00:00:00:00 - 00:00:00:14 Sandra when I 00:00:00:14 - 00:00:08:02 Sandra told them how I resolve this, I heard the you did what? Yeah. And I said, I did, I did it was the right thing to do. 00:00:08:02 - 00:00:17:11 Sandra Yeah. I figured out a way that it was appropriate. And I thought that the board was appropriately using the association funds, I think was a learning moment for all of us. 00:00:17:15 - 00:00:38:02 Speaker 1 Welcome to the uncommon area where we're dedicated to reimagining ways. We provide board members and managers with the resources to create uncommon communities where residents love their HOA and truly love where they live. 00:00:38:03 - 00:01:03:22 Speaker 3 Welcome to the Uncommon Area. I am Matthew Holbrook, and in this episode, we dive into strategies related to resolving conflicts in homeowners associations. Sandra Gottlieb of the law firm Subtle Sun, and Gottlieb joins us again in the uncommon area to talk about these different kinds of strategies, including the nuances related to IDR, to mediation and arbitration. 00:01:04:04 - 00:01:08:18 Speaker 3 And I think that it's a really helpful episode. And so I hope that you check it out. 00:01:09:14 - 00:01:11:02 Matthew Welcome back again, Sandra. They were, 00:01:11:02 - 00:01:15:03 Matthew tackling another episode. Appreciate you being in the in area again. 00:01:15:08 - 00:01:17:15 Sandra Thanks so much. I appreciate being here. Thanks for the invite. 00:01:17:21 - 00:01:31:04 Matthew Well, we're going to talk about fighting in this episode. And in particular, we're going to talk about how an association addresses conflict specifically with respect to conflict between the association and homeowners, 00:01:31:04 - 00:01:41:17 Matthew So to launch into this topic, maybe you can outline what are some of the common things that you see where an association has conflict with homeowners or residents in the community. 00:01:41:17 - 00:02:06:12 Sandra Short term rentals and restrictions, because owners believe that this is my property, I should be able to do what I want with it. Noise nuisances do something about it. You're my landlord in their mind. And, harassment where people are actually harassing each other. And the fact that this is now once again, an association problem, not just a neighbor to neighbor dispute. 00:02:06:12 - 00:02:21:09 Matthew Right. And I would add into your list, architectural issues seem to be a place where there's there's a lot of conflict. And so when we talk about conflict in an HOA, for managers who would be listening to this podcast, 00:02:21:09 - 00:02:30:00 Matthew I think what comes to their mind, at least pretty quickly, would be ADR and maybe some of the more, experienced board members might be familiar with that. 00:02:30:02 - 00:02:35:06 Matthew So talk a little bit about what is ADR, and how does that apply to resolving conflict. 00:02:35:08 - 00:03:02:05 Sandra So ADR stands for alternative dispute resolution. And that can be comprised of a couple of different elements. Internal dispute resolution, where we try and deal with a internal matter between an association and an owner. Less formally, but in a place where we're face to face and that qualifies as zoom to zoom. Alternative dispute resolution normally refers to mediation or arbitration. 00:03:02:11 - 00:03:27:18 Sandra And those are two very distinct things. Mediation. Nobody makes a decision for you or on behalf of the association. The decision can only occur if the facilitator we also call the mediator between the two parties, have a commonality that they can get both parties to agree to, and then they together can agree on a decision to be bound by. 00:03:27:20 - 00:03:42:01 Sandra That's different than arbitration, which is, I call it litigation light. Although a serious arbitration. And you have to prepare for it like you were going to trial, but you have a third party or a panel of third parties, 00:03:42:01 - 00:04:15:05 Sandra Depending on how big the issue is deciding the issue for you. And it is binding on the associations, I'm going to play my hand right here and that is I am not a fan of arbitration for associations. I have associations who have gotten stuck with picking up maintenance responsibilities, governance responsibilities. That was not the association's obligation in its governing documents or statute, but was agreed to in the arbitration because they thought they had to. 00:04:15:05 - 00:04:41:08 Matthew All right, let's break that down. You've put a lot on the table here. Maybe from a big picture. When we talk about mediation versus arbitration, mediation is always non-binding. You have somebody who is functioning to facilitate, resolution between two parties. So we'll come back to that. Arbitration could be non-binding or binding. Generally, when we talk about arbitration, we're talking about binding arbitration. 00:04:41:10 - 00:04:47:12 Matthew So we'll we'll come back and maybe break that down. But everything I've said is right so far. So far okay. Haven't gone off the rails just yet. 00:04:47:12 - 00:04:48:20 Sandra Not quite. 