OZ 00:00

hit record Just so you know, though I don't know how much information you have, but the way we're doing it is I'm not going to take notes at all, we're just going to be using, like an online thing to transcribe the recording. So, yeah.

SM 00:18

Let me know if you have any problems, because my internet connection is not that great, but um, hopefully it'll hold up.

OZ 00:24

Okay, sounds good. You're, um, you're in Mexico City at the moment?

SM 00:27

Yes.

OZ 00:28

Nice, That’s awesome. Ok, so. I am going to first, just to get out of the way, read you the confidentiality statement. Just so that you know. So, our conversations not legally privilege, and we will not keep what you say confidential. We plan to make transcripts and recordings for interviews available for use by future researchers and the general public and portions may be posted online or discussed in posts on our website or other published writing. I want our conversation to flow freely. And I realized that you may discuss a sensitive topic or mention a piece of information that you later realize you would like withheld. So, if you request it now, at the end of the interview, or later on after, we are happy for you to review the transcript of the conversation before it's made public, and you can redact any portions you deem necessary from the transcript.

SM 00:01:24:

Ok, cool.

OZ 00:01:25

Umm so, I guess one thing, just to start off, I want to hear, to begin with about your experience with the Bronx Defenders and the kinds of cases you were bringing um. But I think it is important, um because I feel like I'm really curious about the work you're doing. But we also want to emphasize um that the purpose of the project is to kind of understand more about like your experience lawyering during this time.

OZ 00:01:51

Mhmm.

SM 00:01:52

And like what it was like bringing these cases um and working um with clients and for you personally, to the extent that you're comfortable talking about that um. So, I guess the specifics of litigation are important and interesting insofar as it has a bearing on that so, um. Yeah, um I hope that makes sense. ((OZ and SM smiles))

SM 00:02:07

Yeah.

OZ 00:02:09

And yeah, I guess I'm just to just to begin with, like, what kind of work you were doing, I understand it was habeas petitions or habeas adjacent stuff, so I don't know if you'd like to talk a little bit about that first. ((OZ smiles))

SM 02:18

Sure. So, I can just start up really briefly, I worked at the Bronx Defenders for about five years. And for the first three years, I was just doing um removal defense through this universal representation program, we have in New York City called the New York Immigrant Family Unity project, which provides access to counsel for, you know, indigent, non-citizens, or are alleged ((smiles)) non-citizens, who are in removal proceedings after (Detained) Immigration court in New York City. Um and that’s funded by the City Council in the Mayor's Office. Um, so, the the nice thing about that, I mean, there's a lot of great things about that program. But, you know, because it's a universal representation model, there's no screening for, kind of, there's no merit sort of at least screening, so, we just represent everyone. So that really gives you, people who work in the program, a pretty expansive view of what's happening in the New York detention center—New York and New Jersey detention centers. And then for my, sorry, the following two years on centers, I did more individual federal litigation, which, as you mentioned, involves mainly habeas petitions. We kind of explore during the time of COVID filing actions as civil complaints, instead of just straight habeas petitions and you know, adding kind of emergency injunctive relief, like um requests for your temporary restraining orders and preliminary injunctions. Um, so that was the bulk of the work that was like COVID related um. Individual and group habeas petitions, you know there's a lot of class action litigation happening around the country that kind of started towards the end of March. (.) And that the Bronx Defenders, we were not participating in that directly, we were more just doing individual and group petitions.

OZ 04:25

And how successful would you say those were um at getting relief for the clients?

