Forms

The story of the cutest worst hotel and a sample product liability complaint

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Speak in Sun Valley at Idaho Trial Lawyer Convention in the morning.  Then on a panel in the afternoon. Leave at 3:30.   This means I cannot fly direct to LAX because that plane is gone.  Instead have to fly back to Seattle to then fly to LAX.  Arrive at 10:45 p.m.  Taxi to The Line Hotel.  Arrive at 11:30 p.m.

There’s a reason for the name of this hotel.  There is a line wrapped around it.  Slide through crowd of young people.  Hotel lobby is pitch dark and throbbing with people and music.  I don’t mean the club area to the side of the building.  Or the bar past the front desk.   I mean the actual lobby.  As soon as I walk inside am surround by clubbers.  Which if I hadn’t gotten off an airplane I might have been more pleased with.  But I am a grump.

Wait for front desk to check a woman’s purse so she can dance unencumbered. They give her a bag tag.  My turn finally.  Pretend smile.  Check in process occurs via sign language and reading each other’s lips.  It is too loud to speak.  Go up to 5th floor.  Open door.  Very hip.  Stripped to concrete walls.  Lots of outlets for electronics.  Low slung furniture. Bathroom vanity hits me mid thigh.  Really tall people would have to bend over double to turn on the faucet.   I am 20 years too old for this hotel.  Okay.  Maybe 30. Ceiling to floor window fronts Wilshire Blvd.  The main street.  Look outside.  Can see and hear everyone in the line and every car cruising the strip.   There is also a joint in the road that makes an extra special crunch sound every time a car passes over.

Consider going downstairs to change rooms.  But am too irritated.  The cacophony of sound bounces off the unforgiving gray cell walls.  I look up the white noise station on Pandora.   Waterfall.  No.  Rainforest.  No.  Settle on Springtime showers.   Turn it on via little portable speaker.  It can’t drown anything out.  Pull out  iPhone ear buds.  That doesn’t work.  Pull out running ear buds that fit a little tighter.  That doesn’t work.  Turn up the white noise.  Hello.  Loud white noise is not white noise – it is just noise.   This means that I stay up the entire night.  The party road does tone down around 4 or so in the morning.  But by then I’ve given up.   They are going to get a bad review on Trip Advisor.

Next morning walk from the hotel to Southwestern Law School.  7 blocks away.  It is already 75 degrees.  The school is in a magnificent art deco building.  Take the elevator up.  Am speaking to the National Police Accountability Project.  Spend a delightful three hour morning presenting on voir dire, opening and case themes.  Afterwards one of the attendees asks for a sample complaint.  I write complaints like opening statements.  Filled with details and structured the way that makes the most sense to me.  So here it is.   Complaint FINAL

Photo:  At Southwestern Law School getting ready to speak to NPAP

The origins of my initials and an updated motion to permit skype testimony at trial

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Pick up mom from Shoreline.  It is 58 degrees out and she is in a faux fur black maxi coat with brass buttons.  She bought it for $25.  Half off at the consignment store.  Brand new from Sears.

Take her to late lunch at Din Tai Fung University Village.  Hour and a half wait.  Meet up with my brother Greg and his wife Laurie.  We say forget it.  Go to Boom Noodle.  Eat lunch.  Not as good as Din Tai Fung but quicker.  Greg and Laurie take Nala for doggie sitting play date.  I drive with mom to the movie theater at The Landing in Renton.  My sister Jenny pulls up.  Out jump her boys Ben and EJ.  We eat popcorn and watch Paddington Bear.  Quite delightful.

Movie ends.  Jenny retrieves the young ones.  Take mom back first to get Nala then back to Shoreline.  It is a bit of a haul.  She talks nonstop.  Her memory has been returning.

MFK:  You know when I was in the Bureau of Mines (she was a chemical engineer), I was third in command in case someone had to push “the” button.

K3:  Really.

MFK:   Yep.  At one point, everyone got a promotion.  I was waiting for mine.  I was seven months pregnant with you.  Boss said – well, you’ve got me over the barrel.  If I give you a promotion (and raise) how do I know you’ll even come back.  I said – if you don’t give me a promotion and a raise I will leave right now.  I wasn’t going to let him get away with treating me like that.  Just because I was a woman and it was 1960. Not to mention the Chinese part.   The next day he gave me a promotion and a raise.

K3:  Smile.  (No response necessary).

MFK:  His name was Ken K__ K___.  That’s when I decided if he could live with those initials then so could you.  (Laughing raucously).    Anyway you’re just K cubed.