00:04:48:22 - 00:04:51:14 Matthew So with mediation, 00:04:51:15 - 00:04:52:10 Matthew I guess 00:04:52:10 - 00:05:17:03 Matthew my input and starting off on this is, a good mediator is bringing a very specific and valuable skill set to the table. It's not just somebody who's going to hear two sides and kind of relay information back and forth, but is actually going to skillfully work with two different parties to bring about some common ground that they can agree to, to, to resolve their, their differences. 00:05:17:05 - 00:05:40:15 Sandra And I think that's an excellent way to look at it, because instead of looking at it as just us and them, some having somebody that could address the commonality and come in to deal with the issues from that is the starting point, really makes people less abusive to each other during the mediation process. And more likely to give in on points that are really not important to them anyway. 00:05:40:21 - 00:05:56:15 Sandra They're just collateral, and they're hanging on to those points. As you said, the skillful mediator can hone in on that when they're meeting with each side. Come up with those points, use them for and against each party as to trying to get traction to come to an alignment on issues. 00:05:56:15 - 00:06:20:00 Matthew Yeah, the in and the key to that is the mediator is not necessarily reaching a conclusion as to who's right or wrong. They're just trying to bring about some form of agreement. I've been in situations in mediation where, the mediator has they'll, they'll put usually they will put the parties in different rooms and kind of go back and forth between the rooms. 00:06:20:02 - 00:06:39:14 Matthew And I've had a mediator come into, my room before and say, hey, I understand the case that you're making the people in the other room, they are going to be completely unreasonable on this. And, and and you're probably right, but they're not going to move. I've talked to them for a while. I know that they're not. 00:06:39:16 - 00:06:57:08 Matthew Now, here, your options based on this, this reality, here's how you can think about how to move forward and weighing out the pros and cons on that. And even in that, I found that to be helpful because the mediator is not coming in saying, okay, you're right, they're wrong. And you when they're saying, okay, here's where everybody's standing on this. 00:06:57:10 - 00:07:02:14 Matthew Now, here's how to think about how you move forward and what the what the best choices are. And I think that's helpful. 00:07:02:16 - 00:07:21:17 Sandra I think it's really helpful. I think it's a good strategy for the mediator, and it helps our association boards of directors to really understand. We're not going further than this because they're not going to accept, what we're what we want to put on the table. But in the scenario that you described, that's the moment that I would say if I was in the room. 00:07:21:19 - 00:07:40:14 Sandra Are you going to put together a mediators proposal to try and resolve this? Because to a certain extent, and I'm not saying you said this Mr. and Mrs. Mediator, but to a certain extent the other side is not being reasonable. You're the reasonable one in the room and many times they will but many times they won't really. 00:07:40:14 - 00:07:50:06 Matthew And my experience is almost always at some point, usually later in the day, they'll put together some type of a mediators proposal, and usually that does help get some traction. 00:07:50:06 - 00:08:01:09 Sandra I think it almost always does, even in big construction cases. Yeah. When we get stuck, there can be a mediators proposal that will really assist people to get to a resolution. 00:08:01:11 - 00:08:08:03 Matthew So mediation, costs something. And usually that's a shared cost between the parties. 00:08:08:03 - 00:08:12:20 Sandra Correct. It's a statutory issue and it's some states it's just a governing document issue. 00:08:12:23 - 00:08:23:22 Matthew Okay. Now mediation is generally voluntary in the, in under ADR. Is it a required step that an association take. 00:08:24:02 - 00:08:41:18 Sandra Will have to refer. I'm sorry, to a specific state here in California, it is required, if an association receives a demand for mediation, that the association participate. If it's in reverse and the association makes a demand on the owner, the owner is not obligated to engage. 00:08:41:18 - 00:08:47:02 Matthew So in the first case where the association is obligated, is is still a shared cost for the mediation. 00:08:47:02 - 00:08:48:13 Sandra It is still a shared cost. 00:08:48:13 - 00:08:49:22 Matthew Okay. 00:08:49:22 - 00:08:55:01 Matthew when we're talking about mediation, how does it fit into this discussion? 00:08:55:03 - 00:09:25:03 Sandra So ADR happens first. I say that IDR should be taken seriously by our boards. Maybe we can resolve the issues, but it also helps us know what's going to happen in mediation. And just as I look at mediation as not a waste of time, because at the very least, I'm going to engage in free discovery in the mediation, I can extrapolate from a good IDR where people are actually engaged, information that the owner may not realize or a board may not realize that they're giving. 