers from Steve's office. Um, I'd gotten into it with her many times, and we had finally gotten into it with her because she was demanding that we do stuff on Martin Luther King Jr. Day. And um we said, we are not going to be working. We um expect you not to go filing motions that require us to have answers due on that day. And um we expect you to respect the fact that we are members of the BIPOP community and you are um being very offensive. So on Martin Luther King Jr. Day, Mo is coaching his son, 10 10 years old, at the MLK tournament.

Mo Hamoudi 47:09

Yeah.

Karen Koehler 47:09

And what happens?

Mo Hamoudi 47:10

I get a call that uh that uh did you during the examination that uh clients being followed by uh somebody, and so I say, um and who do they think it might be? And how did they know they were like how because he was doing a terrible job of tailing them? And the second thing was is that they thought it was ice because they're both Ethiopian, yeah, Somali.

Karen Koehler 47:34

And well, I'm sorry, Somalian. And and and our client wears a very traditional garb.

Mo Hamoudi 47:40

Yeah. And so um, what was uh you know? And so I said, like, do you feel safe? And then I was like, if you feel safe, pull over at a stop and take pictures of the place, and I'll go find out who it is. And so he goes and uh stops at a uh you know strip mall, walks up, um, the car's parked, he doesn't still doing a terrible job of being a tail. Um, walks up to go take a picture, and then the guy gives him, you know, the universal language of fix them off. Yeah.

Karen Koehler 48:12

And um our guy actually got a photograph of it. So long story short, we got a judge order. Hired a PI to find out who this guy was. Turns out he was a PI from Oregon. Now we didn't, we we wanted, then we did what this is like on Monday. On Tuesday or Monday night, no, Tuesday, we we tell the defense this happens and we want to depose this guy. And by the way, and we send them the pictures of him flicking our flipping our clients off. And they are pretty embarrassed that we caught him, and he shows up for deposition. Okay. Now, what do we learn in deposition?

Mo Hamoudi 48:57

Mike, what did we learn?

Karen Koehler 48:59

Uh well, we learned how many PIs were there that were tailing this guy?

Mike Todd 49:03

There were two guys.

Karen Koehler 49:04

No, there were four total.

Mike Todd 49:05

Well, there were there were four. Yes.

Karen Koehler 49:07

Four total PIs had been.

Mike Todd 49:09

I mean two that were there when he came.

Karen Koehler 49:11

Two at a time.

Mike Todd 49:12

Yeah.

Karen Koehler 49:14

And they they were trying, they couldn't get him, they couldn't find him because honestly, all he did was be in his apartment or go to the mosque. So they were trying, so they knew that he was gonna go to the exam and they tailed him there and they tailed him back, and they had taken a bunch of pictures of him like talking to people. They'd followed him into restaurants, they were trying to overhear conversations, but they didn't have their mics on.

Middle Mile Parallels And Long Haul Risk

Mo Hamoudi 49:37

Amateur hour. Yeah, beyond amateur. Beyond amateur hour. I mean, it's one of the most What did the court order say? The court order said you have to basically the court said that you're prohibited from using this guy, and you can't do it on holidays like this.

Karen Koehler 49:55

They said, Yeah, they said that they cannot, they cannot ever, ever um uh schedule anything again on a holiday um that in uh involves the BIPUP community, as we complained about. And they told them that they could not um use that PI again.

Mo Hamoudi 50:16

Yeah.

Karen Koehler 50:16

And I thought that they said that they could not tail our client again.

Mo Hamoudi 50:19

I don't know if it went that far. I don't remember the order went that far. But that's the the court was concerned about what happened because you know, this guy was like, I don't know, it was like the Penny Hill show.

Karen Koehler 50:30

And who asked for this? Who asked for this tailing?

Mo Hamoudi 50:33

Amazon did.

Karen Koehler 50:33

Yeah.

Mo Hamoudi 50:34

Yeah. Uh I do want to say, like, one of the things is that we get cases that come to us that This is by the way, this is ridiculous.

Karen Koehler 50:41

This was this is so mean. This guy, like I said, fused from C2 to T2, undisputed.

Mo Hamoudi 50:50

Yeah, yeah. One of the things is we get cases that come to us and we triage the case, but we are moving cases, I averaged it out, from bringing in to ending the case 10 and a half months.