SM 04:32

Yeah, it started off with. Um, we started off with a lot of success. We, along with—we co-counseled a number of our cases in the U.S., excuse me, especially, initially with the Legal Aid Society in New York, and we did a lot of informal collaboration with Brooklyn Defenders and (those are sort of the three organizations that staff met with) as well. Who was our co-counsel petitions with the Legal Aid Society where we would you know, During a habeas on behalf of ours, you know, three or four of our clients and three or four of their clients, we had some early success that was really quite astounding, I think we won one of the first TROs in the country (.) bringing like COVID related Fifth Amendment claim. And so, throughout March and April, of 2020, we had a fair amount of success. And it was kind of also a broader tool um than just individual litigation, it can, you know, the fact of that we were having success in some litigation, seem to pressure the government or the U.S. Attorney's Office into releasing some of our more vulnerable clients, even without litigation running its full course, so even just filing a complaint or a habeas, or by, you know, telling our counterparts at the DOJ’s Office that we were going to for a specific client, we did manage to have a number of clients released, particularly elderly, medically vulnerable. Um, that success really waned quite quickly. And that was very disheartening. And I guess unsurprising given the way these institutions work. I think the judges, and even to some extent, the government, were really worried about COVID, it was all like a really unknown quantity to all of us, if you recall back in March. And so, there was like some level of horror and, you know, fear, I think, from all parties about what was going to happen to people who are being held in these detention centers, and jails, and prisons, and so judges were a little more willing to go out on a limb. And then people quickly kind of got acclimated to the reality that, you know, our clients are going to get sick and die. And that was fine with them, as always, as always has been. And so, we, we saw a real drop off over the course of the summer, even though we had a lot of like medical experts, and epidemiology. ((SM laughs and OZ smiles)) I always struggle with that word. But experts in public health kind of talking about the very high likelihood of a second wave and how that was, again, going to hit congregate settings like detention centers the hardest. And so, what's been most successful since the summer in the fall? Well, we still got a few grants every now and then, was more just, you know, pressure on ICE and pressure on the government. There were some really great class actions that came out of California, federal court, there's a medical section called Fraihat where the government was required to take into consideration people's medical vulnerabilities in making decisions for release. So, we kind of had to shift our expectations and focus a lot more on individual advocacy with the agency. Because litigation is no longer required assistance.

OZ 08:08

I see. So, in addition to the fact that the amenability of, you know, judges finding, being willing to be responsive to COVID needs, that that kind of tapered off. And so, the decision making was more about collaboration, like kind of outside formal litigation to try to advocate on behalf of individual clients?

SM 08:31

Right. And I wouldn't, I wouldn't call it collaboration since the government was not an ap-- party you could collaborate with maybe it's different now. Under the former administration, there was no like, collegiality and working with ICE. ((motions with hands to show a coming together)) There was no like coming to reasonable agreements, it was just like, constant antagonism. But yes, that was became more truthful route. I think what happened a lot, the shift in terms of kind of judicial interventions, it went from a willingness to release people to a greater desire to kind of modify conditions of confinement. And, you know, that was a result in part of some, like, not so great circuit court decisions from around the country. But also, I think, judges just general preference to deferring to the government and you know, the government saying, like, ((gesticulates)) “Oh, we've done all these great things, it's perfectly safe now. Everyone's doing great work. We have experience with this. We’re, you know, distributing PPE, everything's fine”. And, you know, the courts’ desire to just believe that and just go with it. So, I think that was also a shift over time.

OZ 09:44

Yeah, yeah. That doesn't surprise me, the, like, accelerating deference to whatever it was that the government officials were saying they were doing that, yeah that doesn't surprise me unfortunately. Um, in your interactions with the clients that you are representing, kind of how were, you know, the non-citizens being held in detention responding to the, like, ever growing threat of, of COVID? And like how, how was that dynamic as, as an advocate, given that, like you're so siloed from, and I can imagine you would be so siloed from, from information, and it must be extremely terrifying to be in detention. So.

SM 10:24

Yeah, yeah, I think that's exactly right. I think it was, unilaterally a horrific and like, deeply traumatizing, isolating, dehumanizing, terrifying experience for people. And that kind of, you know, tracked with people's preexisting mental illnesses, people's conditions of confinement. You know, often people were, especially at the beginning subjected to conditions that were tantamount to solitary because of the way that facilities for kind of a knee jerk way reacting to some of the guidance from the CDC, or, you know, lack of guidance, about what the best procedures were. I think that there is no one who would say they have like a neutral or positive ((SM laughs subtly sarcastically) experience in jail last year. I think that every single one of our clients, you know, was, was like, deeply, deeply terrified about what was going to happen to them. In part because of the lack of information from the outside world. And that was exacerbated by the actions that we saw ICE and, you know, local jails, taking of like, very (0.5) meaningfully cutting off access, you know, like, people could watch TV, but then, you know, you weren't allowed out of your cell for a certain period of time. There was like, people were discouraged from asking questions from health care providers, and the jail, people were cut off from access from their attorneys, their family visitation, all these normal channels of communication were much more limited. And then, you know, people who wanted to ask guards for information weren't getting any accurate information, they were getting kind of attitudes, or just actual, like aggression, in response to any concerns or questions. So, the isolation and lack of information is definitely part of it. And then the inability to take any of the precautions that people were hearing about that they were supposed to be taking. Like, we all, you know, I’m sure you and all your friends and family and that I had the privilege of being able to say, you know, stay at home, wear a mask, clean my mask, get grocery delivery, you know, whatever it may be, all the things that are recommended. People just have no agency to control their lives in these really small ways, wash their hands, right? There was like a huge dearth of access to soap, hand sanitizer, cleaning supplies, toilet paper, all these things that, you know, ((gesticulates)) even if later on, it turned out we're not scientifically absolutely necessary, at the beginning, especially, when no one not one of us had any idea people were just really terrified, right? When we were being told we had to, like wipe down every surface, every time someone else, you know, touched it—that's not something that people had access to. And then, I think their real lack of clarity about who was being released, why, timeframes for decision making by ICE, criteria, that kind of lack of certainty that's always present in immigration proceedings, because everything's so arbitrary. There's a few rules became like super heightened with courts closing with adjournments, like indefinite postponements not being produced for court, you know, all these kinds of (.5) inability to access even the very few institutions and procedures that do exist, kind of tightened that as well. And then people were getting sick. And you know, some, some people in ICE died. Um. And that was something that people were seeing and seeing that their, you know, their friends and their (WP…) weren't actually getting enough medical care, that they weren't able to get access to medical care, even to the standards, which are really shitty that they were used to. So, I think, yeah, there's this whole jumble of factors that just made this (0.5) a truly horrifying experience, especially, like I said, for people who have preexisting mental illnesses, which is a very, very significant portion of our population.