00:09:25:09 - 00:09:38:00 Sandra But I will be able to see there's a way forward here. Let's take a few minute break. I'd like to talk to each of you independently, and because I heard where each one was willing to go, but they weren't able to say it to each other now. 00:09:38:00 - 00:09:38:11 Matthew So in this 00:09:38:11 - 00:09:42:01 Matthew scenario that you're talking about, the eye is literally you, Sandra. 00:09:42:01 - 00:09:42:18 Sandra Right, right. It would. 00:09:42:18 - 00:09:46:23 Matthew Be. And so the association can have legal counsel present for IDR. 00:09:46:23 - 00:09:50:06 Sandra Correct. And so can the homeowner in some states. 00:09:50:06 - 00:10:13:09 Matthew Okay. So just from a definitional standpoint, so that everybody listening understands IDR is where you are having the conflict, being addressed by both parties, the homeowner and the association, without anybody else mediating, judging. It's just a conversation between the two where both parties potentially could be represented by legal counsel in this conversation. 00:10:13:09 - 00:10:17:15 Sandra Correct. So the only thing I do want to say to our board members 00:10:17:15 - 00:10:34:18 Sandra that are listening is if they are told that the owner is going to have legal counsel present for the IDR, I think from a corporate governance standpoint and for the board to meet their fiduciary duties, they should have association legal counsel attend that internal dispute resolution as well. 00:10:34:20 - 00:11:01:03 Matthew So to put it more directly and bluntly, an association should never enter into a discussion regarding a conflict with a homeowner who is represented by counsel. If the association's not represented by counsel. Correct. So let's move to arbitration now. So you go to mediation and, the association spends the money, the homeowner spends the money, and the conflict is not resolved. 00:11:01:03 - 00:11:15:15 Matthew So maybe to to back it all the way up. You start with IDR an individual conversation without a mediator, without a judge, without anybody else there, maybe the attorneys. There's no resolution. You go to mediation, you have a mediator who helps. There's no resolution. Now you moved to arbitration. 00:11:15:14 - 00:11:16:22 Matthew if the conflict still exists. 00:11:16:22 - 00:11:17:17 Sandra Right. 00:11:17:23 - 00:11:25:14 Matthew Now, I actually don't know the answer to this. What's the difference between non binding arbitration and mediation? 00:11:25:15 - 00:11:59:02 Sandra Very little. Okay. The difference that I would say is that an arbitrator is normally always, a retired judge where a mediator could be a judge or a seasoned attorney, usually in litigation or in their particular skill set. And they may have more tools in their tool chests to bring to the table to force the resolution by being able to point to examples, whether it's on the association side or the owner side, you're never going to prevail in this issue. 00:11:59:04 - 00:12:00:22 Matthew Yeah, okay. That's helpful. 00:12:00:22 - 00:12:03:22 Matthew But most of the time when we're talking about arbitration, we're talking about 00:12:03:23 - 00:12:05:02 Matthew binding arbitration. 00:12:05:02 - 00:12:09:01 Matthew And essentially the way I've always thought about this is 00:12:09:03 - 00:12:20:22 Matthew it is a it is litigation with streamlined, processes and no jury. It's a single judge who is making whatever decision is going to be made. 00:12:20:22 - 00:12:23:03 Matthew And then you have to abide by that decision. 00:12:23:05 - 00:12:46:11 Sandra Correct. The thing that I do want to point out is in that scenario, just as you described it, what's missing is your right to appeal. So in litigation, you lose. At the trial court, you can appeal to the Court of Appeal. They got it wrong in the trial court. Even if we assume everything in the trial court was correct, the ultimate resolution of the judge or jury was incorrect. 00:12:46:11 - 00:12:55:09 Sandra We have the right to be heard in a court of appeal. You don't have that right in almost all arbitrations unless something really horrendous occurred. 00:12:55:15 - 00:13:06:05 Matthew Okay. If there is and maybe this is state specific again, but if there is a conflict and you go through ADR, and then you go to mediation, 00:13:06:05 - 00:13:15:07 Matthew and the homeowner wants to process or the association wants to press on the issue, there is an obligation on both parties to to go forward to arbitration. 00:13:15:09 - 00:13:39:02 Sandra It is going to be state specific. In California, we take the position that mediation will satisfy the alternative dispute resolution and requirements. So it's not like IDR mediation, arbitration. You have to do all three. IDR is in its own class. You have to do that. And then it's mediation or arbitration. So it's. 00:13:39:04 - 00:13:39:10 Matthew Either. 