Thank You to VCBA Business Litigation Section

I presented “Blawgs” 101: Incorporating Legal Blogs into Your Practice to the Business Litigation Section of the Ventura County Bar Association at their monthly luncheon today, and had a great time doing it. I think I managed to pique the curiosity of a few folks, which is what I was trying to accomplish. I’m hoping that curiosity will take them to their computers with the resources list I provided (PDF download) in hand to explore law blogs.

To any participants here looking for the PDF of the resource list, the link in this post is the same as the link in the left sidebar that I directed you to. In fact, I’ll be taking down the sidebar link in a week or so, but this post, with its link, will stay up.

Thanks again for having me, and special thanks to Dennis LaRochelle and his committee for taking a chance on a topic very different from the usual VCBA Business Litigation Section luncheon presentation.

Thanks also to the following bloggers for responding to my call for input on how my readers use legal blogs.

Your input helped me prepare.

UPDATE (4/9/08): See the comments for an attendee’s account of her success using blogs for research.

Prep for Next Week’s Blawg Review

It will be my privilege to post Blawg Review #155 here on Monday, April 14. The weekly Blawg Review is a round-up of some of the most attention-getting and interesting law blog posts of the previous week. If you haven’t seen one before, check out this week’s Blawg Review #154 at Healthblawg, and those from the past two weeks, Blawg Review #153 and Blawg Review #152, to get an idea of what’s coming up here. Go to Blawg Review for links to others (scroll down to the “Past Issues” list in the sidebar there).

If you visit a couple of Blawg Reviews, you’ll note that most bloggers who host the Blawg Review do so with a clever theme. I haven’t settled on a theme yet, let alone a clever one, because it may depend in part upon the posts submitted for consideration. But for now, I’m leaning toward posts about (1) lawyers or judges in trouble for breaking rules — ethical rules, court rules, even rules of human decency; (2) posts about intrigue, skullduggery, conspiracy and corruption — essentially, anything that John Grisham might decide to write about; (3) oddities.

If you run across a post you think is worthy of inclusion in next week’s Blawg Review — even a post from your own blog, and regardless of whether it fits within the themes described above — notify the Blawg Review blog editor directly according to these instructions at Blawg Review. Those submissions will be forwarded to me automatically. Please, please, please, do NOT send submissions to me directly.

Blogging Professors

The New York Times recently ran a piece called The Professor as Open Book, about professors (across all disciplines) sharing personal information on their blogs and social networking sites. How much is too much?

Hat tip: Legal Writing Prof Blog, where John Marshall Law School professor Mark Wojcik offers some commentary on the subject.

It was just last June when University of Colorado law professor Paul Campos wrote in a tongue-in-cheek way about being perhaps the last law professor in America without a blog.

You’ll see precious little personal info on this blog. I only got around to adding my picture a week or so ago. And that’s not exactly private in any event. Like many legal blogs, this blog functions in part as a marketing tool. Having my picture in the sidebar is no different than having it in the county bar directory.

Second Appeal for Presentation Input

NOTE: I am going to keep this post at the top of the blog for a few days, probably until the end of the week. New posts will appear below this one until then, so if you see this post at the top, scroll down to make sure you haven’t missed anything.

In early February, I requested input for inclusion in a presentation I am making soon. Thanks to all who commented and who publicized the request on their own blogs.

The presentation is now less than two weeks off, so I am making a second request for input by reproducing the post in its entirety in the block quote. If you don’t have your own comment to make, an announcement of this request on your own blog, with a link to this post, would be very much appreciated.

How would you like your name up in lights? Or at least mentioned in a presentation? I can’t promise either, but you have a shot at the latter if you respond to my call for assistance at the end of this post.

I am preparing a presentation for a section of the local bar on the use of blogs in legal research. This will be something like the presentation I gave to the Los Angeles County Bar Association Appellate Courts Committee, though there I emphasized my personal experience a great deal, which I intend to downplay on this occasion.

For the upcoming presentation, I’d like to have a better feel about how my readers use blogs in their practices — for research or otherwise.

Most of my non-subscription readers — at least on those days where I am not linked to or from another blog — appear to reach this blog through Google searches. The client inquiries I’ve received through the blog tend to be self-represented litigants, but the stats occasionally show Google hits from very large (“BigLaw”) firms (only the domains of large firms show up by name, typically), which suggests to me that these searches are being conducted by lawyers for research purposes.