OZ 14:35

Yeah. Yeah. I mean, in many in many ways, I can't really imagine a more frightening place to be than in immigration detention during this time, especially if you are maybe not an English speaker or haven’t you know, been in the country for very long or. Yeah, in any event, I can imagine and and I'm curious to hear given how many exigencies are always surrounding immigration. detention and how, like high stakes high pressure it is to always be advocating on behalf of, of your clients how like the past year just like changed the ethos in the office for you and for your coworkers and just how much like it took it to a whole ‘nother level when it comes to the, you know, pressure and tension and necessity of advocating particularly under the administration that you were working with. Well, working against.

SM 15:29

Yeah. ((laughs)) Yeah, I think that's a good question. It was tough. It's like, we, I think a lot of people really felt that they couldn't do their jobs. Like a lot of people, the staff attorneys and social workers and paralegals who are, you know, representing people in the removal proceedings felt like they couldn't show up for their clients in the way that they were used to, because they were prevented from visiting them in court. They were prevented, I mean, visiting them in jail, they're prevented from physically going to court to advocate for them. And the substitute channels of communication that, you know, were set up by ICE in the jails were just almost universally deficient, especially for the first three to six months. And so, you felt like you were failing your clients and their families in a time when they most needed an advocate. And I think that is extremely difficult. Um, and it also just wasn't a way reality wasn't the fault of any of our team. But it was the way that everything was kind of combining to be true, that you know, if you are on the phone with, with an immigration judge for your client’s court hearing, and the immigration judges may be physically present in the room…you're on the phone, your clients, beaming in by video. You know, government's somewhere doing something. It's like, ((wraps hands around her cheeks)) it's very hard to be an effective advocate. And that's, I think, compounded by the constraints that immigration law places on people about what factors judges can even take into account. So, during bond hearings, people will want to talk about these hellacious conditions that what their clients are going through and that would just be deemed completely irrelevant. So, I think that was really hard, just like the feeling that we could never do enough for our clients, which was not just a feeling it was also just reality. And then being separated from, you know, our networks that usually give people strength. I think it's always a grind. The job is horrible..ly ((SM and OZ smile)) difficult emotionally, but to have your coworkers that you can talk to. And then to be able to see your clients like in person and talk to them and have moments of levity and connection is really meaningful and helpful. And I think when, especially with new clients, you're trying to build a rapport over over the phone, having never met them (.) in person. It’s very difficult. It's not, it's difficult to establish trust and give people the comfort that you're actually trying to advocate for them. So, I think that's hard. And I think from our end, like the federal litigation team, we felt incredibly overwhelmed. Because all, like almost ((SM laughs a little sarcastically)) all of our clients, you know, had an underlying health condition, be it mental health or physical health, that would render them at higher—to be at higher risk from COVID. And and we have like, no partner, you know, on the side of the government, like it was essentially a complete, deny everything, like all common sense was denied. Or I didn't even know how to phrase it. I'm trying to say, I guess like, there was no humanity on the other end, it was like talking to a wall. And it was like, it was very disheartening. Because, you know, we've worked with a lot of government actors for a number of years, and they've always been kind of antagonists, I think, but during it, as a lawyer, you get to be in this kind of ugly place where you're friendly with opposing counsel, even when they are like humans doing really harmful things to your clients. But then in this moment, you’re like, “Well, my time is literally going to die if you don't get your client to let them out” and there's still no like, movement, there's still no response of like humanity or empathy. Like that is also just a difficult thing to be like, “okay, I kind of thought I was like, collegial with this person and obviously, we were living on different planets, and they actually don't care if my client dies.” Like that's interesting. Like I always knew that but like this is just, it's just very, very clear. So, that was hard. And then yes, like we could, we could never do enough. And that was hard too. And we could never tell our clients anything we're going to do was going to be successful, which is always always true in immigration world, but I think when the stakes were so high that felt worse.