K3:  (Thinking, ah so there was a scientific reason beyond all of this).  That’s real nice mom.

MFK:  So the next day he gave me the raise.   I had you.  And then a year later we left for Europe (for your dad’s post-doctoral program in Zurich).

Photo:   Mom (Mary Fung Koehler) and I in Switzerland

Motion to permit Skype testimony at trial:  newMtoallowSkype

 

Tips for Attorneys: Injured passenger not liable for possible marijuana use by driver

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Now that marijuana has been decriminalized in Washington state, issues are going to arise about driving under the influence.  Unlike alcohol which only transiently stays in the body and can be detected with various tests, the detection of marijuana is a bit more complicated.

In this case, a van driver  plowed through a stop sign into an intersection without touching his brakes. He smashed into a small car coming from his right.   That car had the right of way.  It had no stop or yield sign.  It was travelling within the speed limit.

During the lawsuit, the defense tried to turn the tables by blaming the plaintiff car passenger for causing the crash.

Even though the car driver did nothing wrong while driving, the defense claimed he reacted too slowly.   They argued that he should have predicted that the van would blow the stop sign and that he should have taken evasive action.  They banked their argument on the finding in his system of a byproduct of marijuana known as carboxy-THC.

At the scene, the police saw no signs of intoxication of the car driver.  Forensic toxicologists determined there was a little carboxy-THC in the car driver’s body.  Carboxy-THC stays in the blood stream for quite a while, even if you are not using marijuana.  The car driver said he didn’t use pot before the crash.

The defense said the plaintiff was at fault because she got into the car with a driver who was under the influence.

My partners Paul Stritmatter, Garth Jones and I, along with co-counsel, proactively brought a motion for summary judgment against the claim that the plaintiff was comparatively at fault.

This defense was ultimately thrown out of court.  Here is the brief: Pl’s Motion for Partial Summary Judgment.

Photo:  Trial Exhibit from the case

Form of the day: client settlement annuity advice letter

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When a personal injury case settles, we are still our client’s lawyer.  This means we need to continue to look out for their best interests until our job is done.  Even if we are not financial planners or accountants, we cannot walk away without first trying to help our client make well informed decisions.  Maybe this is not our legal duty.  But it certainly is our moral one.

During the period of time it takes for an insurance settlement to fund, we should be doing what we can to help our clients make wise decisions.  Particulalry for very large cases involving permanently and seriously injured people.  This can come in the form of referring them to well reputed financial planners, accountants, lawyers versed in governmental benefits, and other professionals.  Sometimes it can involve recommending an annuity or the creation of a trust.

There are times when despite our best efforts, a client will reject all of our financial related suggestions.  We may be worried and concerned for their future.  But our client has the absolute right to do what they choose with their share of the settlement funds. (Except in the case of the infirm or minors).

Once our client decides to decline our advice, it is a good practice, to have them sign a letter acknowledging their decision.  There are two good reasons for this.

First, seeing the letter in black and white may actually result in your client changing their mind and agreeing to some good financial planning.

Second, to make sure there is full disclosure so that you cannot later be blamed.

Enclosed is a form letter and acknowledgment that you can adapt for use when your client receives a very large financial recovery but declines your advice to either structure a portion or work with a financial professional.

Client re Annuity Recommendation.pdf

Photo:  Taken on a sunny deck with several former plaintiffs who made wise financial decisions.

POSCRIPT:

Thanks Karen—

This is really good advice. We have followed this trend rather closely. Clients who have been seriously injured and dissipate their settlements are frequently making claims against their PI attorneys. But the claims go all over the map. Recommending an annuity generates complaints over poor investment performance, lack of flexibility and losses to inflation. Recommending a Trust without the proper trust instrument or reliable Trustee generates complaints about the trust. Giving them a lump sum—which they then spend foolishly generates complaints that the attorney should have known about the clients financial ability.  Another significant issue is the potential loss of government benefits. The main lesson is to take this part of the representation very seriously. Pay as much attention to what to do with the settlement as you do to obtaining the settlement. If you do not feel comfortable advising the clients on this aspect—get someone who is knowledgeable and document it in the file.

Bill

William L.E. Dussault

DUSSAULT LAW GROUP

Why “Honey I did great in trial today” may violate ethics rules – and what to do about it.

RPC1.6-thumb-288x493-21854Lawyers love rules.  Lawyers also tend to be OCD.  Rules + OCD = an intricate, layered, never ending monstrous pile of rules that becomes increasingly difficult to navigate.  The legal profession calls this – job security.