Karen Koehler 51:02

They get really, they got really, really, they get really mad. They keep asking the court for continuances. On the other hand, they don't really want to keep working with us. And so I I think that is our number one recommendation. This is ruthless litigation with Amazon. I mean, it's if you aren't getting sanctions, um, if you are not having multiple CR26Is, then you're just not getting everything. Um, because they are they are, in our experience so far, we have not we have yet to have a case where they have given us what they should have.

Litigation Nastiness And Building Damages

Mo Hamoudi 51:33

Yeah. Um it's 1252. Is there any questions?

Karen Koehler 51:37

Oh, yeah, questions. Well, you can look while you're looking, we'll just keep talking.

Kassie Slugic 51:54

I don't see any new questions in the chat.

Mo Hamoudi 51:57

Okay. Okay, good. All right. Well, that's good. That means we did a good job.

Mike Todd 52:00

Um somebody did ask how much they pay to become a DSP.

Karen Koehler 52:06

Oh yeah. Well, it's you can find the ads. It's it's it's it's surprisingly little.

Mo Hamoudi 52:13

Yeah.

Karen Koehler 52:13

I actually I can say that we asked our economic expert, what are the what are the chances in the real world of paying that much down to become a business and then being and then having them basically give you every single thing that you need for that business, um, every single thing. And then um they don't guarantee you money, but they have the ability, it's you're gonna make it if they give you the assignments. And he said, This is not in the real world. That's what the economist said. Like, this is not, this is it's subsidized. It's this is subsidized.

Mo Hamoudi 52:52

It's under, if you go to logisticsamazon.com, it says that annual profit potential of 100,000 to 400,000, startup costs as low as 10,000. There you go. And and so, and then there's an asterisk. It says startup costs based on first five vehicles and may vary by location. Modeled revenue and profit range is supported by past performance of DSPs operating for 12 months as reported in Amazon's financial reviews and is not a guarantee of earnings. Actual results may vary based on location and owner.

Karen Koehler 53:23

Yeah, we were very interested in the fact that how do you start a business for $10,000 and make $100 to $400 the first year?

Mo Hamoudi 53:32

I mean, that's a really attractive model. I mean, if you think about it, right?

Mike Todd 53:36

It's a very attractive model if you if it actually works that way.

Mo Hamoudi 53:40

But you know, but it uh I'll tell you, don't remember, I mean, yeah, we are getting cases, but we're not getting cases from every DSP. So, and Amazon's making money. That means that DSPs are making money. So there are DSPs out there that are making that money, is what I'm saying. Otherwise, the system would fail. The system is not failing, it is thriving.

PI Surveillance Story And Court Blowback

Karen Koehler 54:01

Well, I am I'm a local counsel on a case um for an attorney from South, I can't remember. Tried one of these and got a large verdict back there and is has this case over um here. And they are they are filing summary judgment motions. Amazon filed the summary judgment motion on vicarious liability. And I'm uh yes. So we're probably gonna have to look at it and make sure that that doesn't, you know, see what that see what's going on. Because, you know, when you're a local council, you kind of sit back and consult a little bit, but you don't really tell people what to do, you just let them do it, which is what I've been doing. You know, yes, you need, you know, for 4,200 words for a summary judgment motion. That's your word limit. You know, I do stuff like that. Um so I'll probably need to pay attention and look at see what that motion actually says. Because I I don't know that they, I mean, they cannot keep maybe they can. They can they can afford anything that they want to. So they can afford to litigate these claims and decide if they want someone to go to trial or not um by whether they resolve it or not. I would personally like to go to trial um on one of these cases. Um, but this one, this one, they've moved for semi-judgment on vicarious liability.

Mo Hamoudi 55:29

Interesting. Let's see what happens. Um, well, uh, I think the moral of the story is is that what?

Karen Koehler 55:36

Oh my god, sue Amazon.

Mo Hamoudi 55:38

Yeah, continue to sue Amazon.

Karen Koehler 55:40

Do you not believe them when they say there's a million-dollar policy limit?

Mo Hamoudi 55:43

Test their economic model. And if we don't have any other questions, do we?

Karen Koehler 55:47

Nope.

Mo Hamoudi 55:48

Nope.

Mike Todd 55:49

Oh, wait.

Mo Hamoudi 55:50

Oh.

Mike Todd 55:51

Um, let's see.

