LFA: Mike, thanks for taking the time to meet with me.

Mike: Hey, no problem.

LFA: My first question is how you first got into the mistrial specialty.

Mike: Good question. I guess the whole thing started about four years ago, in the middle of a normal trial — it was a bad check case. I was still a pretty young lawyer. I was working on my own, and had only had one case before. I had sued Home Depot because the toaster I got there didn’t work as fast as I wanted.

LFA: So you mostly tried civil cases?

Recent Mistrial

Mike: Actually, in the toaster case, I only raised constitutional issues. Anyway, I needed some more business, so I had the court add me to the court-appointed list for criminal defense. Which sucks, because, you know, because everyone who is charged with a crime is guilty.

LFA: Well, not everyone –

Mike: It’s everyone. So there I was, in my first criminal case, sitting in court with the proceeding about to start, and my client is this lady trying to tell me her side of the story or something. I was like, I only met you three minutes ago, so stop trying to talk to me, all right? You don’t know me. I may be your lawyer, but that doesn’t mean you can just talk to me whenever you want. Leave me alone, okay? She didn’t seem to like that, but then thankfully the trial started.

LFA: What defense had you prepared?

Mike: Well, I thought I might argue that my client wasn’t actually forging checks, but was planning on changing her name and was doing test-runs on signing and cashing checks with different names just to try them out. I mean, everyone’s done that before, right?

LFA: I haven’t.

Mike: You must be one of the lucky few people in the world who like their name, then.

LFA: I guess so.

Mike: Suddenly, it’s my turn for an opening statement, and I hadn’t had time to write one because I had been very stumped that day on the morning Sudoku. So I get up there, and I take a look at my client, and I think, this lady probably abuses her kids. It was one of those things you could tell just by looking at her. Now, I didn’t even know if she had kids or not — like I said, I hadn’t even talked to her yet — but I was pretty sure that she was a child abuser. I can be very perceptive like that.

LFA: That sounds like quite a talent.

Mike: It can also be a curse, but that’s a story for another day. So I walk up to the jury, and my brain is firing on all cylinders, like, ping ping ping! And I say, “Ladies and gentlemen of the jury, my client clearly abuses her children, but she might not write bad checks.” And, boom, just like that, I won a mistrial.

LFA: Just like that?

Mike: Just like that. I had no idea it could be so easy.

LFA: I see.

Mike: I mean, I didn’t even know what a mistrial was. This is funny — I turned to the prosecutor, and I was like, “Did I just lose?” And he was like, “No, you idiot, it’s a mistrial.” And I was like, “I’ve never not lost before! This is so cool!”

LFA: So at what point did you feel like you really perfected the mistrial?

Mike: It didn’t take long. My next trial… oh yeah, I was defending someone accused of killing a puppy. One of the jurors was being a huge wussy about it during cross-examination. So I did my baby voice and was like, “Awww? What’s the matter? Are you going to cry? Is Juror No. 3 going to cry about the little dead puppy? Waaaahhh! Waaah!” You guessed – another mistrial, and another checkmark not in the loss column. I was on a roll.

LFA: What have been some of your favorite mistrials?

Mike: Gosh, I’ve had so many. There was that time I had the local high school band sit in the visitors section and play “1812 Overture” during my closing argument. There was that time I called a mental patient to the stand, and he took off his coat and had dynamite strapped to himself, and he demanded my client be found not guilty or he would blow up the whole courtroom. My client wasn’t found not guilty, of course, but there was a mistrial, so it was close enough. I could go on and on.

LFA: Incredible.

Mike: Thanks. Mistrials… that’s just what I do.

LFA: So, what’s next for you, Mike?

Mike: Well, this year I’ll be teaching the nation’s first Mistrial Clinic at Phoenix Law School. I’ll also be working on a full caseload — including my own, which is exciting.

LFA: Your own?

Mike: That’s right! I’ve got an upcoming trial in front of the State Bar to determine my fitness for continued practice. You can bet I’m cooking up something pretty special for that one.

LFA: Thanks for your time, Mike.

Mike: Anytime.

Actual Boat

“This is the first case of its kind,” said Thomas Wenlock, a professor of civil procedure at Duke Law.  “A lot of things have to get hammered out. Where was the boat at the time of the incident? Which law controls? And which personality was Lorraine Eydars when she was driving the boat and wrecked it?”