We are equal opportunity OCD rule creators.  We even create rules to govern ourselves.  Some of them are breathtakenly overbroad and impossible to humanly adhere to.

Enter Rule for Professional Conduct 1.6:  “A lawyer shall not reveal information relating to the representation of a client unless the client gives informed consent, the disclosure is impliedly authorized in order to carry out the representation, or the disclosure is permitted by paragraph b.”

This language is based on the newest model rule.   This goes way beyond what I learned in law school.  We were taught never to divulge confidences or secrets.  Well, that is only the half of it.

The Washington State Bar Association recently published an article written by Jamila Johnson.  She explained if a technical reading of the rule is correct, lawyers cannot mention anything about a case to anyone.

I’ve attended many continuing legal education programs put on by bar associations.  All of them feature lawyers talking about cases.  So I guess they better stop having CLEs.  Or change this rule.

Until then, here is a form letter I am sending to each and every one of my clients now and in the future.

Formclientsecretsletter.pdf

Table – from the WSBA news article:
http://wsba.org/News-and-Events/Publications-Newsletters-Brochures/~/media/Files/News_Events/Publications/Bar%20News/2012%20Full%20Issues/201211NovemberBarNews.ashx#page=13of64

 

Tips for attorneys – the story of the palm reader and my trial checklist

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My mother brought a 73 year old palm reader to Thanksgiving dinner.

Mom:  I want to bring my friend Ed.  He is really bright.  He is an attorney and a palm reader and I share my energy with him.

Me: Mom, I have already set the tables for 27.  We do not have room.  I don’t have any plates left and had to get extra silverware from the office.

Mom:  (guilt tripping me) I never bring anyone.   He doesn’t have anywhere else to go.

Me:  (guilt tripped yet again) Ok mom, that’s fine.  But tell him no palm reading.

Ed shows up late.  With a suspicious looking briefcase and a box of chocolates.  We have already finished our dinner.  Mom makes him a plate.  He is a nice, jovial fellow.  As soon as he’s done eating, he starts reading people’s little fingers.

I’m trying to ignore all this.  Am in another room.  Noelle comes in and says that he has declared that Ben (my 6 year old nephew) has paranormal capabilities.  Oh great.

Mom corners me.  He really wants to give you a reading Karen.

I’m busy mom.

She bides her time.  Corners me 15 minutes later.  I sigh.  Walk to the living room.

Okay Ed, I say with a smile.  Read away.

Sit down on the couch next to him.  Mom perches on the chair across from us.  With a flourish he whips open the briefcase.  Pulls out a magnifying glass just like the Pink Panther uses.  Puts on a large pair of spectacles.  Holds my little finger under the glass.  Shines a flashlight (where did that come from).  Quite the show.

You are very very honest, he says admiringly.

Well, that’s good, I say.

He is studying my little finger.  Turning it this way and that.  Hmming and Hawing.

Yes, you are very honest.  You also…

He looks intently into my eyes.

You also live in the moment…you aren’t a planner.

I smile.  Well, actually Ed, I do live in the moment but I am also a planner.

Hmmm.  He says.   Let me see your little finger again…

Ed is actually quite wrong.  Trial lawyers are planners.  Our ability to act in the moment stems from our painstaking preparation.

Preparation isn’t optional.  It is essential.  In Washington we have fairly strict pretrial discovery rules.  If we don’t disclose witnesses, evidence, and opinions on time, we can be barred from using them in trial.  This may vary  depending upon the judge.  But why take the risk.

Here is the most current version of my trial checklist.

  • Court paperwork
    • Trial brief
    • Jury instructions uncited emailed and hard copy
    • Jury instructions cited emailed and hard copy
    • Anticipated pocket briefs
    • Joint statement of evidence
    • Evidence notebooks
    • General voir dire

 

  • Voir dire
    • Neutral statement of the case
    • Tracking chart
    • Key topic outline
    • Key points  from focus group
    • If possible – heads up juror information
    • Scissors (recommended when re-seating jurors during preemptory process)

 

  • Liability
    • Incident reports
    • Incident documentation
    • Standards, rules, codes
    • Written witness statements
    • Recorded witness statements
    • Photos
    • Video
    • Animations
    • Story boards/Visualizations
    • Poster boards of key visual evidence
    • Models
    • Physical evidence
    • 30b6 deposition designations
    • Party deposition designations
    • Original depositions for filing
    • Perpetuation deposition videos with edits per court’s rulings on objections
    • Identify all lay witnesses who will be testifying
    • Identify all expert witnesses who will be testifying and their opinions
    • Impeachment material