OZ 20:05

Yeah, I can imagine. I mean, especially what you said about, like, one would hope obviously it didn't bear out, but one would hope that, you know, the conditions under which detainees are held are already arguably horrific, and it's very disheartening, immoral, one could say that, like, they just double down and just rather than being like, you know, “okay, we understand that this is amplifying how horrific it is” just saying like, “we're going to be even more restrictive and make it more difficult for you to advocate for your clients in this time” is rough. Yeah. Yeah. So, I'm curious. I mean, you spoke to it a little bit in the in the bond context, but I'm curious how like, I guess my comment kind of dovetails with it, but how this experience in the last year, like given how can't really get much worse than this for detainees, the conditions under which they were living in the last year, how this experience changed, like how you think about advocating for, like, filing habeas petitions or, you know, the factors that judges take into consideration when when ruling on motions and whether it feels like, once the pandemic is over, things will be better? Or if this just kind of totally disillusioned you to the practice in general or…

SM 21:26

((SM laughs reflectively)) Yeah, that's, that's interesting. Um, so I think, you know, in a way, just from a bigger picture perspective, the pandemic has um (.) been a real gift to the practice to like the system of detention because there's like, currently 14,000 people on ICE detention. And a year and a half ago, there was like, 54,000, so I think like that delta, like that change, is remarkable. I can't think of anything else that could have ever led to the release of so many people. I mean, that's a ton of people were deported on my fucking crowded flights to… where people were being like shackled against their will, so it was horrific, I'm not saying it was like all good news. But to have only 14,000 people in detention is amazing. And then on the other hand, you see, like, you think, and you're like, 14,000 people in detention, in the middle of a pandemic, like you already released 40,000 people, what's preventing you from releasing the other 14,000? So, you know, it kind of shows you the flexibility that exists in the system that people are unwilling to exercise, while showing that there's always going to be this insurmountable barrier of like, these people think that they're doing the right thing, like, I don't know. We don’t know. But, um, in terms of like, practice, I think that, yeah, I really showed, it really, the pandemic really brought into, like undeniable clarity, a lot of the things that we know as like law students and lawyers to be true. Which is that these institutions just don't care about whether our clients live or die, like they just don't. And that became clear as like people were dying and getting sick and no one was responsive no matter like, how much we cried and screamed about it. And it really is a system that is meant to focus on like procedure and not outcomes, right? So as long as the government was doing the right—taking the right steps, it didn't really matter what the outcomes were. And it just like the hypocrisy of it all, right? Like all the judges, like every single judge in Southern District of New York and the District of New Jersey where we were filing these petitions, was working remotely. You know, their entire staff was working remotely, like no one would dream of coming into work. And yet everyone was fine with the fact that you know, all these people were in like these like very high-risk detention centers, and that their families were, you know, falling deeper into poverty because they didn't have their only breadwinner. And you know, that's perpetuating the pandemic that way. So, all of that kind of really struck…the structural violence that we all know to be true just became like super concrete. And I think that is a hard thing. I quit my job ((laughs)) because I was like, super burnt out. I was probably burnt out before and this just made it much worse. I think in terms of like, optimism, though, like, you know, we saw that the system has some room to give. You know, we were all trying things we've never tried before. Like, you know, requests for release, habeas pitches and bringing equal protection, you know, substantive due process plans like, I don't know if you've learned this in law school yet, but everyone's like goes “substantive due process is like not a thing, like no one can ever win in one of these claims.” And, you know, so the idea that our clients had some rights, even if it didn't always lead to them to getting out detention. And of course, we're willing to recognize those rights to this very limited extent, I think, is a good thing. Um, there's room to push there. Yeah, I don't know if that really answers your question. I think it's kind of a tough question. ((SM plays with or shifts something on the table that makes a loud noise))