00:13:39:10 - 00:13:40:10 Sandra Or. It's either. 00:13:40:12 - 00:13:41:02 Matthew Okay. 00:13:41:04 - 00:14:00:23 Sandra Unless you have documents that require both or you are in a state that requires both. I know some in the Midwest and some on the East Coast. They do have states that require you to go through both. They're need to call it alternative dispute resolution. It's different lingo, but it requires you to go through all these steps because the courts are trying to keep you away. 00:14:01:01 - 00:14:12:08 Matthew Yeah. So let's talk about California just as an example on this. So you go to you do ADR, you do mediation. There's no resolution to the conflict. 00:14:12:08 - 00:14:38:11 Matthew If a homeowner is the one pursuing the issue at that point, the homeowner has the option of, of pursuing litigation against the association. Does the homeowner have the right to compel the association into arbitration in that scenario, or, does the homeowner have the option of pursuing arbitration? 00:14:38:11 - 00:14:40:22 Matthew It only if the association agrees. 00:14:40:23 - 00:15:17:17 Sandra So I do believe that unless a state requires you to to engage in arbitration or the documents are drafted in such a way, that arbitration is required, there is no vehicle by which the homeowner can make the association go through arbitration. After mediation. We have a case, in California, Pinnacle Museum Plaza. And that is a case that is, important because it had a provision that required all construction defect matters to be dealt with via arbitration. 00:15:17:20 - 00:15:47:05 Sandra So the entire construction industry was involved in watching how that case resolved. And the court in that case said it stands. The document said, in big, bold language, if there's a construction defect issue, the parties are going to arbitrate them. They are not going to litigate them. And when that decision came down, it really changed things in both the construction industry and in homeowners associations. 00:15:47:07 - 00:16:11:22 Matthew Interesting. So when we're talking about arbitration, you detailed that, there is, an inability in most cases to appeal a decision made in arbitration. I alluded to the fact that there are certain processes in the arbitration that are more streamlined. Can you, maybe give some examples of what that might look like? 00:16:12:00 - 00:16:36:21 Sandra Is shorter time frames? Okay. You know, it could take you filed a complaint in California. There's 30 days to respond to the complaint or to demurrer. There's lots of other vehicles for motion that can delay the litigation process. When you agree to arbitration, you are agreeing to a specific timeline that's going to be established by the arbitrator and agreed to by the parties. 00:16:36:23 - 00:16:41:00 Sandra And so it moves things along, in a much quicker pace. 00:16:41:02 - 00:16:48:09 Matthew So that really speaks to what the advantages of arbitration are in that it moves faster and usually costs a lot less. 00:16:48:11 - 00:16:53:02 Sandra Right. I'm stuck on the part that you don't get to appeal if the arbitrator gets it wrong. 00:16:53:06 - 00:16:54:23 Matthew Okay. But those are kind of the pros and cons. 00:16:55:03 - 00:16:55:23 Sandra Of the pros and cons. 00:16:56:04 - 00:17:09:16 Matthew So when we talk about, litigation, what are the things that an association should consider if they reach the stage where litigation is the only answer to resolving a conflict, what should a board be thinking about? 00:17:09:18 - 00:17:43:09 Sandra Well, they should have already thought about tendering to their carrier, if they are on the receiving line of the complaint, they should also think about tendering to their carrier. Or if we have the opportunity for what I call a notice tender, we're telling you about it. But don't start defending us. So if the association anticipates when they filed the lawsuit, that there's going to be a cross complaint against the association, we want to make sure that the insurance companies that are protecting the associations and their interests know something is coming. 00:17:43:15 - 00:18:11:18 Matthew So just to be, really clear here, let's use an example. That this is an architectural issue, that somebody has built something, on their property that they did not get architectural approval for. And the association is not willing to give approval after the fact. The homeowner says, deal with it. And there's ADR, there's mediation. You go through the process and the association says, okay, now we have to pursue litigation to get this issue addressed. 00:18:11:20 - 00:18:38:05 Matthew The association then is initiating the litigation in that case. And there is probably not a scenario where just based on that, that there is going to be coverage from an insurance standpoint if the association is initiating. Your point, if I'm understanding you correctly, is that opens the door for a class complaint for which there could be coverage. And so even if you're the initiator, you still put your insurance carrier on notice. 