Ponderous Practice Book Over-Complicates Filing a CT Lawsuit

What on earth does Section 8-1 “mesne” (mean)?

Confused associate.jpgI’ve written about traps for the unwary in Connecticut practice before, but nothing exemplifies the incomprehensibility of the Connecticut Practice Book quite like Section 8-1.  It is supposed to explain how you start a civil lawsuit in Connecticut.  I’ll let you decide.  It states: 

Mesne process in civil actions shall be a writ of summons or attachment, describing the parties, the court to which it is returnable and the time and place of appearance, and shall be accompanied by the plaintiff’s complaint.  Such writ may run into any judicial district or geographical area and shall blah blah blah I’ve read this 6 times and I still know nothing about how to start a lawsuit in Connecticut.

Makes perfect sense.  Just hang up your shingle, ye lawyers, and have at it!

The rest of Chapter 8 says nothing about:

  • selecting a return date (must be a Tuesday no more than 2 months after the writ of summons is signed, C.G.S. 52-48);
  • the deadline for service (at least 12 days before the return date, C.G.S. 52-46);
  • the deadline to return service to the court (at least 6 days before the return date, C.G.S. 52-46a);
  • the judicial districts in which the complaint may be filed (depends on where parties reside or operate their businesses);
  • who may serve process (a state marshal or indifferent person, C.G.S. 52-50);
  • the restrictions on what state marshal may serve process in your case (marshal’s service powers are restricted to a specific county, but a marshal may serve outside her county in some circumstances)

And much, much more!

I don’t think I even looked at the Official Practice Book for the first 5 years of my practice.  I relied 100% on the annotated Practice Book:  the editors explain the rules in English and the cases they cite cover just about every scenario you are likely to face.  In fact, I considered it a sign that I had moved from apprentice to journeyman lawyer when I was able to use the Official Practice Book most of the time.

Every so often, I ponder whether Connecticut should overhaul its dual-source civil procedure regime and create a single, comprehensive civil procedure statute like many states have.  I always end up firmly on the side of not changing anything, even if the official written sources of procedure are horribly lacking in many ways. 

Why?  Many reasons.  Maze.jpg

First and foremost - I don’t want to have to relearn Connecticut Practice.  For a less selfish reason, the annotated Practice Book does a good job of explaining Connecticut Practice and the cost of buying the book is less than the cost of implementing the new regime and learning it. 

Finally, for a young associate’s development, there is nothing quite like powering through trying to figure out if you need to file a “request” or a “motion” to prepare her for the life of a litigator.  It can be frustrating; it can be stultifying.  Then, we experience the glorious aha! moment when it all makes sense. 

And that can be beautiful and satisfying. 

End of Summer Round Up

I've been trying to keep current with my blogging over the summer, but work -- billable work -- kept getting in the way.  September will be better, I promise.

Right now, I'm finishing up a week of vacation with my family.  I always start vacations with ambitious plans to get to all of the nonbillable, yet very Books I planned to jpgimportant, work.  I gather together a hefty pile of reading material (see image at right) for all that free time I am about to have, secure in the knowledge that I will return from vacation relaxed, infinitely wiser, and with A Plan. 

Reality comes crashing in by the end of Day 1.  I have three children ages 7, 14 and 15.  The 7 year old, rightfully, wants my attention every second of the day.  When she is asleep or commanding my husband's attention, I need to spend some time with the teens to get them talking, so I can know what they are up to.  There is no time for purposeful reading of career-building nonfiction. 

Here's what I actually read this week.

What I read.jpg

Oh well.  A little brain candy never hurt nobody.

Focusing back on work, an article jumped out at me from this week's ABA eJournal:

Stanley Kubrick Thought of iPad Design First, Samsung Says in Patent Spat with Apple.  Really? Science fiction as prior art?  I suppose Fritz Lang thought up robotics.  And don't even think of patenting a process for freezing humans in carboniteGeorge Lucas will have some words for you.

The Power of Sticking Out Like a Sore Thumb

South Dakota, you may know, is not New York or Connecticut.  For one, the roads are straighter and longer.  “Close” in New York is 5 streets or 2 avenues away; in Connecticut it is anything less than 5 miles away.  In South Dakota, “close” is anything under a 2 hour drive. 

And the people are very chatty.  You can’t order a cup of coffee without 2 minutes of chitchat about the weather, where you come from, or the Sturgis Rally.  Worse still, I keep ordering these wacky Northeast beverages, like “seltzer” and “unsweetened ice tea.”  I even ordered hot tea after dinner by specifying that I want it without milk, which my local guide informed me is like ordering tea without mayonnaise.

