Where Do Roundup Lawsuits Stand in the Federal Court Today?

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Roundup, the famous glyphosate-based herbicide, is among the world’s top weed killers. It became commercially available in 1974 and quickly gained traction due to its high efficacy rate in blocking growth proteins in a variety of plants.

Over the decades, speculations have circulated that Roundup causes major health issues, the most prominent of which is cancer. From third-generation farmers to amateur gardeners at home, Roundup has been a go-to aspect of their plantation efforts.

The Guardian conducted an interview with a Californian man, John Barton, who was a third-generation farmer. Barton had sprayed hundreds of thousands of gallons of Roundup throughout the course of 30 years. He mentioned that there had never really been any regulation (besides the need for hazmat suits) regarding the use of Roundup.

In fact, there was no protection offered during the initial years as Monsanto (Roundup’s producer, later acquired by Bayer) claimed it was perfectly safe. Today, the company is facing thousands of lawsuits, with more pouring in as the months go by.

2016: The Year When It All Began

One major reason why Roundup was considered safe during the initial years was that it inhibits growth proteins in plants through an enzyme pathway not present in humans. Hence, even genetically-modified food crops or GMOs were introduced during the mid-1990s, and Roundup was used in large quantities by farmers across the US and the UK.

It is only in the last two decades that glyphosate’s real face has come to light. Back in 2015, the International Agency for Research on Cancer (IARC) considered Roundup weed killer to be “probably carcinogenic.” Around this time, Monsanto was still claiming that Roundup was perfectly safe for humans.

In 2016, Dewayne Lee Johnson filed a Roundup lawsuit against Monsanto, alleging that the product was responsible for his Non-Hodgkin’s Lymphoma diagnosis. Dewayne stated that he did not have a family history of cancer and had been using Roundup as a farmer for decades.

Johnson was particularly afraid that he may have exposed his sons to the disease too (who are also farmers). Given his failing condition, Dewayne’s case was the first-ever Roundup lawsuit to proceed to trial, during which a California jury demanded that Monsanto pay $289 million in damages.

Dewayne’s case reached a settlement in August 2018. Just a year later, a Mutation Research report released by multiple universities found that frequent exposure to high amounts of glyphosate increased the risk of developing cancer, endocrine disruption, and genetic alterations. It was around this time that the seventh edition of the ‘March against Monsanto’ took place in full force across the world but primarily in the US and France.

Since then, study after study has only confirmed that Monsanto (now Bayer) significantly downplayed the dangers of Roundup.

Lawsuits and Settlements Over the Years

After Dewayne’s Roundup trial, several plaintiffs filed a Roundup lawsuit over the years. Two high-profile cases in the Federal Court included a plaintiff who claimed they developed cancer after using Roundup for over three decades. The jury initially awarded the plaintiff $2 billion in damages, but the amount was later considered to be excessive and reduced to $86.7 million.

A similar situation occurred with another plaintiff who was awarded $75 million in punitive damages alone but later received only $20 million. To date, Monsanto and Bayer have settled nearly 100,000 Roundup lawsuit cases, with 30,000 still awaiting settlement or trial as of 2022.

Most cases received a positive verdict from the jury and relevant settlement, but Bayer has had its fair share of victories too. For instance – A child was diagnosed with Burkitt’s lymphoma allegedly due to Roundup, but the California Court did not find any such link. The verdict fell in favor of the defendant as no substantial cause for the diagnosis could be proved.

The latest update on the Roundup lawsuit (as of May 2023) is that nearly 4000 cases are pending in Federal multi-district litigation in California. New cases are still coming in as lawyers accept claims for negotiations or trials.

Reasons for Fast Claims Settlement

In effect, Roundup lawsuits have received settlements at a fast pace. Initially, Monsanto was willing to make a $45 million class-action settlement for false advertising claims, but this was turned down by the California jury.

The class-action settlement did not account for the personal injury claims of individual plaintiffs. However, the considerably high number of cases made it impracticable to go through each case individually. The interesting fact is that Roundup lawsuits were handled both through class-action settlements and multi-district litigations.