00:18:38:06 - 00:19:05:03 Sandra If you believe the facts will provide the basis for a cross complaint, aka speak to your association attorney about it to make certain that we take advantage of that. Why is that important? If we know that's coming, we want to save some of the costs of our discovery until the cross complaint has been filed, because insurance defense counsel will need to address a lot of the issues the association will need to address on its complaint. 00:19:05:05 - 00:19:26:22 Sandra And certainly it is more financially beneficial for an association to have their insurance defense counsel doing that work than their legal counsel, who is the initiator of the complaint. I'm not suggesting that the association's counsel can stop working. I'm just suggesting that we think forward how to best protect the association and its interests. 00:19:27:00 - 00:19:35:09 Matthew So, know, it's interesting. I hadn't really thought about that before. But if you are an association and you're the plaintiff in a claim. 00:19:36:08 - 00:20:03:07 Matthew You are incurring the legal costs to pursue that claim. But if the, if the defendant then files a class complaint that could initiate defense coverage, and now the association has essentially, two different attorneys representing the association on the same matter. One is the plaintiff, one is the defendant. And the association in that case wants to push as much of the work as possible to the defense side whenever there's crossover. 00:20:03:09 - 00:20:04:09 Sandra Well, I'm hoping that 00:20:04:09 - 00:20:09:14 Sandra This, podcast is not shared with the insurance industry, but yes, of course, that's exactly what I'm saying. 00:20:09:16 - 00:20:12:07 Matthew Okay. Interesting. All right. 00:20:12:07 - 00:20:27:18 Matthew the ideal scenario is that an association does not have to go down any of these roads, and you don't have conflict. What are some things that, you might suggest that an association do or pursue to minimize the potential for conflict. 00:20:27:21 - 00:20:55:17 Sandra Listen to what somebody is saying. I don't believe that homeowners realize, how much work boards spend on running the association, even when they have professional management, like action, because they are responsible for the association. And there's many things that they can delegate pursuant to an applicable state law and the governing documents and anything that they can't. Management of the structure in the facilities is one of those delegate acts. 00:20:55:19 - 00:21:29:01 Sandra So listening to what the owners are saying and letting them know here are our limitations in being able to address your issues we had in 2020 for an issue the most unfortunate issue two owners made dueling accommodation claims. The owner on the top floor was the mother and the child. Both had severe asthma smoke within 100ft of them and they really are housebound much of the time, can cause either of them to wind up in the emergency room. 00:21:29:03 - 00:21:51:05 Sandra The unit directly below them was a woman who had terminal ovarian cancer and was smoking pot 24 hours a day. At doctor's request, those two people were at each other all of the time. The board came to me. I said, those are both viable accommodation claims. We need to get into the room with both of them, and we did. 00:21:51:05 - 00:22:24:02 Sandra And ultimately we were able to learn that the mother and daughter had another place that they could live in, which became an issue when the owner downstairs said, I'm actually in hospice. So we had a definable period of time where there's these competing interests. Were there, the association assisted and I approved it, even though it's not a normal association expense, a contribution to the mother and the child to be able to move themselves to this other place for a period of time. 00:22:24:02 - 00:22:37:22 Sandra It turned out to be three months. And then the association also contributed to the cleanup of the common area components from the smoke odors, so that the mother and the daughter could move back into their unit. 00:22:37:22 - 00:22:51:02 Sandra What that taught me is not just assuming that ADR and mediation is where we stop off on the way to litigation, and I've been doing this a long time, and I just really learned this lesson last year. 00:22:51:05 - 00:23:00:02 Sandra Look at each step of the journey as an independent action that the board can engage in to really attempt resolution with their homeowners. 00:23:00:10 - 00:23:29:19 Matthew Yeah, that's a great example. I think that there's there are a lot of principles that come out of that. If I can maybe just throw out a few. First of all, I think a lot of times boards are paralyzed by the concern of acting, in a way that's going to set a precedent. I groan when I hear board members talk about their concern about precedent setting. 