I’m curious how these searches are being used. For example, is the search the first legal research step, akin to opening up Witkin for general background, or is it undertaken instead after an attorney is stumped on an issue and hopes to find some recent development that hasn’t made it into print?

I suspect some of the searches are to supplement Westlaw research. For example, if I find a case on Westlaw decided in the last month or so, I might Google it to see if other bloggers or commentators are discussing its implications. That, in turn, could help my own analysis of the case. The Google search terms usually give this away by incorporating the names of the parties.

Another use I know of is to find out if anyone is talking about YOUR case. I have had litigants contact me when I posted about their cases. One did so publicly in the comments. Another contacted me by e-mail. So I know that parties are out there looking.

In any event, I would very much appreciate comments from readers about how legal blogs have influenced or aided their research or practices. Anecdotes would be great. Broader comments about your habits are fine, too. Any background information about the nature of your practice and the blogs you follow would be helpful.

I prefer you make your remarks in a comment to this post rather than by e-mailing me. That way, after the presentation, I can refer the attendees to this blog post if they want to read your comments in detail.

Please note that by submitting information in response to this request, you are granting me permission for me to use all submitted information in the course of my presentation (which shouldn’t be a big deal, since you’re posting it publicly anyway, and might even get you some small amount of publicity). But if you want to leave an anonymous comment, that’s fine, too, and I will present it as such.

UPDATE (02/14/08): Thanks to the following for getting the word out about this post on their own blogs:

New Appellate Blog: “Appellate Review”

An anonymous third-year law student has gotten a head start on his appellate clerkship by starting a new blog in the last few weeks:  Appellate Review.  The writing is good, and if you enjoy this blog and others like Decision of the Day and California Appellate Report, I think you’ll like Appellate Review.  It is now on my blogroll and one of the RSS feeds I will be checking daily.

Hat Tip: Appellate Law & Practice

A Happy Milestone

Somehow I managed not to notice for a few days, but early last week my RSS feed subscriptions finally cracked triple digits after hovering around 95 for several months.  In fact, subscriptions spiked to 113 earlier this week but have settled down to 101 today.  (Every couple of days, Feedburner drops my Netvibes subscribers and the subscriber figure drops to the mid 30s, but then goes back to the correct figure after a day or two.)

100 regular readers probably doesn’t seem like a lot, especially to those of you who are fellow bloggers.  But it’s a happy milestone nonetheless.

I have a way to go to catch up to University of Tennessee law professor Glenn Reynolds, who, as of today, averages  245,870 hits per day at InstaPundit.

Baby steps.  Baby steps.

Posting Lull

I will be out of the office all day tomorrow and am swamped trying to get some work done in advance of the trip.  I’ve set up a couple of very brief, fun, “Friday”- style posts for tomorrow, but I doubt I’ll have time to review any of today’s cases and thus I may not be able to post anything more substantive until this weekend or Monday.

How Do You Use Legal Blogs?

NOTE: I am going to keep this post at the top of the blog for a few days, probably until the end of the week. New posts will appear below this one until then, so if you see this post at the top, scroll down to make sure you haven’t missed anything.

How would you like your name up in lights? Or at least mentioned in a presentation? I can’t promise either, but you have a shot at the latter if you respond to my call for assistance at the end of this post.

I am preparing a presentation for a section of the local bar on the use of blogs in legal research. This will be something like the presentation I gave to the Los Angeles County Bar Association Appellate Courts Committee, though there I emphasized my personal experience a great deal, which I intend to downplay on this occasion.

For the upcoming presentation, I’d like to have a better feel about how my readers use blogs in their practices — for research or otherwise.

Most of my non-subscription readers — at least on those days where I am not linked to or from another blog — appear to reach this blog through Google searches. The client inquiries I’ve received through the blog tend to be self-represented litigants, but the stats occasionally show Google hits from very large (“BigLaw”) firms (only the domains of large firms show up by name, typically), which suggests to me that these searches are being conducted by lawyers for research purposes.

I’m curious how these searches are being used. For example, is the search the first legal research step, akin to opening up Witkin for general background, or is it undertaken instead after an attorney is stumped on an issue and hopes to find some recent development that hasn’t made it into print?