Yes, I am a Connecticut Yankee in the Old West.  And I am laying it on as thick as I can! 

I am wearing suits and heels to factory visits, I am studiously not bumping up my hair, and I am specially requesting entrees that do feature meat of some kind (to some seriously quizzical looks, btw).

Why?  Because as long as I am “other,” I am an unknown quantity.  No one’s got my number and no one knows quite how to play me. 

I considered whether my purposes in South Dakota would be better served by fitting in or sticking out.  I’ve written before about the challenges of practicing law in a small bar, where everyone knows you and knows your playbook.  But even assuming I could fake the cowgirl or biker ethoi (ethoses? ethosamajigs?) that predominate the region, being cooperative to a fault will not help my client.  And I gots to do what is in my client’s best interest. 

Anyway, a fringed leather halter and chaps is not a good look for me.  Uptight Connecticut lawyer it is!

Vacation is Over; Time to RUMBLE!

Howdy, Strangers! 

Yes, it has been more than a month since I posted.  Mea culpa!  Mea culpa!  Let me assure you, my time has not been ill-spent.  July started with a week-long stay-cation with my kiddies—that special time for all working parents, after school ends and before camp begins—and ended with a week-long trip to South Dakota for document review and making a menace of myself to opposing counsel. 

I’m on my way back to South Dakota now for more fun.

Why travel to South Dakota to be a menace, Fran?  Can’t you can be a menace from Connecticut or New York?   

Good questions!  I can be a menace from Connecticut and New York, and frequently I am.  I’ve come to realize however, that the power of menace, like gravity, is inversely proportional to distance:

                       M = 1/d

 As a result, to be most effective, a litigator has to show up sometimes.  And not in the sense that "eighty percent of success is showing up." (Allen, W.).  Rather, you have to step in, assert your authoritah, and take the advantage in the fight.

I am not suggesting that you should trespass on someone’s property or be a jerk.  Never be a jerk.  I will tell unflattering stories about you if you act like a jerk.  And never do anything that places your professional ethics in question.  BUT, we litigators have a lot of arrows in our quivers, and we must use them.

For example, if you are involved in a dispute among business owners, do not forget that your client has rights to review business records under state law and/or the operating agreement.  Don’t wait for discovery responses to show up -- go get what you need.  And do not let opposing counsel give you any jive about needing to set a time that is convenient to all counsel.

Also, get out there and start interviewing witnesses.  Employees may be off limits if the employer is a party, but vendors and customers aren’t.  Subpoena documents from them too, while you’re at it. 

So, why am I going to South Dakota today, when I just got back 2 days ago?  Because in this case my adversary needs to know that I am ready, willing and able to march into court.  It is a long walk from Connecticut or New York, so I need to show up in South Dakota to get my message across. 

Good thing the kiddies are in camp!

Musings from the Cat Law Bar

Or, dare I say it, "Mewsings"?

Yesterday, I attended the annual meeting of the Connecticut Bar Association at the Connecticut Convention Center in Hartford.  An expedited arbitration that threatened to consume my life nearly kept me away, but once that was stayed, I pounced on the chance to go.

I always enjoy these events.  I get to talk to people who are passionate about the practice of law, stock up on free pens and coffee mugs, and see the new stuff I must have for my practice.  (WestlawNext, anyone?)

A chat with former Superior Court judge John R. Downey left me pining for the time when I was Connecticut's foremost authority on the Law of Cats.Thumbnail image for bigstock_Contract_And_Cat_2580094[1].JPG

It was a few years and firms ago.  Partner X gave me a new case to run, and I had the pleasure of appearing before Judge Downey for several of its motions.  I cannot say that Judge Downey always made good decisions (because a good decision is, by definition, the decision to agree with me).  But I knew I would be heard by someone who would understand the issues and make the right decision.

Anyway, it was a small case, but it was mine.  And it had the potential to answer the question burning in the hearts and minds of cat lovers everywhere: 

Did humans own their cats, or did cats own their humans?

Now, I'm a dog person and I'm allergic to cats, but I knew a case where I could make my mark when I saw it.  No one else in the firm knew a thing about cat law.  I was going to learn cat law, and become the firm's cat law resource.  I checked the journals:  NOBODY had published a thing on cat law.  And let's face it:  "See Slusarz on Cats" is kinda sweet. 

