The Insurance Maze, Tough Clients, and Prevalent Sexism in Personal Injury Practice

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From LawHub, this is I Am The Law, a podcast where we talk with lawyers about their jobs to shed light on how they fit into the larger legal ecosystem. In this episode, Debby Merritt interviews a veteran personal injury lawyer who specializes in vehicle collisions.

Debby Merritt:

I'm talking today with Tricia Dennis, a graduate of the University of Tennessee College of Law. Tricia has represented accident victims, has recovered more than 4 million total for her clients, and has even written a book to help clients cope with the legal side of auto accidents. She also has some provocative television ads that we'll hear later. Let's start with an overview of your practice.

Tricia Dennis:

I am completely, at this point, on my own. I have an extraordinarily able legal assistant and I have one part-time person that does the difficult organizing of files.

Debby Merritt:

What type of cases do you handle?

Tricia Dennis:

Almost exclusively personal injury, some medical malpractice. Although, Tennessee changed their medical malpractice law. That makes it a little more difficult to bring them, so I don't handle as many as I used to.

Debby Merritt:

So in addition to those few medical malpractice cases, what types of personal injury are we talking about?

Tricia Dennis:

Some, what we call, trip and fall or slip and fall, but we're primarily talking about car wrecks. And vehicle collision wrecks would probably be more accurate because you have to divide those into typical two automobiles getting into a collision, or tractor trailer rig. Completely different animal with a different set of rules. But we do have quite a few of those because here in Chattanooga, we are the junction of three interstates. Up until about two years ago, I also did workers' compensation under Tennessee law. That was what us lawyers here in Tennessee would look at is sort of bread and butter work. You wouldn't get particularly rich on it, but it would keep your doors open. And then through tort reform, Tennessee really radically overhauled their system in 2013. But the problem is with tort reform, it's not just getting to the lawyers, it's hurting ordinary people who work for a living and particularly the worker comp is just absolutely devastating.

Debby Merritt:

Why did you decide to focus on personal injury work?

Tricia Dennis:

I think it was partly a bit by default. Secondly, it's kind of fun. I can't imagine ... The other kinds of law one might do, such as wills and estates, I wouldn't be very good at it and it would put me to sleep. Transactional law, I'm just not the type that's going to enjoy rich people. Nothing against rich people, but that would just not be my kind of thing.

Debby Merritt:

You said a minute ago that it's fun. What makes this area of law fun?

Tricia Dennis:

You get to try cases sometimes. I mean, I'm down to where I only try maybe one case a year or two cases a year, but that is always fun. You get to be sassy kind of. But it's fun in that when you're doing personal injury, you're also doing a little bit of medicine and you're doing a little bit of bioengineering. I have a slip and fall that I've been working on today, working on what we call a demand for settlement. This client's a great client. He came into a store to buy his little kitties some cat food. And I assure you if I could attach a YouTube video of kittens to this demand, I would do it. He saw a big sign that said "Cat Food, 3 for $1. And of course, you don't have quite the same comparative fault standard in a grocery store that has signs competing for your attention to "look over here, not down at your feet."

Tricia Dennis:

He took a step forward. Someone had left a piece of cardboard from stocking some shelves and he slid on it, and he has three compression fractures in his vertebra. And he's had to have what's called a kyphoplasty, so I had to look into a kyphoplasty. That's where they essentially put cement in your vertebra. Now when looking at his medical records, he went to several different doctors. One would describe this injury initially as acute, then it got to be subacute, then it got chronic. And those are real red flag words. So then I had to start looking at how a compression fracture occurs. Well, you get into biomechanics. You get into, essentially, engineering.

Debby Merritt:

It sounds like there's a great combination here of just stories about people. The man who loves his kitty and wants to get cat food. But then with that, the science, the fun of intellectually looking into what causes these injuries.

Tricia Dennis:

If you are going to maximize damages, you have to maximize every little nugget in your case. And that does involve doing research, thinking about, "How am I going to show the insurance company I can demonstrate to the jury why a fall like this would crush his vertebra?" How you approach a case ... and everyone has different philosophies ... but my philosophy is you are telling a story. If you go to trial, you really are something of a Broadway producer. You're going to put on a play, and a play is nothing but a story.

Debby Merritt:

You mentioned that you only go to trial about once or twice a year.

Tricia Dennis:

Now.

Debby Merritt:

Now.