I suspect some of the searches are to supplement Westlaw research. For example, if I find a case on Westlaw decided in the last month or so, I might Google it to see if other bloggers or commentators are discussing its implications. That, in turn, could help my own analysis of the case. The Google search terms usually give this away by incorporating the names of the parties.

Another use I know of is to find out if anyone is talking about YOUR case. I have had litigants contact me when I posted about their cases. One did so publicly in the comments. Another contacted me by e-mail. So I know that parties are out there looking.

In any event, I would very much appreciate comments from readers about how legal blogs have influenced or aided their research or practices. Anecdotes would be great. Broader comments about your habits are fine, too. Any background information about the nature of your practice and the blogs you follow would be helpful.

I prefer you make your remarks in a comment to this post rather than by e-mailing me. That way, after the presentation, I can refer the attendees to this blog post if they want to read your comments in detail.

Please note that by submitting information in response to this request, you are granting me permission for me to use all submitted information in the course of my presentation (which shouldn’t be a big deal, since you’re posting it publicly anyway, and might even get you some small amount of publicity). But if you want to leave an anonymous comment, that’s fine, too, and I will present it as such.

UPDATE (02/14/08): Thanks to the following for getting the word out about this post on their own blogs:

Pro Bono Attorney Fees in the News Again

Dollar SignNational Law Journal has a new article called Pro Bono Case Triggers a Fee Fight on the controversy surrounding the attempt of a Seattle BigLaw firm (Davis Wright Tremaine) seeking to recover its attorney fees under a fee-shifting statute even though it took the case pro bono. The case was the closely watched “Seattle Schools” case decided by SCOTUS last year. (If you want some background from the view of the losing party, the school district’s press release from the day of the decision is available as a PDF download.)

In a very detailed post entitled The Pro Bono Road to Riches! last October, I discussed the issue in the context of a California case, in which the dictum of the Court of Appeal seemed to indicate a predisposition to awarding fees in pro bono cases. In that case, the trial court trimmed the fee request by 50% right off the top because it deemed the engagement “mildly pro bono,” and ultimately awarded less than one third of the amount requested. The Court of Appeal’s dictum leaves little doubt that the firm left plenty of money on the table by not cross-appealing to contest the amount awarded. (My earlier post includes several links to information about the Seattle Schools case, by the way.)

My post caught the attention of the Overlawyered blog, which sent me a ton of traffic when they linked my post. In fact, the traffic from Overlawyered was responsible for my highest traffic ever for a single day, and accounts for the anomalous bump in traffic during October that you see in the chart to the right. Clearly, this is a hot issue. So I also followed it up with an article in our local bar publication, CITATIONS.

I continue to believe that a large part of the controversy in the Seattle Schools case is driven by the nature of the party from whom fees are sought: a school district. Obviously, many members of the public are going to think that the district has better uses for the money. (Of course, there were probably a lot of people who said the same thing about the money spent by the district in fighting the case.) I wonder, though, if the people who are outraged at the firm seeking fees from the school district would have been just as angry with the firm in the case I profiled, which successfully represented more than 30 tenants seeking damages on various causes of action arising from the landlord’s refusal to let the tenants return to their units after they were evacuated from an unsafe building by the city. That firm, too, was a BigLaw heavy-hitter, but I’m sure the landlord of an unsafe building is going to get far less sympathy from the public than a school district.

One commentator in the NLJ article raises a point I made to a reporter who called me about my post: Is it right for well-heeled firms who often burnish their images by conspicuously accepting pro bono engagements to then seek fees for those engagements? This is an especially valid question if the firm announces the engagement with some fanfare but keeps the fee request rather quiet. It makes one wonder whether anyone honored for their pro bono work has actually been collecting fees for part of it.

Actually, that wouldn’t bother me, as long as fees were disclosed. A semi-pro bono case — in which an attorney agrees to an engagement for which he is paid only if he can recover fees under a contractual or statutory provision — is really just another form of contingency fee case, with all of the same risks.

Hat tip to How Appealing for the link to the National Law Journal article.

Weekend Downtime on the Blog

I’ll be upgrading the blog to WordPress version 2.3.3 this weekend. I’ve upgraded several times before, and it usually only requires about a half hour of downtime. But you never know what problems will crop up. So if you try coming here and get a “this site is down for maintenance” message, give it an hour or so, then check back.