A class-action settlement was used in cases:

  • Where two or more plaintiffs shared commonalities
  • The defenses and claims of the representative parties were similar to the defenses and claims of the class
  • The representatives were vested in protecting the interests of the class

A multi-district litigation was used when:

  • Individual circumstances were so vastly different (in the context of the injuries suffered) that a class action was deemed challenging.
  • The way people purchased and used Roundup was different and needed individual attention

This played a key role in accelerating settlements for over 100,000 cases through the years.

Importance of Attorney Intervention

In most cases of speedy settlements, attorney intervention played a major role. The best lawyer for a Roundup lawsuit is the one qualified to win cases against well-resourced defendants like Monsanto and Bayer across all 50 US states.

The lawsuit may be filed by any person who was exposed to Roundup for years and was subsequently diagnosed with cancer (especially Non-Hodgkin’s lymphoma). However, only a qualified attorney can confirm eligibility on a case-to-case basis.

According to TorHoerman Law, the plaintiff needs to produce evidence in court that they were exposed to Roundup for years, including receipts, bills of purchase, medical and employment records, etc. They are only eligible to file a lawsuit if they meet the statute of limitations, which is a maximum of three years from the day of diagnosis (but may vary among states).

Since the defendant is a multinational corporation with limitless resources, it would not be wise to proceed with a Roundup lawsuit without a qualified attorney.

Final Thoughts

Today, the evidence against Monsanto/Bayer’s initial claims is overwhelming. This evidence is further confirmed by Bayer’s personal statement that it would take down Roundup from the shelves starting in 2023. This is a major leap on the company’s part to avoid further lawsuits.

However, Bayer has also stated that this move is exclusively made to avoid further litigation risks and has nothing to do with the product’s health concerns. As such, it plans to let commercial farmers have access to Roundup’s original formula.

While Bayer implements its five-point plan to reduce future litigation risks, Roundup lawsuits still continue to pile up in the US California Federal Court.

Strategies for Boosting Box Office Movie Success

Movies have always been a popular form of entertainment, and a successful film can bring in millions of dollars in revenue. However, not every movie is a blockbuster hit, and many fail to generate enough income to cover their production costs. So, what can movie producers and studios do to maximize their movie income and boost their box office success? Here are some strategies to consider.

Develop a Strong Marketing Campaign

A strong marketing campaign is crucial in generating buzz and excitement for a movie while playing Australian mobile casinos . This includes creating eye-catching posters and trailers, partnering with influential brands and personalities, and leveraging social media platforms to reach a wider audience. A well-executed marketing campaign can help a movie stand out among the sea of releases and create a sense of anticipation among audiences.

Release at the Right Time

Choosing the right release date can make a significant difference in a movie’s success. A crowded release schedule can make it challenging for a movie to stand out, so producers should aim to release their films during a less competitive time. Holidays and weekends tend to be popular times for movie releases, but it can also be beneficial to choose a release date that aligns with a specific event or celebration.

Utilize Streaming Services

In recent years, streaming services like Netflix and Amazon Prime have become increasingly popular. These platforms offer movie producers and studios a new avenue to generate revenue, as they can sell the distribution rights to their films for a substantial sum. Additionally, streaming services can help movies reach a wider audience, as they are available to watch anytime, anywhere.

Focus on International Markets

The global box office is becoming increasingly important, as international markets now make up a significant portion of movie income. Producers and studios should consider tailoring their movies to international audiences, such as by featuring international actors or incorporating themes that resonate with specific cultures. Additionally, releasing movies in multiple languages can help them reach a broader audience – at lot like what we see being done in the real money casinos industry.

The Bottom Line

In conclusion, maximizing movie income requires a multi-faceted approach that includes a strong marketing campaign, strategic release timing, the utilization of streaming services, a focus on international markets, and consideration of merchandising opportunities. By employing these strategies, movie producers and studios can increase their chances of box office success and generate substantial revenue from their films.

 

How to Succeed as a Construction Business Owner

Owning a construction business can be an incredibly rewarding endeavor. Not only does it mean being your own boss, but it also offers the opportunity to work on everything from small residential projects to large-scale commercial jobs. However, being successful in this field requires careful planning and dedication.

Here are some tips on how to succeed as a construction business owner.

Have a Competent Team

Having a dependable team of subcontractors, architects, and other professionals on your side is essential to running a successful construction business. The right employees are the difference between a slow, inefficient job and a well-run construction project.

Having a competent team starts during the hiring process. When bringing on any new employees, take the time to screen them properly to make sure they’re qualified and capable of doing the job correctly. Then, continuous training is essential for keeping your team up-to-date and informed.