OZ 25:44

No, it very much did. I mean, I um, I think my question kind of emphasized the (.5) Sisyphean nature of litigating these cases. But I think that you're it's true. I mean, you're absolutely right. Like the it also doesn't, it seems to have demonstrated that there is a lot of room for pushing on it. And just the sheer numbers of people who are no longer in detention as a result of this, even though like you said, that that isn't always a best outcome, is is, yeah, really demonstrative of the way it can be both a good thing and also really devastating and detrimental going forward. For the clients of yours that you were able to, to successfully petition for their release, do you know kind of what the outcome was for them? Like, were they kind of was it like a parole situation pending their hearing? Or were they like, I don't know whether it was kind of, across the board, categorical, like dropping of whatever they were being held on? or?

SM 26:42

Yeah, so it was really, it varied a little bit like when judges would order release, they would often even in that, giving that freedom to the client, defer to ICE to impose conditions of supervision. So, a lot of those times when these prejudicial order are actually released on orders with supervision by ICE, and so they have various reporting requirements, some of which are incredibly restrictive, like ankle bracelets and you know, are holding on to your for, I guess, fighting back and advocacy. And then people that ICE release themselves often would sometimes be released in order supervision, sometimes on an ICE bond, which is like an ERO bond. And none of these are really like parole-type situations. But they are just, you know, could be released ( ), you're still in removal proceedings. The fact is that the immigration system has essentially ground to a halt during the pandemic, especially for non-detained courts, in populated areas. So, everyone's case is still pending. Everyone is, you know, to my knowledge, when I left the ( ), people were complying with all their obligations, you know, wearing their ankle monitors, calling ICE, doing check ins, it's like, which is what the vast majority people do when they're released from immigration detention, which is one of the very many reasons why keeping people detained is ludicrous. But yeah, so I think everything's kind of just going on, like, everything's just wait—everyone's just waiting for the next phase of, you know, COVID phasing out and of course, reopening.

OZ 28:20

Yeah. Yeah, um, something I wanted to ask you, which you've kind of spoken to just about like the that it's thrown into relief, kind of the, I think you use the expression, like the structural violence of the immigration system. Um, but I'm curious, like, what you think the experience of folks being held during a pandemic kind of reveals about, or what we should understand about this as like a society as law students, as people who are hoping to advocate in the future, like what this kind of taught you and what we should kind of learn about it going forward?

SM 28:56

Yeah, that's interesting. Um, I think well, the most, well like one thing that I think is a positive thing is just people are really resilient. Like, it's quite amazing. People will go through this really horrific experience, and then get out and, you know, all they wanted to do was like, what we all want to do is like, be with our families and try to survive this really difficult situation that we're all going through. So, people are resilient. And we all kind of want the same things, which, you know, I think you see, no matter what, when you represent people who are in detention. In terms of what you know, we can learn about the system is that it's really a dehumanizing system, in that it is (.) structured to dehumanize every single actor within it. Like, the government attorneys, I mean, when I have a moment to spare to think of them I don't like, I can't imagine that they are going to emerge from this experience with like, unscathed, because it is like tremendous—tremendously harmful to inflict this kind of violence on people, even from behind a video screen or a phone call, or whatever it may be to say like, “no, this person should not be released on bond, even though they have one DUI from 10 years ago, even though there's a pandemic raging, and, you know, their wife and child are starving, because, you know, the only person working was them.” So, I, you know, so I think it is dehumanizing the fact that it requires the government to be you know, this kind of one step away from inflicting actual violence on people. And then, for the, for our clients, obviously, it's like, they are expendable, like, they're 100% expendable in the eyes of our—of every actor in the system. And that is very, very clear. You know, I think all it takes is like reading reports from, you know, all this detention centers in Louisiana and the South where people are, you know, being held, when there's like a hurricane and a pandemic, and there's, you can't flush your toilet for a week. And anyway, you know, it's like, these are the most extreme, but like, variations of that were happening all over in detention centers. And for the people who work in these systems, you know, directly with our clients, like, once in a while, we would, you know, hear from our clients, like examples of humanity from them, but they're also I think, you know, there comes a point when you can't feel…you can't feel the empathy anymore, or you can't get up and go to work every day is, I imagine. And then for us, yeah, you know, you have to like really do a lot of triage, and a lot of ordering of the value of their clients like lives, right? Or experiences, and I think that's really damaging, too, to say, like, “okay, we have limited resources, are we going to prioritize filing a petition for our female client who has, you know, a claim that she could maybe win? And so, she and she has family in the U.S.? Or are we going to prioritize the claim of our elderly male client who has no family, no chance of winning the United States face versus…” You know, like, making these kind of like, value judgments about people's lives and experiences, is really, I think, detrimental to the idea of, of treating your clients equally, and like viewing humans equally. ((SM laughs)) So, all of that is, I think, also dehumanizing, so yeah, I don't I don't know, I guess that's a lesson. I don't know how to move forward from that lesson, except all you can do is like, you know, be a human when you can and encourage other people ((SM laughs)) to do as well. Yeah.