LawLink Access to The California Blog of Appeal and More

There’s a new way to access legal blogs and more about your colleagues. And I do mean new. I added The California Blog of Appeal to the blog directory at LawLink over the weekend. This is only the eighth blog to be added, but plenty more are sure to follow.

Clicking on any of the blogs in the directory gives you an RSS feed right inside your browser window that shows teasers from the last few (up to 15) blog posts at that blog. Who knows how widely seen it may become? If you have your own law blog, you might as well get it up there now.

LawLink appears to be an attorney-only version of LinkedIn, an on-line networking tool designed to extend your network beyond your immediate contacts to those of your colleagues. I haven’t poked around LawLink too much, and my profile is bare bones for the time being. But the site appears to be designed to present an odd mix (in my opinion) of personal and professional information, considering that it is limited to attorneys. For example, there are fields to broadcast that you are looking for a personal relationship, whether or not you are single, etc.

Time will tell if it grows into a truly useful networking tool and blog resource.

UPDATE (2/6/08): The number of blogs has more than tripled since I registered this one on Saturday. The directory is now up to 25 blogs, some of which I have not seen before. This will definitely be worth checking every once in a while.

Jury Foreman’s Blog a Likely Issue on Appeal

A local trial court has just denied a new trial motion based on juror misconduct, where the misconduct was the jury foreman’s blogging about the gang member’s 19-day murder trial while it was going on, including posting a photo of the murder weapon, commenting on the evidence and witnesses, praising his own performance as jury foreman, and criticizing the work ethic of courtroom staff. From today’s Ventura County Star:

After sentencing a gang member to prison for murder, a Ventura County judge ripped into the jury foreman Tuesday, holding the juror in contempt of court for writing a blog that exposed details of the case during the trial.

The blog, or Web log, also criticized the judge’s staff and complained that the 19-day trial was taking too long.

Ventura County Superior Court Judge Edward Brodie told the jury member, identified only as Juror No. 7, that he had failed to follow the judge’s daily instructions to refrain from discussing the case with anyone during the trial.

Attorneys said this apparently marks the first time a jury member in Ventura County has been accused of misconduct for producing a blog, an increasingly popular type of journal on the Internet.

“. . . an increasingly popular type of journal on the Internet.”  Ya think?

The jury foreman testified at his contempt proceedings that “he didn’t believe his blog constituted ‘discussing the case’ in defiance of the judge’s instructions.”  Really?  According to the defendant’s lawyer, the blog included a chat room where readers asked questions and the juror answered them.

The article includes some sparring between counsel over the merits of raising the blog as an issue on appeal.  The trial judge’s ruling, obviously, means that he did not think that the misconduct prejudiced the fairness of the trial.

According to the article, the blog is titled “The Misanthrope,” but none of the blogs I found that included “misanthrope” in the title had posts about the trial.  It’s possible the judge ordered the juror to take down the posts, but I couldn’t even find cached pages in Google.

Slogging through Blogging

OK, that’s a litte bit of an overstatement. But Mark Hermann, a partner in my erstwhile employer, Jones Day, has this article in the National Law Journal about lessons learned during his first year of co-blogging at Drug & Device Law blog, and the first of those is that blogging is hard work:

First, blogging — or, at a minimum, blogging about substantive legal issues — is hard. Perhaps it’s easy to host a blog that simply pokes fun at current events by commenting on, and linking to, the news of the day. I wouldn’t know; I’ve never done that.

Amen and amen!

He follows the article up with this post at his blog describing reaction to the article. I recommend that anyone considering a blog check out both the article and the follow-up post.

Appellate-Related New Year’s Resolutions

I discovered a few on-line resolutions by some appellate bloggers:

At The Opening Brief, taking his own advice that improvement of one’s writing is a career-long endeavor, Sacramento appellate attorney Tom Caso resolves to work actively on his writing during the year.

At the (new) legal writer, New Orleans appellate attorney Raymond Ward resolves to keep in perspective such legal writing trivialities as whether to put one or two spaces after a period, where to place citations, and whether to fully justify text. Attention to detail is important, he says, but there’s room to disagree on things like this.

I’d like to say that I didn’t come up with any resolutions like this because my writing is already perfect, but alas, these reminders have led me to the same resolutions. We should all jump on board, if you ask me.