Develop and Follow a Business Plan

Having a detailed business plan is an important part of running any successful construction business. Without one, it will be difficult to track progress and make sure that projects stay on schedule and within budget.

Your business plan should include not only your long-term goals but also how you intend to achieve them. This means outlining the steps you will take to complete projects, how much money you plan on spending, and how long it should take.

Understand Your Clients’ Needs

In order to be successful, it is important to understand your clients’ needs and wants. By taking the time to get a good grasp on what they are looking for in terms of design, function, aesthetic, and cost, you will be able to better meet their expectations. Communication with clients is key; regular check-ins throughout the building process is key to ensuring that the construction project is heading in the right direction.

Finally, being transparent throughout the whole project is essential for building trust and creating a good reputation.

Compliance

A construction site is a dangerous place, so complying with all relevant laws and regulations is for your own good. For example, violating OSHA (Occupational Safety and Health Administration) safety guidelines like wearing the right gear and using the correct tools often leads to preventable accidents and injuries.

Other compliance issues include making sure all permits are up to date and that taxes are paid on time. Not adhering to these regulations means hefty fines and even legal action, so it is important to be aware of the laws that apply to your business.

Marketing

Marketing is a non-negotiable part of running a successful construction business. Word-of-mouth referrals are always great, but having a comprehensive marketing strategy in place is how your business will stand out from the competition and attract new clients.

This could include developing a website, creating social media accounts, or utilizing paid advertising to reach potential customers. It’s also important to invest in branding, as this helps your business create a professional and polished image.

By following the tips outlined above, you will be well on your way to running a successful construction business. With dedication and hard work, you can build a thriving enterprise that is both respected and profitable.

 

3 Tips For Protecting Your Body From Injury At Work

Regardless of the type of job that you’re working, there’s always a chance that you could get hurt while at work. Whether you’re spending your working hours cleaning supporting tanks with on-site nitrogen, moving heavy loads around a worksite, or working in an office setting, there are always going to be hazards that could cause you harm. Knowing this, it’s vital that you learn how you can best protect your body considering the environments that you’re frequently working in.

To help you see how this can be done, here are three tips for protecting your body from injury at work.

Take Care Of Your Body

One of the best things that you can do to protect your body, be it at work or in other environments, is to take care of your body preventatively. The more time and effort you put into getting yourself into strong shape, the harder it will be for small injuries to balloon into bigger injuries.

As a part of this, it’s important that you learn how to take the best possible care of your body while doing the tasks required at work. If you have to lift heavy items, make sure you know the proper ways to use your body and brace the load you’re lifting. If you do repetitive movements throughout the day, spend time learning how to do these things as ergonomically correct as possible.

Keep Hazards To A Minimum

While it’s possible to slip on something at work or get hurt through some kind of accident, most workplace injuries take place due to having workplace hazards that aren’t addressed as they should be. Knowing this, you should do everything in your power to keep hazards to a minimum in the environment where you’re working.

To mitigate these hazards as much as possible, you’ll want to do things like keeping items off of the floor and out of walkways, learning how to properly use any equipment required of you, and fixing or replacing equipment when it is no longer safe to be used anymore.

Wear The Right Protective Equipment

For any job, there are going to be protective equipment that you can use to help protect your body from injury and keep yourself comfortable throughout the day.

For many people, protecting their feet from injury is a major priority, especially if they spend the majority of their day on their feet. Along with this, using ergonomic versions of your equipment can help to ensure that there’s no major pressure points that could cause you harm over time.

If you want to make sure that you’re able to continue working without getting injured on the job, consider using the tips mentioned above to help you learn how you can better protect yourself at your place of business.

Want to Become a Professional Music Producer? Here’s What You’ll Need to do

Whether you’re a skilled musician curious about the music industry or someone who dreamed about becoming the next Dr. Dre, you should know that breaking into the music business as a producer is not as complicated as some people may think. We’re not saying that it’s easy, but there are so many opportunities out there for producers, and if you’re willing to grind, then there is a real chance that you might get a break if you are actually talented. Let’s take a look at what you’ll need to do to become a professional music producer.

