Jeffrey Lewis: Welcome everyone. I am Jeff Lewis. And Fran, when I was a kid and I was sick at home, skipping school, there would be this black and white TV show on called The Outer Limits that said, We are in control of your TV. today we're in the outer limits of the podcast world because Tim is on vacation and the kids are in charge. I got to invite one of my favorite people, great appellate lawyer, the lawyer that puts fear in landlords all throughout California. Fran Campbell, thank you for being here with us today.

Frances Campbell: Thank you, Jeff Lewis. That's so nice of you to say. You're my favorite

Jeffrey Lewis: And it's true.

Frances Campbell: appellate lawyer. Don't tell Tim. He's

Jeffrey Lewis: Yeah.

Frances Campbell: up there too.

Jeffrey Lewis: He's not gonna listen. He's not gonna listen to this. we're gonna do our best without Tim here. for those who listened regularly probably understand that Tim is the backbone of this podcast and he's not here, but we're gonna do our best to get by. We've got three or four cases to talk about and let's start with a case I know that is near and dear to your heart, Fran, the Barrington case. What was it about? What was at stake? What was your role? And where are we at with that case?

Frances Campbell: So that was an interesting case because all of a sudden Douglas Emmett, one of the biggest landlords in Los Angeles, mostly mostly commercial, but also a huge residential landlord, decided they wanted to evict everyone in Barrington Plaza for the reason is they wanted to put in sprinklers. because they said, Well, there's been two fires here, we can't take it anymore, we want to put in sprinklers. Now, Elizabeth Warren has a plan for that. If you want to take your apartment building and make repairs to it in a way that we're to require people to move out, they have something called a tenant habitability program. And what happens is the landlord who has rent controlled tenants submits his permits to the Los Angeles Department of Building and Safety, and they go, okay, this looks like it's going to disrupt some people. They send the permits to the housing department to determine what should be done about the tenants, and they don't issue the permits until there is a habitability plan in place. And then they have to send the tenants out to another place within five miles and move them back. That's the law in the city of Los Angeles. But Douglas

Jeffrey Lewis: Okay. Sounds like a great plan.

Frances Campbell: would be a good plan, except for Douglas Emmett didn't want to do it. So they just said, well, why don't we take this law that's not at all meant for that. And just invoke it. And that law is the Ellis Act. And the Ellis Act is a very interesting law that allows a landlord to evict all his tenants because he wants to go out of business. Now, if you really want me to get deep in the Ellis Act, I can.

Jeffrey Lewis: Well let me ask you, Frank, 'cause I don't I don't do this work, right? if I have a landlord tenant problem, I call you or I call Eileen. what is the problem that the Ellis Act is trying to solve?

Frances Campbell: I'm glad you asked. In nineteen hmm it's the nineteen seventies, before Santa Monica passed its rent control laws and all the various laws that are attached to it, a seventeen-year-old man bought an apartment building. And the seventeen year old, I mean can we even call him a man? I guess so. He owns an apartment building. So he doesn't like being a landlord. e he didn't like the people there. I guess they were bothersome to him. This is in the court record. He said, All I want to do is evict my ungrateful tenants and hold the property for land value. That's all he wanted to do. And so he says

Jeffrey Lewis: Okay.

Frances Campbell: to the city of Santa Monica, give me a demo permit. And the city of Santa Monica says hey, we got these new laws. Well hey No, no, it looks like you're making a good enough return on your investment. you got some you've got some poor people in there. Yeah, we're not gonna give you a demo permit. And he's like, Well, that means you're forcing me to be a landlord. I'm gonna sue you. And I'm gonna say that you're forcing me to do this profession. And that's a little bit like slavery. I don't I don't think the courts are gonna approve of that. So he sues Santa Monica and the Superior Court. And this Superior Court agreed. and that's a little bit like slavery, Santa Monica. You can't

Jeffrey Lewis: Okay.

Frances Campbell: force someone to be a landlord. So of course, Santa Monica goes, yeah, no. Here we come, Court of Appeal, right? And they took it up there. And guess what? Court of Appeal goes, God, it is kind of like slavery. I mean, not all the way 13th Amendment slavery, but it's kind of like slavery, Santa Monica, what you're doing. You're forcing them to stay a landlord.

Jeffrey Lewis: I don't buy the analogy, but go ahead.

Frances Campbell: Well well I'm just hey I'm just I'm summarizing cases.