If you haven’t already made these resolutions, consider this your notice of default under rule 8.220(a), California Rules of Court, so you have 15 days from today to make your resolutions in a timely fashion.

Apple v. Bloggers Settlement includes Shutdown of Apple Rumor Blog

This isn’t really appellate-related, but I figure that at least some of you must be, as I am, a Mac-using lawyer, and will find this of interest.

In this post at The UCL Practitioner, Kimberly Kralowec updates some of her earlier reporting on the Apple lawsuit against some bloggers that had leaked internal Apple information. She provides links to a few articles about the settlement, reminds us that “in 2006, the Court of Appeal ruled that the bloggers were ‘journalists’ and that California’s shield law therefore protected their sources,” and links to some of her earlier coverage about the case.

Happy New Year, Everyone!

I hope everyone is off to a good start.

After 10 days or so off from blogging, I’m ready to get started again. Did I miss it? Surprisingly, no.  I mean, I’m glad to get started again, but I was so busy while getting ready for “vacation” (that word is in quotes because I worked on two days), that I was just happy to rest.

I just checked my stats, and traffic was predictably light from just before Christmas through today.  At least nine people out there must not have had a very good Christmas, since they hit my blog that day.

Watch for posting to resume soon. 

Merry Christmas and a Christmas Posting Hiatus . . . Maybe

Santa-Claus-1Not “maybe a merry Christmas.” The “Merry Christmas” part is unqualified.

The “maybe” refers to my anticipated posting hiatus while I am visiting family the entire week of Christmas. Not sure if I’ll blog or not. As much as a week’s break from blogging sounds to me like welcome relief right now — I put an awful lot of work into this — I feel like blogging is now “in my blood.” I’m not sure I can stop for a whole week! (Does this mean I fit into Judge Kozinski’s perception of bloggers?)

I will have access to a computer and the internet, so the temptation will be there. I’ll just have to wait and see.

I just don’t want any of you to think that I’ve given up for good if you don’t see anything new here until January.

Again, Merry Christmas to all!

Thank You to LACBA Appellate Courts Committee

I had the honor of sharing the stage on Monday with Denise Howell of Bag & Baggage fame (not to mention Lawgarithms and other projects) for a presentation on blogging and other internet media to the Los Angeles County Bar Association Appellate Courts Committee. Denise has more than six years of blogging under her belt. I spoke specifically from the “young blogger perspective.”

The committee members were quite receptive and interactive, with great questions that were fun to answer. Thanks to all involved, including Denise, and to Ben Shatz for setting it up.

By the way, because I expect a few visits from committee members as a result of my shameless plug at the conclusion of the presentation, I intend to park this post at the top of the blog for a day or two. For that period, new posts will appear below this one.

ABA Journal Blawg 100 Voting

200711302231The ABA Journal’s December 2007 issue announces the “ABA Journal Blawg 100,” which it describes as “the 100 best Web sites by lawyers, for lawyers, as chosen by the editors of the ABA Journal.”

The list includes three of the blogs that made my top 10 list in this meme about two months ago: WSJ.com Law Blog, Legal Pad, and Wayne Schiess’s legal-writing blog.

California lawyer blogs on the list include Pamela Fasick’s California Civil Litigation Quote of the Week and Denise Howell’s Bag and Baggage.

I don’t mind telling you I’m jealous as . . . heck.

There may be other California lawyer blogs on the list, but I need help identifying them. If you know that any of the other blogs on the list are authored by practicing California lawyers, please tell me which ones they are by shooting me an e-mail or posting a comment.

This link takes you straight to the voting page. It’s a little confusing at first. The blogs are divided into 12 categories, and only one category shows at a time. At the voting page, look for the logo that accompanies this post, and to its immediate right you’ll find a box with the categories listed. You change categories by clicking on the category you want.

ABA Journal says “Voting ends Jan. 2.” I don’t know whether that means you can only vote through Jan. 1 or through Jan. 2. So vote early.

By the way, I’m going to keep this post at the top of the blog at least through the end of the day Monday, so until then, look for new posts below this one.

Welcome to all Los Angeles Daily Journal Readers — and a Happy Thanksgiving to All

Welcome to all those visiting this blog for the first time after reading my article in the November 21 Los Angeles Daily Journal! Click and scroll around, check out some of the links in the blogroll, and come back again. Better yet, subscribe to this blog’s RSS feed.