Study the Craft

The very first thing we would suggest you do is to pick the type of music you want to produce, check for some of your favorite tracks of the genre and look at how these tracks were made. There are millions of videos on YouTube of people reproducing popular songs, and if the songs you pick are somewhat known, you should find a tutorial on how to reproduce them using common tools.

This will allow you to know if you truly like the process and if you could see yourself doing it. If the process seems exciting and you want to take the next step, you will need to start building a foundation.

Consider Taking Classes

Some music producers came into the business with no or virtually no formal musical education. But, in most cases, music producers, no matter the genre, will have at least a foundation.

If we were to suggest that you learn one thing at least, it would be the keyboard. If you can use the keyboard properly, then you can play virtually any instrument through a DAW and not need anything else. But, if you want to be a master producer, understand a wide variety of tools, and take the guesswork out of the equation, we suggest you get an actual producer course.

You could get an online course for producing on a site like Masterclass, but you could go for something more serious and attend a school like Los Angeles Academy for Artists and Music Production or the Berklee College of Music in New York, for instance. This will give you all the tools needed to make solid and professional-sounding productions.

Get the Gear

You also need to get the startup gear to make your first tracks and to practice. You will need to look at a few DAWs like Fruity Loops, Ableton Live, and Cubase, midi controllers, and an audio interface. You’ll also need to have a computer that can run all of this.

Picking a desktop such as Lenovo PCs for music production will be the logical option here since you’ll most likely be doing most of your work from a fixed location. You’ll also get a much more powerful machine for the price.

Start Building Your Portfolio and Get Representation

The next step is starting to make your own production and posting them online for feedback. YouTube and Soundcloud are all great places for that. Make sure that you have a solid Instagram account and are active too.

You can then use the criticism you get to shape your production. If you notice that people are excited about your music, you can start looking for an agent. You could also close deals directly with artists if some approach you, but you will need to find a music business attorney to draft contracts and protect your intellectual property.

Conclusion

This is really all you need if you want to start a career as a music producer. Everything else is about networking, becoming better, and considering all opportunities, even those that might not look the most glamorous.

 

4 Easy Steps to Make Your Business More Green

The world is rapidly going green, and businesses are starting to change their ways to reflect this new trend. Apart from the benefit to the Earth, this move benefits businesses by helping them save money and increase their customer base. If you’re looking to make your business more green, here are four easy steps you can take.

Use Green Packaging

An easy place to start going green is with your packaging. Using sustainable green packaging solutions helps to reduce your business’s environmental impact and can also be cost-effective in the long run.

Further, it sends a message to your customers that you care about the environment and are taking steps to be sustainable.

You can research different types of green packaging to find the best option for your business.

Here are some options:

  • Paper bags. Paper bags can be made from recycled paper and are often recyclable themselves.
  • Reusable bags. Customers can reuse these bags, which helps to reduce waste.
  • Compostable bags. These bags break down over time, making them a more sustainable option than traditional plastic bags.

Choose Energy-Efficient Electronics

Another way to make your business more green is to switch to energy-efficient electronics. This not only reduces your carbon footprint, but it can also help you save money on your energy bills.

Some energy-efficient options to consider include:

  • LED light bulbs. These use less energy than traditional incandescent bulbs and can last up to 25 times longer.
  • Energy-efficient appliances. Look for appliances with the ENERGY STAR label, which means they meet strict energy-efficiency standards set by the U.S. Environmental Protection Agency.
  • Solar panels. Solar panels can efficiently provide power for your business and can also help to offset your energy costs.

Implement Recycling Programs

Recycling is a great way to reduce waste and help the environment. You can start a recycling program at your business by setting up bins for customers to deposit recyclable materials.

You can also recycle office paper, cardboard, and other materials used in your business. Many communities have programs that will pick up these materials from businesses.

Finally, you can encourage your employees to recycle at home by providing them with information about local recycling programs.

Reduce Water Consumption

Water conservation is another important way to make your business greener. There are many ways to reduce water consumption at your business, including:

  • Fixing leaks. A small leak can waste a lot of water, so it’s important to fix any leaks as soon as possible.
  • Installing low-flow fixtures. Low-flow fixtures use less water than traditional fixtures, and they can help you save money on your water bill.
  • Encouraging employees to conserve water. You can encourage employees to conserve water by providing them with tips and information about water conservation.

Taking steps to make your business more green is good for the environment and can also help you save money. Implementing some or all of these tips can help you make your business more sustainable.