Jeffrey Lewis: All right, okay.

Frances Campbell: so santa Monica loses again. And the Santa Monica's like, hell no. And so they s you know seek review with the California Supreme Court. and this time the California Supreme Court says, Okay, I see where the other courts are coming from and it is kind of Bit like, you're impinging on someone's liberty interest to do a certain profession. It kinda but it's not as serious as all that, Court of Appeal and Superior Court. I mean, the guy can hire a property management company, he could sell his building, he doesn't have to be a landlord. And we're gonna say your new regulations are okay, Santa Monica. So finally Santa Monica wins. But you can imagine. real estate concerns have been watching this litigation, which is in fascinating. We would have watched it too. and so they say, no, we like what the Court of Appeal said. So they passed a special law called the Ellis Act that would, What is a la word for get rid of that California Supreme Court opinion? And and And go back to the

Jeffrey Lewis: Good old days.

Frances Campbell: good old days. Anyway, to get rid of this Supreme Court opinion and Nash and and give the landlords an absolute right to quote go out of business. This government code 7060.7. And the first part of the Ellis Act says, Cities, you can't interfere if a landlord wants to go out of business. Okay, so now let's go back to recent the recent past. Douglas Emmett's lawyers said, Hey, we could use the Ellis Act to get rid of everyone on the ground that you're going out of business.

Jeffrey Lewis: And that's like five or six tenants in this Barrington plaza?

Frances Campbell: Yeah, five hundred and fifty-eight units, probably more like seven hundred and fifty tenants-ish. It was a big

Jeffrey Lewis: That's a big deal. Okay.

Frances Campbell: deal. So I heard about it from the coalition from Economic Survival. I do a tenants' rights clinic with them every Saturday, that the all these tenants, this was happening to them and they were upset. And so I happened to mention to the head of the Coalition for Economic Survival, I said, Well, what they have to do is form a tenant association and sue for declaratory relief, because that's not what the Ellis Act is for. They're not going out of business. They're renovating. That's very much being in business. And so anyway, that's how that's how my firm got involved in that. And we filed the Deck Relief Action and ultimately won. Although sadly we could not get Judge Chalfont to enjoin them from filing eviction actions until the end of the litigation. So a lot of people left behind these bad Ellis notices. And I can say they're bad Ellis notices now because we did win that case. Judge Ford agreed with us. And a lot of landlord's attorneys came up to me and said, Hey, confidentially.

Jeffrey Lewis: Ha ha ha.

Frances Campbell: You gotta win that case. I said, Yeah, I know.

Jeffrey Lewis: Yeah.

Frances Campbell: So so anyway, we won, but now it's on appeal. yeah. No,

Jeffrey Lewis: Okay. And when you say one, was that the pleading stage or was there a trial?

Frances Campbell: there was a trial. We went all the way to trial because there was a lot of talk about what it means to go out of business. And they really focused their defense around how important these repairs were and how long it was gonna take and how disruptive it would be. I I didn't put on a single witness. All I did was cross examine Jordan Kaplan and and one of, his corporate counsel about the thing she signed that says What are you gonna do with the building once you go out of business? You wrote undecided. I'm like, well, that's not really true, is it? You filed you you published press releases. You filed them with the SEC. You're gonna remodel, re rent. So there was a lot of talk about what it means to

Jeffrey Lewis: I see.

Frances Campbell: go out of business. And so that's what's up on appeal now. What does this mean to go out of business? Did Judge Ford

Jeffrey Lewis: Okay.

Frances Campbell: get it right or Judge Ford get it wrong?

Jeffrey Lewis: Question of law or question of fact upon appeal? What is this?

Frances Campbell: Well, I think it's gonna be a question of law because

Jeffrey Lewis: Okay. All right.

Frances Campbell: w we're interpreting what that means under government code seventy sixty point seven. What does that mean?

Jeffrey Lewis: right. And me

Frances Campbell: I I mean I think our position's strong, but I get really in I I frequently get high on my own supply, so

Jeffrey Lewis: Yeah, yeah. You're totally biased favorite tenants. We get it. so, maybe I'm confusing cases because you and I sometimes nerd out on obscure appellate issues.

Frances Campbell: Mm-hmm.

Jeffrey Lewis: was there a super sedious issue in this case that the nerds who listen to our podcast will be interested in?