Tricia Dennis:

That was not the case when I started out.

Debby Merritt:

And was that because your caseload has changed or because the courts have changed?

Tricia Dennis:

It was because when I started out, I was a woman and I was the new kid on the block. I was going to have to try most things. The offers that I would get would be so minimal. And obviously, and actually, my caseload is vastly expanded from when I started out. But at that time here in Chattanooga, I was maybe one of three ... I might still be one of three women plaintiff lawyers. But there weren't very many of us, and so it was constant testing. But now, obviously I've been around for a long time. Some of the adjusters I deal with are the same ones I dealt with three months ago.

Debby Merritt:

So they know you're serious and that you'll go to trial if you have to.

Tricia Dennis:

If you want to avoid war, you've got to show that you're ready for thermonuclear war. You have to be very exacting, very detail oriented. And when you're dealing with the insurance companies, those demands, no mistakes, no margin error. You just don't have it.

Debby Merritt:

Let's walk through a typical case. You have a client who contacts you and arrives for an initial consultation.

Tricia Dennis:

If they get an office appointment, chances are they have a viable case.

Debby Merritt:

How do you do that initial screening?

Tricia Dennis:

My paralegal, Judy, is amazing. If somebody says, "I was in a car wreck and I want to come see Ms. Dennis," Judy will say, "Well, tell me a little bit about your problem." And they'll say, "Well, I was going down Highway 64 and I tried to avoid a bunny rabbit and I ran into a telephone pole." Well, they're not going to get an appointment. The next one will say, "Well, I was driving my car and another car came over into my lane, and we had a head-on collision." "Okay, do you have insurance?" "No, I don't have any insurance." About 40% of Tennesseans have no insurance. "Well, have you heard from the other insurance company?" "Well, he doesn't have insurance either." Well, they're not going to get an appointment. There's no money there.

Tricia Dennis:

But here, we have somebody saying, "I was on Gun Barrel Road," that's a big road here, "and I came to a stop and the car behind me didn't and rear-ended me." "Well, who's your insurance?" "Mine's Liberty Mutual." "Have you heard from the other insurance company?" "Well, yeah. They're State Farm." "Well, come on in." Now, we know that at least we have liability. There's no question of liability. So they'll come in and fill out paperwork, some forms, and I'll go meet with them, look at the police report, and I'll say, "Now, let's start at the top of your head and let's work down, and let's talk about how you're feeling." And I use that approach because most of the time they might have gone to the emergency room.

I don't even have to look at the ER record to know what happened. It's not because I'm a wizard. It's just that I know they will have gone to the ER, "I was in a wreck. My neck hurts. My back hurts." They're going to get an x-ray, they're going to get some muscle relaxers, they're going to get some lortab. Hospital will say, "Goodbye. Good luck. Go see a primary care physician. Much of the time because Tennessee also has a high rate of uninsured people. And we did not take the Medicaid expansion of the Affordable Care Act, so at least 50% of my clients have no health insurance, which means they have no doctor to go to. So I know they haven't gotten a thorough exam and we'll start talking about, "Well, where do you hurt?" "My neck hurts. My shoulder hurts." "Well, tell me about your shoulder." Because one of the things you'll see in a rear-ender, if it's an impactful enough, is a torn rotator cuff, particularly if they're of a certain age.

"Well, I can't lift my arm above my shoulder." Well, right there, we may have a rotator cuff problem. You go on down and you get the history. "Have you made neck complaints, back complaints? If I get five years of your past medical records," because the insurance company sure will want it possibly, "what am I going to see?" We go over that, and then I say, "We are going to get you to a doctor." And I have a physician that I work with who is, let me stress, very independent. I would want him to be independent. He does not say what I want him to say. I do not send my clients to chiropractors. In fact, I tell them, "If you go to a chiropractor, I will not represent you." But I send them to this medical physician and I know he's extraordinarily thorough. And what he does, even though they don't have insurance to give him, I know there's going to be money here.

Debby Merritt:

Right.

Tricia Dennis:

So they will sign an assignment with him, and he charges a little bit more to cover the fact that he's going to have to wait on his money. And he'll check them out and if it looks like it's just a neck or back strain, the next step is they'll go to physical therapy. And I explain to them why you have to go to physical therapy. That's because, first of all, it's going to make you feel better. But second, physical therapists take wonderful notes. They take wonderful data. They can talk about, "The trapezius muscle is spasming today," because you can't fake a spasm, and that's objective data that a jury really likes. "We like you going into physical therapy, Client, because we're going to get a lot of great data." The second reason we like you going is because a jury is going to take your injury more seriously if you went through the time, expense, and inconvenience of going to physical therapy three times a week for three or four weeks.