 

  • Damages
    • Photos/video of plaintiff before incident
    • Photos/video of plaintiff after incident
    • Relevant preincident medical records
    • Relevant post incident medical records
    • Medical bills and Medical bill summary
    • Xrays, MRI, CT films
    • Medical animations
    • Medical Diagrams and charts
    • Wage loss documentation
    • Life care plan report
    • Economic report
    • Life expectancy analysis
    • Poster boards of key visual evidence
    • Physical evidence
    • Original depositions for filing
    • Perpetuation deposition videos with edits per court’s rulings on objections
    • Identify all lay witnesses who will be testifying
    • Identify all expert witnesses who will be testifying and their opinions
    • Impeachment material

 

  • Equipment
    • Projector and screen (get preapproval from Bailiff)
    • Projector stand
    • Ipad loaded with all exhibits and deposition transcripts via an app
    • Laptop
    • Laptop stand
    • Remote Clicker for laptop
    • elmo
    • speaker
    • computer cords
    • Post its
    • Easel
    • Butcher paper
    • Pointer or laser pointer (if using television instead of projector need old fashioned pointer)
    • Powerstrip
    • Painters tape
    • Permanent marker pens in several colors
    • Thumb drive

Photo:  John setting up trial equipment in King County Superior Court September 2012.

 

Form of the day: Defense Medical Exam Agreement

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Some of the richest doctors no longer practice medicine.  Instead they make up to half a million dollars a year, working for insurance companies.  Their assignment:  examine injured plaintiffs with a jaundiced eye.  Then proclaim they should be cured in 60 to 90 days.  Sometimes a little longer.

About five years ago, there was a mean retired neurosurgeon who said a  mother was paralyzed and in a wheelchair because she made up the injury in her mind.  He called it “hysterical paralysis.”   Made for a good defense.  Of course in reality, she’s still paralyzed today.  Apparently the hysteria hasn’t ended.

Defense exams should not always be agreed to.  “Good cause” must first be shown by the defense.  Schlangenhauf v. Holder, 379 U.S. 104 (1964).

Justice Tom Chamber’s  concurrence In re Detention of Williams, 147 Wn.2d 476 (2002), lays out the constitutional concerns but also talks about the realities:

Aside from the constitutional concerns, an examination by an expert hired by the opposition is rarely a desirable experience. Examinations can be financially, physically, and emotionally demanding. Parties are often required to take considerable time away from work or other activities, to travel inconvenient distances to the expert’s office, and to wait significant amounts of time to be subjected to questions and questionnaires posed by experts suspicious of their answers and motives. Examinations often involve unwanted touching, poking, and twisting, causing discomfort and indignity. All done pursuant to a written order of a judge vested with the authority of the State. Such extreme exercise of judicial power should only happen upon a most stringent showing of necessity. Id. at 498.

When I started practicing, I worked for Justice Chambers who was then simply “Tom”.  He routinely made me go down to the courthouse and fight against all defense medical exam requests.  I usually lost.  But almost always succeeded in having the court impose conditions.

Over the years my list of conditions has changed as the examiners have become even more sophisticated, jaded and mean (the truth will set you free).  Defense lawyers would rather not have to bring motions and so they tend to agree with this extremely, reasonable, nice, kind and proper agreement.

Here is the standard stipulation letter for a defense medical exam: DME Ltr form k3.pdf

Photo:  Clip from the Preparing your Client for a DME Exam DVD 2012 Trial Guides.  Co-Produced by Guenther Prod and Yours Truly.  Patient – my friend, lawyer Ed Moore.  Doctor – my friend, lawyer and chiropractor Aaron DeShaw. 

How to turn in a bad driver

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We can do more than file a lawsuit when a bad driver hurts our clients.  We owe it to society to get those drivers off the road.

State licensing departments have simple forms that can be filled out to trigger an investigation.  They don’t publicize these but they exist.

Here is the form for Washington State.   dol.pdf

Next time someone runs down your client in a crosswalk, feel free to use it.

Tips for Attorneys: direct exam of a treating physician

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Outlines serve a purpose.  They just shouldn’t be relied upon to the exclusion of the rest of what is going on in a courtroom.

This general outline has been in my repertoire for 20 years.  My former boss, Tom Chambers, developed it.  I have barely changed it.  I use it as a reminder.  As a guide.  Not as a script.