Frances Campbell: Well yes, I'm glad you asked. So they did something really crazy after the Barrington case, because they lost. So all the eviction notices are invalid now, and there's still some people left. Like 80. So they sent out these bills and said, by the way, you owe rent. They they said by the way and by the way, pay rent, and we're not waiving our appellate rights. I was like, yes, they are, because as soon as a landlord collects rent from someone, that's like the equivalent of a landlord saying to the tenant, Hi five, you're okay with me. I love you. Here's your new periodic tenancy.

Jeffrey Lewis: All is forgiven.

Frances Campbell: Right. So now if they change, if they reverse the judgment. They everyone gets to stay anyway because they've

Jeffrey Lewis: I see.

Frances Campbell: collected rent from all these people who are there. They've created new periodic tenancies. So The Ellis Act, because it's so, you know, it's consequential to the tenants, it has a lot of regulations. And if a landlord takes his property off the rental market, and then within two years of the date of withdrawal, functionally three years here, they re-rent, everyone displaced is entitled to damages and exemplary damages. Those are the only facts. Did you tell the city? You're taking the building off the market. Did you collect rent within two years of the date of withdrawal? Boom! Those are the elements. Yes and yes.

Jeffrey Lewis: Sounds like a sounds like a plaintiff's motion for summary judgment. So

Frances Campbell: I wonder about if well we you and I could talk about that the possibility of doing that at a later time. I'm not sure you

Jeffrey Lewis: Okay.

Frances Campbell: can. But anyway, so that's where we are. So on behalf of a hundred and ninety-two displaced tenants, we filed a second action. it's like, you've c collected rent within two years of the date of withdrawal. My people are now entitled to damages. And that's all there is. And I thought long and hard about is there some reason why I can't? Because the judgment is not final, but it doesn't matter. It doesn't matter if they've reversed the judgment or affirmed the judgment. They still re rented within two years of the data withdrawal.

Jeffrey Lewis: the cause of action is a violation of the Ellis Act and it's an action for damages and

Frances Campbell: It's a violation of the rent stabilization ordinance, technically, but it is a

Jeffrey Lewis: Okay. Okay.

Frances Campbell: cause of action completely approved by the Ellis Act.

Jeffrey Lewis: Alright.

Frances Campbell: So they said, Hey, the judgment's not final. And I said, Hey, it doesn't matter. And they did a motion they brought a motion first they filed a notice of stay saying that the new case, which was called the Svetko case, is stayed. And it's like, no, it's not. Judge Long says, Did someone file bankruptcy? I'm like, no, because it's not state. And so then they brought a motion to enforce the stay, which the tentative was in their favor. And I turned the judge around. And s someday we can get into how much better it is, everyone out there listening, to appear in front of a judge in person and be the one talking into his eyeballs while the other lawyers are on the screen. Because I turn the tentative.

Jeffrey Lewis: And Yeah. Okay, good.

Frances Campbell: But now they filed a petition for writ of supersedious inside the Barrington Plaza case, saying that somehow my ongoing Svetko litigation was going to interfere with a Court of Appeals jurisdiction. No, and I still can't fully understand their logic there. But they're very strong in their opinion, I will say that. And they lost.

Jeffrey Lewis: And what did Okay, so the did the Court of Appeal punt or did they just say denied?

Frances Campbell: They said denied.

Jeffrey Lewis: Well, very good. Very good. and is a petition for writ a supersedious, is that like a motion where you've got fifteen days to file an opposition and then there's no argument, the court just decides it? Okay.

Frances Campbell: That's correct. I have fifteen days to file to respond to an eleven thousand word motion.

Jeffrey Lewis: Do you think maybe they took more than fifteen days to draft that? Yeah.

Frances Campbell: I'm sure they did because they filed an extension of time to file the reply brief in the Barrington Plaza litigation and then and then dropped this on me. So when they asked for a second extension, I opposed that and the Court of Appeal agreed with me. So

Jeffrey Lewis: All right. Okay. all right. Well stay tuned. I'm gonna wish you luck on that one. the

Frances Campbell: Thank you.

Jeffrey Lewis: second Francentric case we're gonna talk about before we hit the the recent cases is tell us about tenants who don't wanna wear pants.

Frances Campbell: I'd be happy to. There is a mobile home park called the Olivedell Nudist Resort that's out in Colton, California. And it's a historic nudist they don't like the word colony. It's a historic nudist resort. And historically to when you were a tenant there, you also were a member of a nudist association and the People could join who didn't live there and come in and enjoy the facilities and there was a clubhouse and a pool and a sauna and tennis courts and all this great stuff for nudists. So people bought this property and decided they would change the rules. First of all, they stopped maintaining everything. And then they said, new rule. You have to wear clothes now. Well, that's not how

Jeffrey Lewis: That seems like a big change.