Debby Merritt:

You're both helping the client and preparing for possible trial or settlement negotiations at the same time.

Tricia Dennis:

Always. Always. And my philosophy is if you get the medical in place, if you make sure your client is getting the proper medical care, the case tends to fall in place. And one of the things we have to tell the client ... because they don't like going to physical therapy because darn it, it is inconvenient ... is, "You need to understand. Every time you don't go to physical therapy, it's like you're opening up that spigot and letting money run out." Then, you have some clients who like to go too much. They may have heard on the street, "Oh, if you run up your medical bills, you're going to get a whole lot more money." Well, no. Your lawyer will get a lot more money and the physical therapist will get a lot more money. But you'll be lucky to walk out of my office with $500 because we have to pay these people back.

Debby Merritt:

You mentioned, before, the demand letter and how important it is to get that right.

Tricia Dennis:

Yes.

Debby Merritt:

Could you explain where that comes in the process?

Tricia Dennis:

So my client will call up, will tell Judy, my paralegal, "Hey, I'm through treating. I finished. Had my last physical therapy visit." Well, that's our queue. At that point, we probably have already gotten in their ER records or whatever else they had. And that's where we get in the final doctor notes, we're going to get in the physical therapy records, we get in all the bills. And that process takes a month. A month later, I sit down, go through it. "Please set this letter as a demand for settlement in the amount of," and it will be an absolutely unreasonable amount of money. Let's say they have $7,000 in medical bills, which might not be unreasonable. Well, I'll start out at $25,000. Now, I'm not going to get within shouting distance of $25,000, but you have to start out fairly high. Never so high that the adjuster just gets offended, but certainly never low where you find yourself negotiating against yourself.

Debby Merritt:

I remember years ago ... Remember Robert Bork, the conservative judge?

Tricia Dennis:

I do. Unfortunately.

Debby Merritt:

Yes. But remember, he slipped and fell at the Yale Club of all places.

Tricia Dennis:

Oh!

Debby Merritt:

He did. He hurt his leg, I think, fairly badly and sued for $1 million dollars.

Tricia Dennis:

Are you serious?

Debby Merritt:

Oh, absolutely.

Tricia Dennis:

How did I not know that?

Debby Merritt:

He settled the case, ultimately, for an undisclosed amount.

Tricia Dennis:

I hope it was $3,000. I'm sorry.

Debby Merritt:

I know. It's a great example of how people are critical of the personal injury system until it happens to them.

Tricia Dennis:

And I find that all the time.

Debby Merritt:

Tricia, let's get back to the demand letter for your client with the $7,000 in medical bills. So far, you've told us that the letter starts with the demand for an amount much higher than that. What comes next?

Tricia Dennis:

You point out the liability and you use a lot of action words. You always, always write in the active voice. I mean, I really do think that makes a difference. And I have my own little technique. I never say the insured's name. I dehumanize them. I say, "Your insured. My client was proceeding down Gun Barrel Road and when traffic slowed to a stop, she stopped lawfully. However, your client, ignoring the traffic before him, rammed," you use those kinds of words.

Debby Merritt:

Rammed, that's a good one.

Tricia Dennis:

"Rammed into the back of my client's small Hyundai Elantra." So you write like that, and I don't know if it makes a difference or not, but it gives the adjuster an idea of how this lawyer is going to present this to a jury. The kind of words, the action words that the lawyer is going to use because adjusters are supposed to use some independent judgment. So you talk about liability and then you get to medical history. "When the crash occurred," and you use words like "crash" and "collision." It's never an accident. When you teach your students, if they use the word accident, wrap them on the knuckles. It's never an accident. It's a collision. It's a crash.

Debby Merritt:

A catastrophic event.

Tricia Dennis:

Oh, yes! Now, my dear Hamilton County jurors here in Chattanooga might not know what a catastrophic event is, but they sure would know what that is up in the more enlightened frosty north. And I don't mean to be ridiculous about it, but you're advocating, so you use words of advocacy. So then, you go to medical history. "When the crash occurred, my client immediately felt burning pain in her neck or in her back." Then you go on and you talk about ... Some of my colleagues do not get this involved, but I discuss each and every doctor visit.