OZ 32:56

Yeah, I mean, I, I must admit, like, I don't lose a lot of sleep or a lot or spend a lot of time sympathizing with like the attorneys who are advocating on behalf of the ICE policies, and who are, you know, the judges who are ruling against these motions, but they are also, I don't know, I don't know if they like, close their computer and move on. And don't even think another time about it. But that's also. Um, yeah, they're also very much. Yeah, everyone is responsible for the, like, ethical and emotional conundrum that this situation represents. And I'd like to think that at least some of the people who have been complicit in maintaining the system have realized what they are doing. I, yeah, I don't know. Yeah, I mean, I, I'm, I'm just kind of curious, I guess, like, do you… I know, you left the your position with the Bronx Defenders and do you see yourself doing immigration work in the future? I don't know what your what your work is now, but like what your future holds? ((OZ laughs))

SM 34:03

Yeah, I'm still I'm still working as an immigration attorney in Mexico. I work for this nonprofit that does kind of work on transnational families. ((SM pauses to swallow)) And so, there's still some there's a lot of like direct legal services, but it's very different from the world events. You know, I think it's a different perspective on how devastating our immigration system can be. Because for the most part, our clients, so people who have been deported from the U.S. or people who have left state live in the U.S. at some point, still have family there, come back for some reason and are trying to reunite with their families. Um and it just shows really the kind of the other side of what I saw in the U.S. and I was always working with clients and advising clients about, you know, their forthcoming deportations. And I think that's a really hard thing to grasp for people who've lived in the states for any period of time, sometimes decades, and their families are going to be separated from them. And then here, it's people who are, have already confronted that reality and come to terms with it in some way or another. But I think, for me, I don't know actually, I can’t answer that question—what's next? This is just a one-year position. ((OZ says mhmm)) I think that one thing, like very ancillary thing, I learned from doing all this COVID litigation, and collaborating with a lot of the national organizations and kind of like fancier litigation firm—like shops that were bringing some of the class suits, is that I don't really, um, I didn't love being a direct services attorney, because it was a real (.) grind and so much emotionally, traumatizing work. Um but I don't like the idea of being like a class action litigator, because there's a lot of distance from the people who are actually going through this stuff and a lot of the triage decisions that I was kind of talking about that I think are distasteful and don't really lift up and elevate the voices and preferences of people who are affected by these policies. So, I don't really know what's next for me. But I think there's a lot to think about how to be an effective partner in moments of crises and moments when, there's no technical crisis, but you know, anyone in removal proceedings who’s a teen I think is facing some sort of individual crisis. So yeah, I think it's a hard, it’s a hard question. Like, what, what role? What's the best role for lawyers in situations like that?

OZ 36:55

Yeah, I think I mean, I think that's very true. I'd never thought of it that way. But yeah, the distance for a class action litigator is probably easier emotionally, but also maybe less efficacious that like getting the voices of the clients on who, because it's so much more like diffuse, and like you'd have less contact with the plaintiffs than you do with the direct service— as a direct services attorney. But that's also a lot more emotionally difficult. I can imagine. I think those are, I mean, most of my questions, and like that was really, really interesting. And I feel like, yeah, it's really great to have like an inside look at what, at the work that you've been doing. I'm curious if there's anything else you want to share about, you know, what working in this field was like for the last year or what the experience of being an attorney during a pandemic behind, behind bars was like?

SM 37:48

Yeah, I mean, I think I can't think of anything else I think, you know, our privilege is like, just really, that we always have really comes into focus even more at this higher level. Like I always had the feeling when I would walk out of jail after visiting my client, I would like drive home, you know, and like, sit in my apartment and eat Chinese food or whatever, like, “okay, like, this is a big difference in my life.” And

OZ 38:17

I don't know if you can hear me but you, you froze.