Ruport, acting with caution, initially directed the parties to file briefs establishing that they are actually diverse. Both Yarp and Whetner submitted affidavits from Eydars stating that she is only Yarp when in Andover and only Whetner when she crosses over into Espyville — so, in effect, each personality has residence in different states. Simple enough, but things got even more complicated when Whetner filed a cross-claim against William Feck as a third-party defendant. Feck is another of Eydars’ personalities residing in Ripley, N.Y.

“Although Feck was not in the boat at the time of the accident,” said Whetner’s brief, “he was the individual who purchased and registered the boat. His negligent failure to maintain the boat in satisfactory condition was a large factor in the incident.” Feck has yet to respond, as his personality has not surfaced within Eydars for months.

All three personalities have retained separate lawyers in the litigation. The attorneys report that extra precautions must be taken to ensure lawyer-client privilege at all times.

“You have to be careful,” said Lucas Thompsen, attorney for Yarp. “You want to make sure you’re talking to your client, and not another personality pretending to be your client.”

Ruport appears to be satisfied with the diversity requirements, having already set a discovery schedule. The current list of expected witnesses has soared to 39, every single one of which is a different personality within Ms. Eydars.

“I saw the whole thing, and Ms. Yarp is clearly at fault,” said eyewitness Ralph Henneson.

“That’s a load of horse-paw! I saw it all, and that Whetner lady done wrecked the whole darn ship!” said Ike “Rat Hat” Barnaby, moments later.

Ruport is expected to rule this week on a motion for interpleader by Wendy Roppel, an Eydars personality who says she was an innocent bystander injured in the wreck.

Gavel Bang in action

Initially, the Urban Law Journal functioned like most other law journals, choosing its editors through a rigorous tryout, complete with Bluebook exercises and interviews. With time, however, the character of the journal has taken a more unconventional turn, emphasizing what has been called “street editing” and students’ “underground” cite-checking skills.

This has resulted in the newest innovative practice at the journal: Selection of new editors through what is called “cite-checking battles.” Those vying to join the journal’s editing staff match up one-on-one against one another, taking stage for improvisational cite-checking before an audience and putting their source-verifying abilities to the test through intense, often entertaining, contests. Often held late at night in abandoned buildings in the city’s Fifth Ward, these cite-checking battles earn victors places on the journal’s editing board, but, more importantly, immense respect from their peers.

“No editors out there can cite-check like me,” boasted “J-Scales,” who was recently given an offer to join the journal’s editorial board. “Some editor brings a weak Supreme Court case-cite, I hit back with the text of a municipal ordinance in Toledo, Ohio, in 1926. Some editor steps up with a United Nations resolution, I explode out of nowhere with an unreported decision of an administrative judge for the Mine Safety Commission. My boys are like, ‘Damn, J!’ Where you come up with these cites?’”

On a recent Saturday night, the journal held its fall competition in an empty warehouse in the city’s Beechnut neighborhood. After an hour of an amateur tournament, the final battle was set: “Gavel Bang” versus “Erroneous P.” Gavel Bang began with a string of intimidating cites:

“Yo, yo, e.g., Frank W. Lutherson, Annotation / The Writ of Habeus Corpus in Capital Espionage Cases 82 A.L.R. Fed. 286 (1964) / full docket number available in slip opinion, b*tches / United States v. Oliphant, 373 F.5d 923 (2nd Cir. 1849) / cert. granted 282 U.S. 932 (1853) / (No. 822, 1853 Term; renumbered No. 82-5, 1854 Term) / substantive information, use parentheticals, as needed, explain relevance, yo, yo / see generally Kevin Wrung, Xenophobia and Its Affect on Patent Regulation, 284 U. Roch. L. Rev. 82 (1835) / (describing trends in the visa application process as in relation to copyright procedures) / ordinary jurisdiction, courts of appeal in civil matters!”