Debby Merritt:

It sounds to me like you put as much effort and creativity into writing these demand letters as many lawyers do for an opening argument.

Tricia Dennis:

But I'm trying to demonstrate to the insurance adjuster that we're going to impress the jury, that there's medical research behind why you hurt after being rear-ended. A simple demand's going to run probably about three pages. And then at the end, you do the demand. "In light of the foregoing, we're demanding this utterly unreasonable amount of money. This demand shall remain open for two weeks. Thereafter, we'll file suit. I look forward to your thought." And we all know that I'm not going to file suit at that exact 14-day mark. I might have one every 18 months where they just mess around so much, I do finally file suit. But that doesn't happen very often. So the adjuster will call back and say, "Here's my really unreasonably low demand." I don't even tell my client about the first offer. And I tell my client, "I'm not going to tell you about the first offer. It's just going to annoy you. It's going to be so low it's just going to upset you. There's no point to it."

Tricia Dennis:

In Tennessee, the average verdict is about 1.1x the medical bills. And if I can't get 1.5x, I'm real disappointed. State Farm will come back with, let's say, $10,000 or $11,000, and that's where the second writing is. If I give the client a rejection acceptance memo. Because frankly, negotiating for a settlement offer is not the hard part. The hard part is educating your client. You want your client to focus on the math of the case. You want your client to forget what Uncle Louis said about his neighbor who had a hangnail and got $5 trillion from Geico. Because of the drumbeat of, "We need tort reform," clients think, "Well there's these out of control juries. I'm now hurt, so I ought to get $50,000 for this relatively mild soft tissue injury," and you really have to knock the stars out of their eyes. The way I do that is they have to review jury verdicts for their particular injury. Say if it's Georgia, they get to see Georgia jury verdicts. If it's Tennessee, Tennessee jury verdicts. They have to review those and they see all those zeros, where people got zero money from a rear-ender.

Debby Merritt:

Wow.

Tricia Dennis:

Or 1.2 times. They have to look at that memo, which is about six pages long. It can be a lot of reading. Sometimes, I have to read it to my clients.

Debby Merritt:

So the client has a memo explaining to them, in their particular case, what the pros and cons are.

Tricia Dennis:

Right.

Debby Merritt:

And you've also put it in the context of overall recoveries, including zero verdicts.

Tricia Dennis:

Then you go on to say, "Okay, remember you signed a contract that said not only do I get one-third, I get whatever it costs to go to trial. I get that reimbursed. This is what I estimate it will cost to try your case." Let's look at this. If you go to court and you get 4x your medical bills, after we deduct all of this, are you any better off?

Debby Merritt:

Sure.

Tricia Dennis:

What's the settlement equivalent? They have to sign off on this. At the end of that, it says, "I want to accept State Farm's offer of $11,000," "I do not want to accept State Farm's offer of $11,000." But either way, they have to sign. The reason I do that is it takes the emotion out of it. I explain to them, "It's math." And it allows me to say, "I want to do whatever you want to do. My job is just simply to educate you."

Debby Merritt:

If you don't mind, I'd like to ask you a little bit about the economics of your own practice. You're really ...

Tricia Dennis:

Hard.

Debby Merritt:

Hard. You're really a small business owner in addition to being a lawyer. Is that right?

Tricia Dennis:

I would put small business owner before lawyer.

Debby Merritt:

Okay.

Tricia Dennis:

I think that's really important for anybody contemplating going to law school in this present-day climate that says, "If it doesn't work out, I'll just hang out a shingle." Don't approach it that way because you are a small business owner before you're anything.

Debby Merritt:

Can you give me a sense of what your office expenses are?

Tricia Dennis:

Well as a matter of fact, I thought you'd might ask that, so I pulled out the tax return that I just filed. Last year, I grossed ... this isn't what I settled for cases, this is what I took in as what we call legal settlement income ... about $325,000. But to put that in perspective, before people think, "Oh, I'm going to be rich." No. I spent $140,000 of that on advertising alone. Postage alone was $2,100. I only tried one case last year. Case expenses were almost $25,000. Wages are about $65,000, so you can start doing the math. My office is a very nice office, but it's not in a glass and steel high-rise. My rent's about $1,200 a month, which is pretty good for Chattanooga, and I'm in a suburban area. Out of what sounds like a pretty juicy figure. I'm lucky if I get to keep a third. Obviously, if I didn't have to have that advertising, I'd keep more.