My regular readers of more than a few months’ duration have seen my posts about the subject of that article — last August’s en banc decision in U.S. v. Larson, in which the Ninth Circuit resolved a 3-way intra-circuit split on the standard of review for Confrontation Clause challenges based on limits placed on cross-examination — here and here. The article in the Daily Journal is behind their subscription wall online, so grab yourself a hard copy of the newspaper or check back here after Thanksgiving weekend, by which time I should be able to get a copy posted here.

I plan to keep this post at the top of the blog at least through the Monday or Tuesday after Thanksgiving. Until then, all new posts will appear below this one, so be sure to scroll down on return visits.

Here’s wishing old and new readers alike — and everyone else, for that matter — a happy and meaningful Thanksgiving holiday.

Best Law Blog Voting Open Until . . . ?

Wa2007200X100Jm9-1The finalists for Best Law Blog have been decided and the polling site to vote for your favorite is here. In a great example of ambiguous writing to avoid in your briefs, the site says only that “Polls close November 8, 2007.” When on November 8 . . . who knows? To be on the safe side, get your vote in by 11:59 p.m. EST on November 7.

Playing Catch-Up

Last week’s workload left even less time for blogging than I thought it would, so I am still playing catch-up on last week’s legal developments.  Look for some catch-up posts this week.

Posting May be Difficult Today – Here’s Some Reading

I’m probably going to be tied up with a client for most of the day and will be unable to post.  But here’s a few things I found that might interest you. 

The Appellate Practitioner poses a hypothetical regarding writ review, then provides the answer.

The UCL Practitioner links to an article on the state of legal blawgs.  Still healthy.  Getting stronger, in fact.

Pamela Fasick is back at California Civil Litigation.  Welcome back from hiatus, Pam.

Party of the First Part wonders if he’s found the worst on-line agreement ever.  It’s got to be close, at least.

WSJ.com Law Blog makes it sound like things have changed since I left “BigLaw.”  They also have a post up about a trademark dispute that you’ll find of interest if you like Samuel Adams beer.  Or maybe if you just like beer.

Law.com Newswire posts about SCOTUS agreeing to hear the Exxon Valdez punitive damages case.  They also have advice for giving bad news to clients.

California Business Litigation Blog finds that lawsuits are a pretty good sign that not everyone is happy with their iPhone, even though the writer thinks they should be.

Legal Pad writes a bout a malpractice claim against Irell & Manella that may remind you of the premise behind the great TV show “Ed” (the “Bowling Alley Lawyer,” if you need a reminder).

And finally, Blawg Review #132 is up at Home Office Lawyer.

And don’t forget to check in with me again tomorrow!

The Evidence Prof Blog Arrives

200710270019

The Evidence Prof Blog is a new blog in the Law Professor Blogs Network. I only discovered them last Friday, though the blog has been up since October 2.

They recently posted regarding Rhoades v. Avon Products, Inc., case no. 05-56047 (9th Cir. Oct. 15, 2007), which applied Federal Rule of Evidence 408 in a trademark declaratory relief action. Issue: Whether a letter from counsel proposing settlement of a trademark dispute (and containing threats of litigation absent settlement) can be admitted to establish that a plaintiff seeking a declaratory judgment of non-infringement of the sender’s trademark has the requisite “real and reasonable apprehension that it would be subject to liability” if it continued to manufacture its product. Check ’em out.

By the way, I discovered Evidence Prof Blog by following one of the links in the feed in the right sidebar of this blog titled “Blogosphere Coverage of he Ninth Circuit.”  It pays to check some of those posts out once in a while.

An Interesting Law Blog from an Interesting Source

I’ve run across an interesting blog:  Winning Trial Advocacy Techniques.  With a title like that, I don’t need to tell you what its about.  But I got really interested in it after I’d read some interesting posts and clicked on the “about” link to see who runs it.  Turns out its an organization called “Trial Theater,” yet another name that gives you an idea of the organization’s perspective.  Worth checking out.

A Light Posting Week

This week is likely to be light on posts, as I will be very busy on a couple of cases.  I am trying to get as many posts up this weekend as I can and set them for publication over the course of the week.  That means nothing especially current after Monday or Tuesday, probably.  Any case law I post about will probably be no newer than Oct. 12.  If I unexpectedly find time to post on something new, I’ll do it.