 

Sample.  Outline direct examination treating health care provider (mix and match order)

Background

  • Name
  • Address
  • Occupation
  • CV

First visit

  •   Date
  • What is your understanding of treatment  plaintiff received following the incident and before s/he saw you
    • Did you perform an exam
    • What were significant findings
    • Initial diagnosis
    • Definition injury
    • History of incident
    • Development of pain/disability

Course of care

  • Reasonable
  • Necessary
  • Improve with care
  • When was last appointment

Mechanics of injury and causation

  • How did the incident cause injury
  • After trauma can injury cause:
    • Physical limitations
    • Degenerative changes
    • Susceptibility to future problems in area
    • After last appointment what was prognosis in terms of reasonable medical probability
    • Reasonable to expect plaintiff would suffer continuing symptoms requiring continuing treatment to this day on a more probable than not basis from acc.

Pre-existing condition

  • If plaintiff had previously injured ____, but had not had medical care or symptoms for almost __ yrs before the incident, would it be fair to say that the injuries were caused by the incident

Medical expenses

  •   Are you familiar with the costs of health care in this community
  • Show bills:  Have you had a previous opportunity to review the medical expenses.
  • Were the health care services provided to plaintiff reasonable
  • Were they necessary
  • Were the health care bills charged for those services reasonable and customary in the medical community
  • In terms of reasonable medical probably, do you have an opinion as to whether or not the medical conditions and symptoms of plaintiff which you have testified about today were caused by the incident?
  • Wage loss
    • I’d like you to assume that immediately following this incident, plaintiff missed work for ____ (or was unable to return to work).
    • Would you have an opinion as to whether or not the time off work (or inability to return to work) that I just described is a reasonable period of convalescence for plaintiff as a result of the incident.
  • Future losses
    • Can you detail the future medical care that plaintiff will require?
    • What is the cost of that care?
    • Can you describe future limitations of plaintiff
      • Daily life activities
      • Need for care or assistance
      • Recreational
      • Work
      • Emotional and interpersonal
    • Have you met with NAME, vocational counselor/life care planner
    • Did you provide information to that individual to assist in creation of a life care plan
    • Did you review the completed report – do you agree with the medical portions of that report
    • Future medical risk factors or complications
    • Loss of life expectancy

Final opinion re causation

In terms of reasonable medical probability, do you have an opinion as to whether or not the plaintiff’s medical conditions and symptoms were caused by the incident of DATE?

Social Networking Warning Letter Form for Clients

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When plaintiffs file lawsuits, the defense insurance companies hunt them down on the internet like criminals.

The plaintiffs’ fun, fellowship, and joy of connecting with others through Facebook and Twitter; is instantly smashed to pieces when they find out they are being spied on.

But many people don’t know that their harmless wall posts, photos, and video clips, are being amassed into an arsenal to be used against them.

In one of our cases, a 20 year old woman was almost killed when a car crossed the center line and hit her car.  She suffered a terrible brain injury and to this day must live in a nursing home.  Her mother kept her Myspace page active.  Even though her daughter couldn’t use Myspace anymore, it was a way to keep in contact with her daughter’s friends.  The defense attorneys pretended to be friends to try to get into the site.  When that didn’t work they subpoenaed Myspace to get at the records.  They were digging for dirt, even though the young woman was not at all responsible for the wreck.

My paralegal John Meyers and I developed this form letter for our clients.  Please feel free to use and share it:

Social Networking Site Letter.pdf

 


Check out a recent interview by Super Lawyers about my blog. Yes, I'm a lawyer. But I'm also a human being. I have a doggie named Nala, three daughters, eat brown sugar cinnamon pop tarts for breakfast, and wear jeans as often as possible when not in court.
Favorite Quotations

If you talk to a man in a language he understands, that goes to his head. If you talk to him in his language, that goes to his heart.
— Nelson Mandela


Be still when you have nothing to say; when genuine passion moves you, say what you've to say, and say it hot.
— D. H. Lawrence


Why slap them on the wrist with a feather when you can belt them over the head with a sledgehammer.
— Katharine Hepburn


Truth, when not sought after, rarely comes to light.
— Oliver Wendell Holmes, Sr.