Debby Merritt:

But advertising clearly matters a lot for you.

Tricia Dennis:

You cannot make money in this business without cases. You cannot get cases unless you are advertising. It is not possible. The advertising lawyers are putting out of business the lawyers that have been here even longer than I have, that you would think have a client base.

Debby Merritt:

What's the type of advertising that pays off best for you?

Tricia Dennis:

I've tried several types. At the end of the day, television is what works the best.

Debby Merritt:

Tricia, I happen to have here a link to one of your ads that's on YouTube. I haven't seen it myself yet, but I'd like to play it for our listeners and myself, and then hear your reaction.

Ad (Client #1):

I've been injured in a car wreck and I need the insurance company to pay all of these bills. I need help.

Ad (Tricia Dennis):

I'm attorney Tricia Dennis and I can turn your car crash into lots of cash.

Ad (Client #2):

Trish helped turn this car crash into all this cash.

Ad (Client #3):

There's my crash. Here's my cash.

Ad (Client #4):

Tricia got me my cash.

Ad (Tricia Dennis):

If you've been injured in a car crash, I'll get you all the cash you deserve.

Ad (Client #5):

Call Attorney Tricia Dennis, the appointment's free, at 892-5533

Tricia Dennis:

It takes tackiness to a new low. This is now the state of law practice in America. I was not the original lawyer in my area to have a jingle.

Debby Merritt:

And it works. I take it that you run the ads because then people respond and they come to your office.

Tricia Dennis:

The amount I cited for last year, $140,000, I think I was spending about $12,000 a month. I've now almost doubled that. I'm up to $20,000. And to meet that obligation along with my other obligations, I have to sign up at least six cases a month, about 72 a year. That's probably about all a one-lawyer office could handle properly. I mean, you can do the math.

Debby Merritt:

Out of the 72 cases, there may be a few that wash out a large number that will settle, and then just that one or two that go to trial.

Tricia Dennis:

When you're spending that kind of money, you have to choose your cases very, very, very carefully. You cannot take just what comes in the door ever because you're throwing money away on it.

Debby Merritt:

So Tricia, you said you've been spending about $20,000 a month now on advertising. Does that buy you one ad a week? An ad a day?

Tricia Dennis:

I think that is getting me around 45 or 50 a week. That does not count what we call overnights, where you kind of get them for free. I advertise only on the broadcast networks. No, I'll take that back. We are now advertising on TBS. But for the most part, all of the money goes into broadcast. Cable does not work very well because the audience is just too splintered.

Debby Merritt:

Let me ask you, based on that. Do you think we have too many lawyers? Is that part of the problem here?

Tricia Dennis:

Is that a trick question? It is a profound, profound problem, at least in this state. It is a very serious problem.

Debby Merritt:

Part of why the advertising is getting more intensive and it's costing more for each lawyer.

Tricia Dennis:

Well, there's no question that's part of it. And I don't want to sound like I've got mine. Where I think the trouble really comes and where the impact of too many lawyers is much more profound is, for instance, I'm 59 years old. I've been doing this for a long time. Someone my age, we should be mentoring young kids who either by choice or by circumstances are not getting big firm jobs, what passes for a big firm in Tennessee, or not going to government work. We should be mentoring these people, but we can't.

Tricia Dennis:

I mean, there is no way I could mentor a young graduate from UT simply because I cannot train my competition. But I cannot stay in business and have somebody else learn my business model, and then compete against me. Now, when I was starting out in 1987, it wasn't quite so bad. It was beginning to get there, but it wasn't quite there. I was mentored by a mean son of a bitch, but he knew how to teach me how to practice law and he was willing to do it. I look back and realize he was really sacrificing quite a lot in doing that.

Debby Merritt:

Interesting.

Tricia Dennis:

But he could do it because there were still enough cases that I wasn't going to hurt his business. I think that is one of the saddest outcomes because, quite frankly, I cannot imagine practicing law any other way but having your own little firm and building something. I'm sure for some people, big firm life is great. But particularly for a woman, sexism, believe me, is still alive and real in law. But for somebody trying to raise a family, having your own little firm is the great way to do it.