Frances Campbell: Yeah, that's not how rules are f are passed in mobile home parks either. So anyway, we we were busy w mostly dealing with Barrington case, and somebody approached me about this case with this all these tenants out there in a nudist mobile home park needing representation because of what was happening. And I, I said to my beloved and long-suffering law partner. I said, come on. I said, if we're not taking a nudist mobile home case, what are we doing with our lives? You ch you just have to do it. So we did it. And it's it's become quite a mmm something show. the opposing counsel is very unusual and doesn't want to answer any discovery and so it's it's been a very challenging litigation. The owners, I guess, of the nudist mobile home park are going around removing everyone's electrical meters so they can't get electricity and people are having to get generators and preliminary injunctions have issued and it's still hard to enforce them because these are people who really don't care about the law. They just do whatever they want. So these are the struggles we're having.

Jeffrey Lewis: are you at the pleading stage or getting ready for trial? Where are you in that case? Yeah. Okay.

Frances Campbell: Somewhere in between. everyone has answered. But we filed maybe twelve motions to compel and then they just fix the way they answered and basically go, we don't have any documents. text messages? no, we don't know how to do text messages. Of course my clients are getting text messages. Pay rent, you know. But they're claiming that they don't have any because somebody stole a laptop from the office a year earlier. Well, what about the emails they're sending today? What about the organizational documents for the

Jeffrey Lewis: Yeah.

Frances Campbell: owners, for the management company? no, crickets, you'll have to go ask someone else about that. And I really don't know how they're gonna be able to prove their case. but, time will tell. I gotta stick we're gonna start taking depositions pretty soon in that case. yeah. It's an interesting case.

Jeffrey Lewis: Yeah. all right. Let's pivot a bit from naked mobile home parks to the Supreme Court of the United States. Now Tim

Frances Campbell: Yes.

Jeffrey Lewis: and I don't typically cover United States Supreme Court decisions, but there's one that's got kind of a California angle that I want to cover. And I do a lot of anti SLAPP work and mostly for defendants. if you are a plaintiff's lawyer who does anti-SLAPP work and you sometimes do it in federal court, you want to pay attention to this next this next case. the Supreme Court in January issued a case called Berk v. Choy that just came to my attention. And that case was unanimously decided. There were some concurrences and all that, but there were no dissents. And the issue in Berk v. Choy wasn't a anti-SLAPP case, not even a First Amendment case. It all about medical malpractice. And I guess Delaware has a law that says, hey, if you're going to file a medical malpractice case, we don't want frivolous cases here in Delaware. We want you to get a doctor who's going to sign off that he's looked at these facts and it's a righteous case, and that's going to be a pre-filing requirement. And the clerk's not going accept your case for filing if you don't have that. And This wound up all the way to the Supreme Court. The Supreme Court decided Yeah, we don't like that rule. It seems to run afoul of the federal rules of procedure. And therefore, yeah, that rule doesn't apply in federal court. I bring this up because many times in California, defamation cases are filed in federal court instead of state court to avoid our anti-SLAPPs, early screening of merits. And, although the anti-SLAPP law applies in federal court for now in the Ninth Circuit, there's lots of ways it's watered down. And if I were a defense lawyer and I read Berk v. Choy and I was in a federal proceeding involving a SLAPP, I would be citing to Berk v. Choy saying Jeff Lewis shouldn't be filing an anti-SLAPP motion. It's no longer allowed under Berk v. Choy. They'd be wrong, but that's what they should argue.

Frances Campbell: Jeff, why would you be giving this hint to all the defense lawyers listening to your podcast?

Jeffrey Lewis: you and my mom are the only people that listen, Fran, let's be real. But let me ask you, Fran, had you been paying attention to this case and w what do you think about the SLAPP law's ability to continue to be applied in the federal courts?

Frances Campbell: Jeff, I think the SLAPP law in the federal court is circling the drain. I really do. And I can understand the logic behind the Burke case. The US Supreme Court does not want to deal with all the little states, little requirements. It's untenable. They're gonna say, you're in my house now. We don't do that here. So know I Should there be a federal anti SLAPP law? Sure, let's go. But until there is, why should the US Supreme Court or all the federal courts have to bother their pretty little heads over California anti SLAPP?