Gavel Bang then slammed down his microphone, poured a bottle of Ye Olde British malt liquor over his head, and raises his hands in triumph. As the crowd exploded in cheers and riotous whooping, Erroneous P launched into a cite-check of his own:

“That’s right, muthaf*ckas, get ready, get ready / different case name on appeal / yo, parties names are reversed / Harold v. Charleston Street Vendors Ass’n, 923 N.L.R.B. 283 / enforced 495 F.8d 2843 (4th Cir. 1830) / denial of certiorari or rehearing / appeal of administrative action / what what? that’s right! promulgation year / abbreviate subdivisions, article, clause / Mixura Li art. 38, Sec. 8 (1859) (D.R.C.) / typeface, Internet source, unavailable in print medium / opinion available only on Internet / Lorton v. Kansas, No. 38-22576, slip op. at 9 (U.S. Jan. 24, 2006) / http://www.kscourts.org/opinions/06pdf/38-22576 / cite statutes, session laws, regulations / use jurisdiction parenthetically if not clear from context!”

Erroneous P then tore his shirt off and leaped into the audience, which, boisterously clamoring in approval, hoisted him up while he displayed various footnoted tattoos on his back. Gavel Bang attempted to keep his assault going, citing single editions with publisher and date, but that proved too simplistic for the mobs of journal editors in attendance, who quickly shouted him down with a chorus of jeers, sending him running from the stage in a barrage of empty Red Bull cans.

“Gavel Bang, he got things going. Ripped it for a while,” said “Mandamus Maximus,” an articles editor at the journal who judged the competition. “But trying to come back with a single edition? That sh*t is whack. Totally amateur.” With minimal deliberation, the board voted to offer Erroneous P an editorial position.

“I know my federal jurisdiction, no doubt,” said Erroneous P after the match. “No one can match me when it comes to constitutional courts or criminal matters. I’ll spit appeals without even thinking about it.”

While the technique has yet to spread outside of the Houston Urban Law Journal, other journal editors at other schools say they are impressed with students who bring street cites to their publications. As more and more people earn cite-checking cred on the underground scene, other law-school groups could embrace such competitions.

“I can put anything in a parenthetical, even substantive information,” said Robert Draysone, editor-in-chief of Memphis Law Review. “But I don’t know how these inner-city cite checkers can tear through judges and officials as fast and effortlessly as they do. I’ve even seen someone cite non-student-written book reviews without even blinking. It’s absolutely amazing.”

The Litigation's Bicep

Hey everyone, LFA has asked me, The Litigation, to impart my legal wisdom on the masses. Here’s the lowdown: The Litigation tells judges what the law is. In effect, I am a living legal treatise. The Litigation is a fearsome attorney that juries adore and opposing counsel wish they could be.

My stint in law school was epic. My professors begged me to take a professor position, but I declined. The Litigation isn’t about teaching law; The Litigation is about being the law, son. During the bar exam, the proctor declared it was unnecessary for me to complete the exam after I schooled him on Marbury v. Madison. Separate but equal, baby.

Ever since easily passing that exam on my fourth try, I’ve been dropping knowledge on juries and judges alike, doing appearance for cases where I may not even know who the parties are, but you know what matters? The fact that The Litigation is on a particular side. Especially when I flex a cite or two that opposing counsel didn’t expect; hell, I may just make one up, to get everyone excited. I’ve been accused of using performance enhancers, probably because people can’t believe the crazy-ass points of order that I come up with, but the reality is the strength of my legal arguments is 100-percent natural.

From my experience, the body of the legal memorandum is where you can do the most damage in a brief. As such, and heretofore, I consistently utilize acronyms and abbreviations to maximize on the allotted space allowed. It’s a mechanism that has garnered several victories over bombastic adversaries. As Muhammad Ali said, “It ain’t braggin’ if it’s true.” Well, you know, it’s true, as far as The Litigation is concerned.

So grab a hold of your legal notepads and take some notations: The Litigation is going to set some legal precedents even Justice Marshall would’ve never dreamed possible. I intend to become the most recognized and celebrated judicial body in whatever court I step into. If that means a host of wonderful, beautiful law clerks just begging to score a summer-associate position with my firm, so be it. You have to respect your law, and, if you respect your law, the honeys will share that respect, and that’s when you bang that gavel, son. Motion to adjourn, straight up.

Get ready, because The Litigation is about to bronze up your mind. Props to my mom for making this writing ability possible.

“I’ve still got some gas left in the tank,” she said at a press conference announcing the signing. “While I’ll always be indebted to the Supreme Court and its fans for giving me some of the best judicial years of my life, I want to prove I can still perform at a high level. I’m excited to start doing everything I need to do to help bring the next groundbreaking constitutional precedent to Nebraska.”