Mo Hamoudi 55:54

In the DSP model, are you leasing the trucks from Amazon?

Karen Koehler 55:57

Yep.

Mo Hamoudi 55:57

Well, that's a really good question. There are a couple of ways to get the trucks. One is a lease, and one is through a holding company.

Karen Koehler 56:04

Yeah.

Mo Hamoudi 56:04

Kind of like rental cars.

Mike Todd 56:06

And then uh, what experts generally are you using to establish the elements of their business model?

Mo Hamoudi 56:12

Uh, I don't use experts, I use their own witnesses. I use their own employees and I use their own, I use their own their own stuff against them.

Karen Koehler 56:22

30b6 is your friend.

Mo Hamoudi 56:24

Yeah, but you know, there's a there's a there's a I would say there's an art to the 30b6 approach with Amazon, which would take another hour to talk about it, but I wouldn't just start with a 30b6.

Karen Koehler 56:35

Yeah, he was actually telling me the other day that he hated the 30b6 model.

Mo Hamoudi 56:39

I mean, the 30b6 is like, let me go to train a guy to tell him what to say. Here's my puppet. I don't want to deal with that guy. I like to see, you know, I would like to get down and dirty.

Karen Koehler 56:50

I like the puppet guy in trial, but in discovery, when you're actually trying to get stuff, the puppet guy is irritating.

Mo Hamoudi 56:57

Yes.

Karen Koehler 56:58

But you can do both. You can you can have you want the puppet guy. Yes, and hopefully a really bad puppet. Yes, and typically a lawyer that will only be lawyer-like.

Mo Hamoudi 57:08

Yes.

Karen Koehler 57:08

But yeah, it's getting the getting the people.

Mo Hamoudi 57:11

Yeah, yeah, yeah. Getting the people.

Karen Koehler 57:13

You want the trainers.

Mo Hamoudi 57:14

Yeah.

Karen Koehler 57:17

And you want the finances, you guys. You gotta get the finances.

Mo Hamoudi 57:20

Yeah.

Karen Koehler 57:21

You want to know what and you know, everything between Amazon and the DSP. Yeah. Everything. Not just like a folder, everything. All right.

Mo Hamoudi 57:35

Well, we got a couple minutes left. Well, what I think is that are you gonna wear that all day long? I I like it. I think I think the color is becoming. It's it's it's raining outside. It's kind of giving me like my vitamin D.

Mike Todd 57:47

I think it's good to make sure that defense counsel can see you clearly.

Mo Hamoudi 57:50

I know. And by the way, I'm an incredible inspector. I gotta tell you, one of these warehouses, yeah, I could go get a job inspecting warehouses as like a career after that. They are very clean, they're incredibly clean.

Karen Koehler 58:03

I mean, they have must have cleaner, cleaner robots because I'm a clean freak and I had no complaint.

Mo Hamoudi 58:09

Oh, but by the way, the the the snacks.

Karen Koehler 58:12

Oh, yeah. They have they have the break room. The break room is as big as this whole office. It is empty, of course, because who has time to have a break?

Mike Todd 58:22

It's not working.

Karen Koehler 58:23

I mean, my favorite part was this was like, I'm like, is anybody ever in this room? Because there's so much there's so much, and they have like, oh my god, they have like foosball tables, they have the special nerds, the one, the gummy nerds. Yeah, hello.

Q&A On DSP Costs And Key Witnesses

Mo Hamoudi 58:38

I mean, but you gotta pay for it. It's not free, you gotta pay for it.

Karen Koehler 58:41

You gotta pay for everything. I know.

Mike Todd 58:44

Okay, okay. Oh, wait, somebody asked one last question. Can you share discovery requests with us motions?

Karen Koehler 58:51

The answer is we can share, you mean the actual summer the the discovery request? Yes, we will put together a basic discovery request.

Mo Hamoudi 59:01

We can do that. We can do that.

Karen Koehler 59:02

Yeah, okay. Just uh email Cassie and she will we'll give it to her and she can send it to anybody that asks for it. Okay.

Kassie Slugic 59:10

Okay, thank you so much, well, Karen and Mike. That was a great presentation. Please make sure to fill out the poll so I can get you attendance or credit for attendance. Thanks, everyone. Have a good day.

Mo Hamoudi 59:22

Thank you.

Kassie Slugic 59:23

Bye.