00:23:29:21 - 00:23:46:15 Matthew Because it's very rare that you have two identical situations that come up. And I think you can define situations without that. But I could envision that in this scenario, a board looking at this saying, no, we can't contribute funds to help move them because then we'll have to do that for somebody else. And we're setting up. You're never going. 00:23:46:17 - 00:24:10:14 Matthew Hopefully it's the situation you just described would be an exceedingly rare dynamic. There are lots of one off exceedingly rare dynamics and I think an association has room to, act reasonably in those situations without fear of setting a precedent. So that would be one of a few things I would I might take out of that. 00:24:10:14 - 00:24:33:17 Sandra So I want to address that before you tell us what else there. Sure. And that is, we know what association funds can be used for. And, moving somebody out is not one of those one of those things. But I was able to work with the board and say the amount of money we're going to save in litigation is in the tens of thousands of dollars, multiples of that. 00:24:33:18 - 00:24:54:05 Sandra Yep. And the small amount of money we're going to pay to resolve this issue in the short term. The woman below who was smoking, she couldn't do anything about it. Her doctor said she was on as much morphine as they could give her without putting her in a coma. There was nothing she could do. And this is something that I believed. 00:24:54:07 - 00:25:06:20 Sandra Once she disclosed that she was in hospice, I thought that the board should know that I was going to, as corporate counsel, condone it and gave them the vehicle by which they could reach that resolution. 00:25:06:21 - 00:25:27:03 Matthew And that was going to be my second point was, there are practical considerations in lots of scenarios where you weigh out what's going to be the most financially beneficial route to take, and clearly what you just articulated. It would be true in the situation, it would be much less expensive for them to take that route. And so, 00:25:27:04 - 00:25:39:18 Sandra But it's novel. Yeah. It's novel. So art lawyers meet every 7 to 10 days and we do a zoom, and we talk about what new opinions that we worked on. Did anything new come in? What happened with such and such case? And 00:25:39:18 - 00:25:48:04 Sandra when I told them how I resolve this, I heard the you did what? Yeah. And I said, I did, I did it was the right thing to do. 00:25:48:04 - 00:25:57:17 Sandra Yeah. I figured out a way that it was appropriate. And I thought that the board was appropriately using the association funds, I think was a learning moment for all of us. Yeah. 00:25:58:03 - 00:26:05:14 Matthew Well, it brings me to my third and will be the last point that I highlight that I'm taking out of this particular example. And that is, 00:26:05:14 - 00:26:15:15 Matthew I think there's always a place for recognizing the humanity of a situation. And what you just described is, is a horrific human reality, that two different, 00:26:15:15 - 00:26:18:19 Matthew people or families were, were living with and dealing with. 00:26:18:19 - 00:26:30:07 Matthew And for each of them, that would be such a significant situation that they're just trying to figure out how how to how can they survive or get through this situation. And, 00:26:30:07 - 00:26:49:11 Matthew I'd like to see boards and I love to hear as an attorney that there, there is some consideration in, in that type of a situation to say, how can we act as humans and maybe there's not a very specific, paint by numbers approach for how the association can spend money in this situation. 00:26:49:11 - 00:26:58:23 Matthew But let's find a way that's going to be the right financial decision for the association, can be justified and can be respecting the humanity of the people who are dealing with a really, really hard situation. 00:26:59:01 - 00:27:00:12 Sandra And that's why I said I learned from it. 00:27:00:12 - 00:27:25:10 Matthew Yeah, I think it's a it's a great example. Well, I think in, in highlighting, that example further, it just it, it indicates the importance of actual communication, not just people yelling at each other. There's a lot of education of, of boards, education of homeowners preemptively on what, the association is trying to do in different situations. 00:27:25:12 - 00:27:32:09 Matthew And all of that can, can move towards, minimizing the risk of having these conflicts that can escalate. 00:27:32:11 - 00:27:33:11 Sandra I agree. 00:27:33:13 - 00:27:41:19 Matthew Well, Sandra, again, thank you so much for a really interesting episode. And, I think that board members will find this just really, really helpful. So thank you. 00:27:41:20 - 00:27:43:07 Sandra Thanks so much. Thanks for having me. 00:27:44:13 - 00:27:51:14 Speaker 3 Well, I appreciate Sandra and her expertise and input regarding this topic of conflict resolution. 00:27:51:14 - 00:28:00:11 Speaker 3 I'd encourage you to like and subscribe to the uncommon area and tell somebody else who might also benefit from the content of this podcast.