Supreme Court

That will prove to be quite a challenge to the U.S. District Court of Nebraska, which many feel to be still in a rebuilding phase. Last year, the Court saw a whopping 73 percent of its decisions overturned at the Circuit Court level, leading to the firing of the court’s clerk as the caseload plummeted. Insiders say that Ginsburg signing makes sense for the Court, however, as a high-profile justice on the bench will help fill the docket even if the panel has yet another disappointing cycle.

“We couldn’t be more excited to bring in a judicial legend such as Ruth Bader Ginsburg. This immediately makes us competitive with the other District courts in our circuit,” said newly hired court clerk James Orbellet. “To celebrate, we would like all litigators to know that the first 2,000 plaintiffs to file in our court this week will receive a free Ginsburg bobble-head doll.”

Reaction in Washington was mixed. Although all universally praised the justice for the role she played in crafting some of the most forward-looking constitutional precedent of the past two decades — including, notably, striking down public male-only military academies in United States v. Virginia despite only having served on the Court for three years — other fans said the drop-off in her performance was noticeable. Last cycle, Ginsburg was assigned the least number of opinions than any other time in her career.

“She was one of the very best, without a doubt,” said expert Supreme Court commentator Jacob Wersler. “But these days she’s a shadow of her former self. It’s painful to read, and now we’re all going to witness as her career voting statistics sink. It’s always sad when a great justice doesn’t know when to hang up the robe.”

Ginsburg will take the bench for the U.S. District Court of Nebraska’s first session of the cycle next week. Tickets to oral arguments in a routine labor dispute have already sold out.

Patent

Soon after reviewing the facts with Brestle Corp.’s general counsel, and performing rudimentary document review during pre-trial preparation, Triest realized that he was in possession of the proverbial “smoking gun” — an email from Reuven’s CEO allowing Brestle’s CEO the use of underlying patent at issue in the case in exchange for an agreement to end an costly and aggressive advertising campaign. However, instead of burying the email until a dramatic reveal during trial, Triest did the unthinkable: He exposed the email’s existence in a pre-trial summary-judgment memorandum.  The result was an easy victory for Brestle, despite the company’s previous willingness to pay Swanter, McMillan and Carte “whatever it would take” to win the case.

Immediately following the Court’s grant of summary judgment, Richard Swanter, the firm’s managing partner, released Triest of his duties, citing “behavior unbecoming of a trial attorney.” 

The firm’s official termination letter noted that any attempt to win on summary judgment had to be approved by a minimum of two partners, and the speed at which Triest had closed the Brestle case had not received such authorization. Further, firm policy in corporate cases is, during the course of pre-trial preparation, to review every single document possessed by both companies. By ending document review as soon as dispositive evidence was discovered, Triest precluded the months of records examination the firm had scheduled.

“I don’t know what Triest was thinking,” Swanter said in a recent interview with Minnesota Litigator Monthly. “He let the whole firm down. There were numerous attorneys looking forward to putting in long hours on the Brestle case. Now, they’ll never get the chance — all because Triest had to show off. It’s selfish, really.”

For his part, Triest has been apologetic. In the same Minnesota Litigator Monthly piece, he admitted to having been “caught up in the rush” as the case prepared for trial. “I really didn’t stop and think,” he said. “Sometimes I can be too competitive. … I saw the document and just went for the ‘w,’ you know?”

The firm has voluntarily self-reported the case to the Minnesota Bar Association, which has indicated it will not seek further sanction.

Appellate memorandum

On paper, it looked ideal: Castill was looking to beef up its roster of recognized legal professionals, and Droganon was tiring of sitting on the sidelines. But now, eight months after the high-profile hire, sources inside the firm say the marriage is on the rocks. At fault? Droganon’s no-computer policy.

“We were all really excited when we heard Frank was going to be a partner here. I mean, the guy is a legend,” said one associate who asked to remain anonymous. “We got a team in place for him and everything. Then, on his first day, he walks in and tells his whole staff that he doesn’t allow computers. By noon, most of his associates had asked to be transferred.”

Sources say Droganon circulated an introductory memo saying the policy, which he had originally developed for first-year students in his Evidence class at University of Pennsylvania Law, was to keep associates “focused” on the material and prevent “tempting distractions.” Droganon informed his associates that they would work with pen and lined paper, and would have the option of typing the material into a word processing program on their computers after hours, if they so choose.