Hold fast to dreams For if dreams die Life is a broken-winged bird That cannot fly.
— Langston Hughes


There is no charm equal to tenderness of heart.
— Jane Austen


Words have no power to impress the mind without the exquisite horror of their reality. — Edgar Allan Poe


If you just set out to be liked, you would be prepared to compromise on anything, wouldn't you, at any time? And you would achieve nothing! — Margaret Thatcher


Be who you are and say what you feel because those who mind don’t matter and those who matter don’t mind.
— Dr. Suess


Be sure you put your feet in the right place, then stand firm.
— Abraham Lincoln


If you are neutral in situations of injustice, you have chosen the side of the oppressor. — Desmond Tutu


True eloquence consists in saying all that is required and only what is required. — La Rochefoucauld


No act of kindness, no matter how small, is ever wasted. — Aesop


The thing you fear most has no power. Your fear of it is what has the power. Facing the truth really will set you free. — Oprah Winfrey


If you're not failing every now and again, it's a sign you're not doing anything very innovative. — Woody Allen


The soul never thinks without a picture. — Aristotle


To thine own self be true, and it must follow, as the night the day, thou canst not then be false to any man. — William Shakespeare


Float like a butterfly, sting like a bee. — Muhammad Ali


Intelligence is the ability to adapt to change. — Stephen Hawking


It is better to have less thunder in the mouth and more lightning in the hand. — Apache proverb


People take different roads seeking fulfillment and happiness. Just because they're not on your road doesn't mean they've gotten lost. — Dalai Lama


How wonderful it is that nobody need wait a single moment before starting to improve the world.
— Anne Frank


Learn to laugh; it is a discipline to be mastered. Let go of the everlasting burden of always needing to sound profound. — Richard J. Foster


Imagination is more important than knowledge. Knowledge is limited. Imagination encircles the world. — Albert Einstein


Believe, when you are most unhappy, that there is something for you to do in the world. So long as you can sweeten another’s pain, life is not in vain. — Helen Keller


Remember that lost time does not return. — Thomas á Kempis


If thou faint in the day of adversity thy strength is small. — Proverbs 24:10


Everybody gets so much information all day long that they lose their common sense. — Gertrude Stein


It is harder to crack a prejudice than an atom. — Albert Einstein


The right of trial by jury shall be preserved. — 7th Amendment of the U.S. Constitution


I'd rather die on my feet than live on my knees. — Ludacris


And the trouble is, if you don't risk anything, you risk even more.
— Erica Jong


Words are chameleons, which reflect the color of their environment. — Judge Learned Hand


You may shoot me with your words, You may cut me with your eyes, You may kill me with your hatefullness, But still, like air, I'll rise. — Maya Angelou


The moment that justice must be paid for by the victim of injustice it becomes itself injustice. — Benjamin Tucker


He who keeps his eye on results cannot give himself wholeheartedly to his task, however simple or complex that task may be. — Howard Thurman


An eye for an eye makes the whole world blind. — Mahatma Ghandi


Life is painting a picture, not doing a sum. — Oliver Wendell Holmes Jr


The truth does not change according to our ability to stomach it emotionally. — Flannery O'Connor


We must adjust to changing times and still hold to unchanging principles. — Jimmy Carter


To be rooted is perhaps the most important and least recognized need of the human soul. — Simone Weil


It is not the level of prosperity that makes for happiness but the kinship of heart to heart and the way we look at the world. — Alexander Solzhenitsyn


It is high time that the ideal of success should be replaced by the ideal of service. — Albert Einstein


The opposite of love is not hate, it’s indifference. The opposite of art is not ugliness, it’s indifference. And the opposite of life is not death, it’s indifference. — Elie Wiesel


I don’t know the key to success, but the key to failure is trying to please everybody. — Bill Cosby


The time is always right to do what is right. — Martin Luther King Jr.


I had rather attempt something great and fail, than to attempt nothing at all and succeed. — Robert Schuller


It is very easy to break down something. You can take a stone and throw it through that window; that is easy. Try fixing it, and that takes longer. It takes longer to help someone who has been broken. That’s the work you’re doing. — Desmond Tutu


How we spend our days is, of course, how we spend our lives. — Annie Dillard


Mine honor is my life; both grow in one; Take honor from me, and my life is done. — William Shakespeare


To straighten the crooked you must first do a harder thing – straighten yourself. — Buddha


A thought is an idea in transit. — Pythagoras


Fall seven times, stand up eight. — Old Japanese proverb


No generalization is wholly true, not even this one. — Oliver Wendell Holmes Jr.


Of what use is eloquence? He who engages in fluency of words to control men often finds himself hated by them. — Confucius


There is a vitality, a life-force, an energy, a quickening that is translated through you into action and because there is only one of you in all of time, this expression is unique. — Martha Graham