Jeffrey Lewis: 'Cause the anti SLAPP law is substantive, not procedural under Erie, that's why.

Frances Campbell: I thought you were gonna say 'cause it's awesome. I do I do anti slab work as well, but I won't

Jeffrey Lewis: That too. yeah. It's a it's

Frances Campbell: do it in federal court. No thank you. No, well especially now. Especially

Jeffrey Lewis: Really? You won't do it in federal court. Okay. Okay. Well, for our listeners,

Frances Campbell: now.

Jeffrey Lewis: in federal court you can't bring a factual challenge, it's gotta be a pleading challenge, a legal insufficiency, there's no sixty day time limit, and plaintiffs can amend all day long. to to get around the SLAPP law. And there's no real immediate appeal from a loss given the gopher media case that's I think seeking review in the Supreme Court. So federal SLAPPs are pretty anemic as it is. But it's a good reminder on the plaintiff side with this little landmine lurking in terms of Berk v. Choy If you're on the plain I mean if you're on the defense side and you're bringing an anti-SLAPP in federal court, you should always be Filing in the alternative to a 12v6,

Frances Campbell: huh.

Jeffrey Lewis: just in case the SLAPP rug gets pulled out from under you.

Frances Campbell: Good tip. I haven't walked into a federal courthouse since twenty twenty eighteen.

Jeffrey Lewis: Yeah. That's a courthouse you should go up here and appear in person to argue. you feel like a grown up lawyer when you go to federal courthouses.

Frances Campbell: the federal courthouse downtown LA, the newer one, absolutely beautiful architecturally. Mm, perfect.

Jeffrey Lewis: Yeah. All right. Let's talk about another case. R.M. v. A.G. This is from June of 2026. It's from the second appellate district. It is published, and the reason this case caught my eye is it's about DVROs, domestic violence restraining orders. I don't do those kind of cases. But I frequently am asked When someone is opposing either a civil harassment or a domestic violence restraining order, Jeff, can we bring a SLAPP? Because they're not really trying to restrain conduct, they're trying to restrain speech. I want to do a Facebook post that says my ex is awful and this judge won't let me. So, Jeff, let me do a would you do an anti-SLAPP? I frequently turn those down. But I have to say, the more the courts are allowing online cyber speech to form the basis for one of these restraining orders and there's not conduct going along with it, meaning it's just mean, terrible words, the more uneasy I feel. But, Fran, I know you on occasion do DVROs. What did you think of the R.M. v. A.G. case?

Frances Campbell: thought it was really interesting. First, I thought it was a beautifully written case that really explained the law much more than other cases I had I had read recently. but it's hard to talk about that case outside that context, right? Because here's people I mean, yeah, that that case had it all, like, rough sex and, when the online posts are in the context of this really problematic relationship that was violent, that involved stalking, that involved thousands of text messages that include online messages like, I'm gonna change my name online to yes, go kill yourself or something like that, please kill yourself. I mean, how is that speech not impactful in that context? I mean free speech what

Jeffrey Lewis: Yeah. Context is king, I get it, I get it. It's always the cases on the fringes that have me on on edge though.

Frances Campbell: Yeah. I mean, those are fighting words. Definitely. I mean, that was just a a terrible, terrible case. and I mean, it was a terrible relationship described. Beautifully written case. Very interesting.

Jeffrey Lewis: Yeah. Yeah. I mean and look, the gist of the case is trial judge didn't consider social media activity as abuse within the act, and so the party who wanted to introduce that evidence at the trial didn't get the restraining order or their mutual restraining order, brought it up on appeal. The Court of Appeal agreed, and here's the interesting thing not only reversed the failure to consider this social media evidence, but But reversed everything saying when you're dealing with a mutual restraining order, the two go hand in hand and the fact finding in terms of primary aggressor and all that go hand in hand.

Frances Campbell: And there can be two primary aggressors.