Productivity plummeted immediately, sources say. Although Droganon claimed that his personal ability to work was helped immensely by eliminating the loud clicking of keystrokes within the office, those working underneath him said the time to draft memos and briefs increased by threefold. Two major clients were enraged at the increased legal bills and decreased output and dropped the firm within two weeks, one source revealed.

“It was very strange,” said a paralegal who also asked not to be named. “We had a general counsel travel into the office and start using his laptop. Frank was trying to talk with him, and then stopped the whole conversation to complain that there wasn’t enough eye contact when the guy was looking at his computer. That was because all the notes that were relevant to the case were pulled up on the guy’s screen, but Frank didn’t seem to care.”

The no-computer policy led to clashes with the firm’s managing partner, Joseph Krickman. Krickman attempted to address the concerns by making all subordinate associates sign an oath not to surf the Internet while using computers at work, but Droganon would not accept a deal unless the attorneys also promised not to use e-mail. In the end, Droganon got his way, and communication at the firm was in total disarray. One former partner, who left the firm because of the Droganon policies, said that it became nearly impossible to collaborate in a timely fashion within the firm or with clients.

Those in the Philadelphia legal scene say that Castill’s entire future now hangs in the balance as attorneys refuse to work under Droganon’s demands and clients balk at the decreased productivity. Were Droganon to be let go, it would be a hugely embarrassing misfire for Castill, once one of the fastest-growing firms in the city. As for Droganon, being fired for managerial incompetence would surely affect his ability to obtain another prestigious professorship.

Laws For Attorneys attempted to reach Droganon for comment on this story, but he did not respond to e-mails.

Litigator

Litigators are time-honored and respected positions in the law. As such, through the long history of the profession, a number of often-observed, yet infrequently discussed, traditions have naturally developed in the field. Those who have moved into litigation, or are considering it, will need to quickly get up to speed on these customs in order to be effective. As experienced litigators who have tried more than a half-dozen cases, we here at Laws For Attorneys are well-versed in the unspoken conventions that define the litigation culture. Below we address commonly observed “do”s and “don’t”s that are now well-established among trial lawyers.

• Do – Make strong, emphatic points.
• Don’t – Use profanity unnecessarily. Some profanity will usually be appropriate, but overuse can sometimes have the opposite effect. The most effective courtroom advocates instinctively know when a strategic “f-word” will strengthen the point, but know those occasions may be as rare as once every five to ten minutes.

• Do – Speak loudly.
• Don’t – Scream without pause for a prolonged time. Volume conveys the importance of the proceedings and the urgency of the matter at hand, and so an occasional wordless shriek may force the jury to pay attention. However, studies of juries have shown that some may find uninterrupted screaming distracting or annoying.

• Do – Dress aggressively.
• Don’t – Wear anything with feathers. Bright neon colors and pinstripes let the jury know that you’re a winner and so is your client. A boa made of ostrich feathers, however, runs the risk of upsetting animal lovers.

• Do – Have mastery of the English language.
• Don’t – Obsess about grammar. Periods, commas, and other punctuation marks may look good on paper, but also reveal a lack of concern with being time-efficient.

• Do – Laminate exhibits.
• Don’t – Use construction paper and crayons that are similar colors. The end-product might be difficult for others to read.

• Do – Intimidate opposing counsel with arm motions.
• Don’t – Rest your hands on a podium, desk, or other surface. A general rule of thumb is that a litigator’s hands should never fall below his or her shoulders.

• Do – Treat attorneys with respect.
• Don’t – Argue with opposing counsel about anything, whether or not you may feel that the issue is material or relevant to your client’s position. This is highly unprofessional and will not be tolerated by a judge.

• Do - Develop a photographic memory.
• Don’t – Make copies of documents. Paper documents suggest that you’d prefer not to have to converse personally with others about the material, which may appear rude, anti-social, or egotistical. Perhaps worse, making physical copies shows a lack of concern for the environment.

Short for Xtreme Legal Reference and Citation Guide, the X-Ref hopes to shake up the staid norms of legal citation, which, for the past decade, have been set primarily by the Bluebook, to a lesser degree, the Association of Legal Writing Directors Citation Manual. Calling their new publication “edgy” and “modern,” editors of the first-edition X-Ref say the field is ready for a revolution.