3 Profitable Business Ventures to Consider

A business venture can be the difference between financial security and instability. It can be a great way to generate income, but only if it is done correctly. There are many different types of business ventures that people can pursue, but not all of them are created equal. Some are more profitable than others, and some require less work than others.

If you are thinking about starting a business venture, here are three profitable ones to consider.

Consider the Crude Oil Industry

The crude oil industry is one of the most profitable businesses in the world. It is also one of the most volatile, which means that there is a lot of risk involved. However, if you are willing to take on that risk, you could potentially make a lot of money.

There are different ways to make money in the crude oil industry. You can start a company that invests in oil companies, transports petroleum products, or invests in oil futures.

If you’re considering it, make sure you have the right tools and equipment appropriate to the industry you go into. For instance, if you’re going to be transporting, Lease Automatic Custody Transfer Skids (LACT skids) is essential. Or if you’d rather just invest in oil companies, you’ll need software and apps to research the best companies to invest in.

Look Into Starting a Franchise

Another option for starting a business venture is to look into franchises. Franchises are businesses that are already established and have a proven track record. When you purchase a franchise, you are essentially buying the rights to use the franchise’s name, logo, and marketing materials.

However, one of the downsides of franchises is that they can be expensive to get started. Another downside is that you may have less freedom when it comes to running the business than you would if you started your own business from scratch.

So if you’re considering a franchise, make sure to do your research. Be sure to choose a franchise that you are passionate about and that has a good reputation.

Start an Online Business

If you are looking for a low-risk, low-work business venture, a great option is starting an online business. With an online business, you don’t have to worry about renting office space or hiring employees.

You can run your entire business from the comfort of your own home and keep all the profits.

There are many different types of online businesses that you can start, from selling products to providing services. One popular option is to become an affiliate marketer, which involves promoting other people’s products and earning a commission for every sale that you make.

Still, starting an online business requires some skills and knowledge. You will need to know how to manage a website, please customers, and market.

There are many different types of business ventures to consider. If you are thinking about starting a business, one option to consider is the crude oil industry. Another option is to look into franchises or start an online business. No matter what type of venture you choose, make sure that it aligns with your personal and professional goals.

 

How a Medical Practice Can Find the Right Medical Equipment Supplier

As a medical practice, you must source your equipment most cost-effectively. One way to do so is by finding suppliers that offer a combination of quality and affordable prices for supplies. However, this can be time-consuming and take your valuable time away from treatments and appointments. Fortunately, there are numerous online resources where you can find the best equipment suppliers.

In addition to finding out more about the quality and cost of products, you can also research which suppliers have the most positive reviews. This is a great way to identify companies that offer high levels of customer service and value-added support.

What is the best way to find a supplier you can trust?

By following these tips, you will be better placed to source supplies for your practice.

Bear in mind personal preference

Prioritize your needs and the type of products that you use in your practice. For example, do you need specific items that are not available elsewhere? If so, research potential suppliers and their product range to find the best one for your needs. You should also bear in mind what type of resources would be most beneficial for your practice. For example, if it is to manage patient records or review case notes then an automated system could be the best choice for you.

Survey potential suppliers

This may seem obvious but compare like for like quotes from several potential suppliers. Not only can you get an overview of the prices, product quality, and services, but you will also have access to customer feedback, so can make an informed choice about your medical supplies.

Ask for the best price

You should always start with a blank canvas and ask for quotes. By doing so, you will avoid being stung by hidden extras. Many suppliers offer a variety of prices, depending on the level of service required. Make sure you understand what is included in the quoted price and how long the contract will last.

Join a buying group

You can also consider joining a buying group which will increase your bargaining power. This will enable you to reach an agreement with suppliers on the price, quality, and time of delivery for each product. You may need to sacrifice some flexibility on where you buy the medical supplies as your group may have contracts in place with specific suppliers.

Keep up-to-date

Going to trade shows can be useful in keeping up to date with the latest technological advances or by finding new suppliers that have entered the market. This will help you find suppliers that offer the best rates and identify medical equipment that could benefit your practice. For example, if certain safety features are important to your practice then you can make sure that they are incorporated into the contract. You may also be able to find new products and services which could improve patient care.