Jeffrey Lewis: Yeah. Yeah. Yeah. Super interesting. okay. last case I want to talk about today, and that is Jane Doe. versus McGrath. And this is a june twenty ninth case, again in the second district, again published. I do a lot of work volunteering as a fee arbitrator. And so I'm always interested in enforceability of fee agreements and when can you strike it down? When c when is it enforceable? And one of the leading cases the Supreme Court issued on this issue of the enforceability of agreements in the context of conflicts was the Shepard Mullen case that said, Look If you've got a conflict, an actual conflict, and you didn't get a waiver, you're gonna have a hard time collecting your fees. Might be the whole fee is forfeit. we remand for that, but your fee agreement's likely not enforceable when there's an actual conflict. And then this case comes up a few years later, and this is the Jane Doe case, involving a potential conflict when you have multiple clients. So anytime you have more than one client, you're supposed to do a Conflict waiver. Hey, down the road something might happen. you might have a different view in terms of settlement or trial or evidence, and who knows? But I'm telling you now, sometimes it's a good idea to have your own lawyer, right? We all know that. this Jane Doe case said failure to obtain a conflict waiver for a potential conflict involving multiple clients not only could void a fee agreement in terms of the lawyer's ability to collect fees, but in this case it i the I guess the illegality permeated the contract so badly that an arbitration clause was denied enforcement. So big impact from not getting a conflict waiver. What did you think?

Frances Campbell: And that's the arbitration clause in the retainer agreement.

Jeffrey Lewis: Exactly, exactly.

Frances Campbell: I noticed that case. It was affirmed my very favorite trial judge of all time, Barbara Shepper. She was on it. I really miss her as a jurist. So

Jeffrey Lewis: She made an impression.

Frances Campbell: I'm glad she's getting this win after after her retirement.

Jeffrey Lewis: Yeah. Yeah. yeah. Anyway, good reminder. Yeah.

Frances Campbell: But it makes sense. It makes sense. It's a illegal contract. You're supposed to have that conflict waiver in there.

Jeffrey Lewis: Yeah, I get it on the fees. I don't I was I'm surprised that they carried it all the way to the arbitration clause. I could see denying fees, denying enforcement, but all the way to the arbitration clause. I I was pretty surprised by that. I would be surprised if somebody hasn't taken this up to seek review in the California Supreme Court.

Frances Campbell: But they would have to arbitration clause or no arbitration clause. You still have to do fee arbitration. So that's a arbitration clause after the initial fee arbitration. So

Jeffrey Lewis: Right. Yeah.

Frances Campbell: yeah. No, I'm I I I'm pro that case. Everyone put a

Jeffrey Lewis: Okay.

Frances Campbell: conflict waiver into your retainer agreement. How hard is it?

Jeffrey Lewis: Alright. So all right, you've redeemed yourself for being against free speech in federal court. All right, nicely done.

Frances Campbell: What?

Jeffrey Lewis: all right, and then th that was the last case I wanted to cover and then there was one news tidbit I wanna cover. I don't think Tim and I got a chance to cover this and that I recently noticed I got served with a motion and there was a new case no department number on the caption for a motion. They've renumbered all of the departments downtown LA, Stanley Mosque, one of the biggest courthouses In the world, in the country, in

Frances Campbell: Yes.

Jeffrey Lewis: the and so now there's some sanity and your courtroom number now matches what floor you're on. So if you've gotten a new Yeah.

Frances Campbell: It matches what room you're in. The department number is the room.

Jeffrey Lewis: Yeah. So I guess that makes sense, but for old timers like me, it's chaos. Yeah.

Frances Campbell: It is chaos. Where's apartment 94? It's on the seventh floor. Why? I don't

Jeffrey Lewis: Yeah.

Frances Campbell: know the answer to that.

Jeffrey Lewis: Yeah, and and by the way, the stairs are our the escalator's out. You're gonna wait for the elevator.

Frances Campbell: Yes, exactly.

Jeffrey Lewis: Okay. Fran, this has been a lot of fun, but I can hear Tim screaming from afar. It's time for the adults to get back in charge and return the keys to the car to to the parents. So I think we're gonna wrap up this episode. I really appreciate you coming on.

Frances Campbell: It's my pleasure, and I hope I can apply for my certification now.

Jeffrey Lewis: Certified podcast host. Alright. All right.

Frances Campbell: That's what I meant. I need to apply for to be a certified podcast host. I hope I have a correct number of points.

Jeffrey Lewis: Yeah, well I'll I'll give you a reference. All right.

Frances Campbell: Thank you.

Jeffrey Lewis: listeners, if you have ideas about future episode topics, we've gotten some great ones. Had some justices even email us with some ideas. feel free to give us an email at info@calpodcast.com and in the future look for updates about crazy naked tenant cases and other litigation and appellate topics.