Debby Merritt:

I wanted to ask you, actually, about sexism in the law. We are, it happens, exactly the same age. I turned 59 yesterday.

Tricia Dennis:

Happy birthday!

Debby Merritt:

Thank you very much! And we started practicing law during the same era. I certainly remember being a novelty and facing skepticism from clients and other folks that I interacted with. Was it any different in Tennessee?

Tricia Dennis:

You started in Ohio, right? Or did you start in Illinois?

Debby Merritt:

I actually started in Atlanta.

Tricia Dennis:

Ah! Well, okay.

Debby Merritt:

In terms of practicing law.

Tricia Dennis:

Where in Atlanta.

Debby Merritt:

I was with a firm. It was then called Bondurant, Miller, Hishon, and Stevenson.

Tricia Dennis:

Okay. We call it God and Spalding up here. King and Spalding.

Debby Merritt:

Oh, no, no, no, no. I was at the law firm, Tricia, that sued King and Spalding in the sex discrimination case.

Tricia Dennis:

That's wonderful. You did the work of God.

Debby Merritt:

That's right, because no other firm in town would take the case. We represented Betsy Hishon.

Tricia Dennis:

Well, good for you because they really got hung on that, if I recall.

Debby Merritt:

So Tricia, have your experiences changed?

Tricia Dennis:

We're now into the 21st century. I'm not sure it has markedly changed. But I will say when I first started out ... and I can say this because he's dead now. I had a federal magistrate say to me ... and this was probably around '89 or '90, something like that ... "Trish, I like you all right. But women have absolutely no place in my courtroom." He said it!

Debby Merritt:

I hear stories like that from my students here in Ohio today.

Tricia Dennis:

Particularly the women. If you're young, probably whether you're good-looking or not good-looking, you're going to get hit on. There's always those wolf lawyers. Inevitably, they're going to hit on you. Thankfully, I'm old enough and mean enough that it doesn't happen anymore. But particularly in my middle years, if I beat a male lawyer in the courtroom, there were a few that took it really personally. I mean, offended. It is though you had and were attacking their manhood I think they kind of look at me like, "You're taking food out of my kids' mouths. Why don't you go home and let your husband support you?" I think that attitude is still ...

Debby Merritt:

Or, "Go do some nice pro bono work."

Tricia Dennis:

Yeah. Or, "Why can't you do that guardianship stuff? We don't want that."

Debby Merritt:

Right.

Tricia Dennis:

I don't want to imply that it is as bad as it was when I started out, but it's still very, very much alive. You have to learn how to be extremely tough. Learning how to cuss and use all those words that your mother told you not to use is a very important part, believe it or not, of your toolbox.

Debby Merritt:

That's exactly what I had to do when I started teaching the criminal defense practice.

Tricia Dennis:

Well, that's interesting.

Debby Merritt:

You wouldn't believe how I can cuss, Tricia.

Tricia Dennis:

I'm glad to hear another woman say that because ...

Debby Merritt:

It's just the way people talk in the courthouse.

Tricia Dennis:

But it's not just that. It's how you get their attention that you're crossing a boundary.

Debby Merritt:

Right.

Tricia Dennis:

It's, "Wow. Gosh, she must be really pissed off."

Debby Merritt:

It's what you told us earlier with the adjusters. They have to understand that you mean business, and that may mean being overly aggressive and tough for a little while until they get that. We've talked about advertising and we've laughed somewhat about jingles and so forth. But at the end of the day, the people that you represent are people who have been injured. They have real injuries. We've talked about the fact that you wouldn't take their cases if they didn't have injuries.

Tricia Dennis:

No. I know very few lawyers that would.

Debby Merritt:

It doesn't make any economic sense.

Tricia Dennis:

No.

Debby Merritt:

And we also know that the middle class today, let alone the working class that's less than middle class, they're living on the edge. They don't have extra money. So if you're injured in a car crash and you have these medical expenses, what do you do?

Tricia Dennis:

I've got one guy who is a cook. His elbow got shattered. What's he going to do? He wasn't making that much money. He can't go back to work. They had to put pins in his arm. He's out for the next four or five months. He's not going to have a job to go back to. You hit a chord when you approach it from working people who are already on the edge, they have no cushion. I don't get calls from the rich part of Chattanooga. I don't get calls from those people. I get calls from very ordinary people who are so on the edge. Nevermind three weeks, three days without a paycheck is going to tip them over.

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