The medical practice industry is undergoing rapid change and the market is constantly evolving. To remain competitive, you need to find reliable equipment suppliers that provide quality products at affordable prices. By following these tips and using the right resources, you will be able to source medical supplies that are both effective and cost-efficient.

 

Top Items You Need for a Physically Demanding Job

There are some jobs that require a person to sit in an office from 9 am until 5 pm five days a week. While such jobs are important and fairly common among working professionals, they certainly aren’t the only jobs out there to choose from. Rather, you might want to make a career for yourself in a professional that is more physically demanding than others.

Physically demanding jobs that involve their fair share of manual labor can end up being great positions for some people. They provide important and crucial services for society and for private companies as well. That being said, there are some things to be aware of when you decide to take on a physically demanding job.

For starters, such jobs can really take a toll on your body over time. They will require you to be on your feet for most of the day, engaging in manual labor, a fact that can result in some serious wear and tear.

The good news is that there are a few things that you can do in order to keep yourself in tip-top shape while you work. Here are a couple of items that can help you to keep up with your physically demanding job.

The Right Attire

It is important not to underestimate just how significant the right work attire is for a physically demanding job. Failure to wear the right things at work can result in discomfort or even injury to your person over time.

Start by making sure that you have the right footwear in tow for your job. The company you work for should be able to provide you with some options to choose from, although there are a few tried and true items that tend to work well for certain types of physically demanding jobs.

For instance, those who are on their feet in the great outdoors all day should consider getting some cowboy boots for work. The comfort and support offered by these boots will help to keep your feet protected against the elements and from any sharp objects that you might come across.

A Durable Water Bottle

When your job is a physically demanding one, the importance of staying hydrated all day cannot be overstated. Failure to drink enough water each day can result in extreme fatigue and a higher risk of incurring an injury while on the job.

In order to make sure that you get enough water while at work, it is a good idea to invest in a durable water bottle. Such a bottle should be able to hold enough water to get you through the bulk of your day and be durable enough to stand up against some real wear and tear.

A Yoga Mat

Alright, so you might not be the type of guy who is interested in taking up a yoga practice. That being said, when you have a physically demanding job, it is important that you look after your body. This means having a consistent stretching routine at the start and end of every day. This will help you to avoid injury and keep your muscles, joints, and ligaments safe.

 

4 Reasons You Should Hire a Lawyer for a Legal Issue

Statistically, a very small percentage of people with legal problems actually seek out a lawyer to help navigate the issue. In many cases, people assume that they simply can’t afford a lawyer, or maybe they are just too hesitant to bother taking legal action.

Whatever the reason may be, the numbers show that people who need lawyers aren’t using them as much as they should. Hiring a lawyer to help you solve your legal issue is significantly better than trying to figure it out yourself — here’s why.

They Can Simplify Complex Laws

Laws can be incredibly complex and full of exceptions and clauses. Not all of us have the time or energy to delve deep into legal literature to figure out a legal question. A lawyer can help us understand what a law means and how it applies to our particular situation.

Since lawyers spent years at law school and had to vigorously study to pass the bar exam, they are much more versed in the law than an average civilian. As such, they can be extremely helpful for everyday folks trying to navigate the often complex laws that are not easy for a non-legal-professional to understand.

They Can Save You Money

In many cases, people avoid hiring a lawyer because they assume they can’t afford it. However, in many situations, not having a lawyer actually winds up costing you more. It’s much better to hire a lawyer who can try to make you money by winning your case. Hiring a lawyer can often be seen as making an investment. Although it costs an initial fee, the payoff is well worth it since they can make you your money back and then some.

They Can Help You Avoid Dangerous Mistakes

The legal system can be a slippery slope full of complicated protocol and strict deadlines. Trying to file yourself can lead to a mistake that could ruin the entire outcome of your case. You’re better off letting an attorney handle your legal procedure so that you have the greatest possible chance of things working in your favor.

They Can Negotiate For You

Experienced attorneys know the art of trying to get the best possible settlement for your case. They can use their experience and knowledge to know when it’s best to settle, and when it’s time for negotiation.

Without law school and other legal cases under your belt, it’s likely you have no idea where to begin when it comes to negotiating.

Don’t put yourself at a legal disadvantage. The law is extremely complex and requires proper education and experience to master. Relying on a lawyer to handle your legal issues for you can be one of the wisest decisions you ever make.