Possible document which may be cited

“This isn’t your grandfather’s legal-citation guide, or standards that are going to be used by some old judge,” said editor Philip Dramm. “The X-Ref is for attorneys looking to shoot their memos full of adrenaline. It’s basically legal citation on steroids.”

X-Ref overhauls every element of accepted style, replacing them with a mix of artistic, noncomformist, and unconventional formats. Some of the changes are drastic, most notably the total replacement of numbers with Roman numerals. Other changes are very specific, such as using lesser-known fonts when citing foreign legal sources; when citing New Zealand courts, for example, the X-Ref requires use of the “Shruti” font.

Most source abbreviations themselves have been modified to be more “hip,” Dramm explained, so that Treasury regulations previously denoted as “Treas. Reg.,” are, under X-Ref, shortened to the less formal “T-Regz.”

“We wanted our citations to have a linguistic quality to them, a sort of oral flow,” said Samantha York, a consultant on the X-Ref staff. “Citing to ‘S.D.’ for the South Dakota Supreme Court isn’t nearly as cool as citing to the ‘S-Dak SCO-Crew.’ If you’re referencing a previous footnote, ‘supra’ is just about a boring word as there is. In X-Ref, you’d ‘smackback’ that note.”

Interestingly, use of the X-Ref would, for the first time ever, introduce color into formal legal documents. Citations to various journals are given specified colors, for example, the University of Miami Entertainment and Sports Law Review is cited in “purpaqua,” described a “mix of purple and aqua.” As periodicals are cited in all lower-case, with no spaces, an X-Ref citation to the journal is “mia-vips&ballerz.”

“Black and white is the past. X-Ref is here to bring the flash,” said Dramm.

Publicly, editors at Bluebook and ALWD said they welcomed the competition. Privately, however, many expressed doubt as to whether X-Ref would take hold. Many attorneys said they would sample X-Ref just for the experience, but wouldn’t be giving up on their traditional citation guides any time soon.

“Sure, you might write a memo, just within the office, with X-Ref. If things are a little slow around the office, it might be entertaining,” said Jack Wasner, a partner at Wasner, Murg & Lorry in Detroit. “But I think people will see it for the gimmick it is.”

Dramm brushed off such comments as uninformed.

“Once you start working with X-Ref, you won’t want to ever go back. Literally spray-painting in a citation using the graffiti function of MS Paint… how could you settle with typing words after that?” he said. “X-Ref is going to change the game. And you can [expletive] cite me on it.”

God Trust

Simply, creating a trust with another gives rise to a legal obligation to believe what they say. Trustees owe a duty of reliance to each other, in which they must fully act without reservation based on any information conveyed by the other party. In many ways trusts resemble familial bonds, and, arguably, brotherly bonds, in some instances.  Trusts are governed by trust documents, in which the signers agree to accept everything the other says as true. Trusts can also be formed through oral declaration or a court order. For a trust to be valid, there must be 1) the intention to enter a trust; 2) clearly identified subject matters as to which the parties are to be blindly believed; 3) entities for which the trusted parties vouch (and are thus also are trusted) that are specified.  After the formation of a trust, trustees have many rights and responsibilities. Breaching a trust, by not believing what another trustee has made a representation on, can lead to legal liability.

There are numerous benefits to creating a trust, and there are many ways in which trusts are used. Many people enter trusts for privacy reasons, in that information they reveal and ask not to be revealed to others stays confidential. In a very real sense, trustees become “co-owners” of whatever information is shared between them. Others enter trusts so as to enable long-term planning; those in trusts can rely on all trustees to be part of the trust for an extended time, potentially even the life of each party. Disadvantaged parties or those with few relationships or interactions may place much value in a trust, as it offers a simple mechanism for protecting their information.

Some basic types of trusts are as follows:

• Simple Trust: where only certain, limited information is to be believed
• Dynasty Trust: established between members of different generations within a family
• Irrevocable Trust: a trust that cannot be terminated, as opposed to a revocable trust
• Unit Trust: a trust where each party is required to share equal amounts of information with each other
• Offshore Trust: a trust between members of two separate nations

In the end, however, trusts give all parties peace of mind. Many times, people have information that they want to share, or want to be able to know that what someone else has told them can be relied on. Not only does this assist with planning, but it also improves everyone’s overall quality of life.