So, the facts:  a cat shelter took in some cats abandoned by New Orleans residents fleeing from Hurricane Katrina.  As part of their agreement with the Humane Society, the shelter kept the cats for a certain length of time, and then found new homes for them.

Several months later, two New Orleans residents -- humans who thought they owned their cats -- contacted the shelter and demanded the return of the 3 cats.   The shelter, having already found new homes for the kitties, refused.   The humans sued, claiming conversion of cat.  (Yes that's right, the shelter took possession of the kitties and converted them to their own use.) 

This led to hours of research, trying to understand how those humans could assert a property interest in cats they abandoned months ago and, on a more fundamental level, whether cats are even property that a human can own

Dogs were clearly the property of humans, as evidenced by the fact that the government taxes them.  See annual dog license feeBut see Mr. Peabody and his boy Sherman

Yet cats were not taxed.  Hence, cats were not property and, therefore, could not be converted.

More importantly, I proved that cats owned humans. 

Alas, this important legal precendent was never to be adopted; my brilliantly-crafted argument never to be heard; my career as the nation's pre-eminent cat law authority cut short.  We settled the case. 

And not for the 9-cat treble damages payout that I suggested.

Microsoft Word Creates New Cause of Action

Plaintiffs Finally Can Redress Circuitous Wrongs as Foreseeability Spell-Checked Into Oblivion

It seems that Mrs. Palsgraf has finally been vindicated, forcing law professors across the country to revise their 1L Torts exams.

Not a Lawyer, or Don't Remember the Details of Palsgraf v. LIRR?

One fine day, as Mrs. Helen Palsgraf waited on one end of a Long Island Railroad Platform, a passenger on the other end was hurrying to catch a train.  Two friendly LIRR guards -- one on the train and one on the platform -- pulled/pushed the passenger into the train, causing the passenger to drop a package he carried, which just happened to contain fireworks.  The fireworks exploded when the package hit the rails, and caused a scale beside which Mrs. Palsgraf was standing to fall and injure Mrs. Palsgraf.  She sued the LIRR, claiming that the negligence of the guards caused her injuries.

The trial and appellate courts found for Mrs. Palsgraf.  The NY Court of Appeals, in a decision written by Chief Judge Benjamin Cardozo, reversed and dismissed Mrs. Palsgraf's complaint, holding that the relationship between the guards' actions and Mrs. Palsgraf's injuries were too indirect to make the railroad liable.

In short, a limitation on tort liability was born:  if the injury is not foreseeable, the actor is not liable in tort. 

Or, put another way, the court instituted as binding precedent something parents had known about cause and effect for years.  See Sibling A v. Sibling B, 1 Slusarz 299 (2010)(holding that Sibling B's hogging of the computer did not cause Sibling A not to clean her room). 

More of a visual learner?  This might help:

What Changed and How did it happen? 

Spell check on Microsoft Word doesn't recognize the word "tortious," making unwary lawyers advocate for or against tortuous interference with contracts, business expectations, etc.

Full disclosure time:  I'm a word geek.  I make no apologies

To continue:  according to Merriam-Webster, "tortious" means "implying or involving tort," and "tortuous" means "marked by repeated twists, bends, or turns...marked by devious or indirect tactics...circuitous".  Basically, an actor could not be liable in tort for tortuous behavior, for lack of foreseeability.

So, whenever I see legal writing where someone has fallen prey to the siren-song of spell check, I see Benjamin Cardozo eating his words, and Mrs. Palsgraf declaring sweet, sweet victory.

HUGE Med Mal Verdict Shows Importance of Offer of Compromise

Smart Lawyering Adds About $30MM to $58MM Verdict

Personal injury powerhouse Kathleen Nastri of Koskoff, Koskoff & Bieder secured a $58MM verdict in a case where an bigstock_Money___922494[1].JPGobstetrician failed to deliver a baby by caesarean section immediately upon discovering certain conditions.  The baby, born two days later by caesarean section after mom went into labor, developed cerebral palsy and needs extensive home care.

Most of us will not have this day in the sun in our careers, but let me highlight something we all can do:  file an offer of compromise pursuant to Conn. Gen. Stat. § 52-192a.  This is NOT limited to personal injury cases -- I use them all the time in business litigation. 

By filing an offer of compromise, you say, "This is what my client will take to settle this matter."  The defendant has 30 days to accept the offer. 

If the defendant doesn't accept, and the damage award at trial is greater than the offer, the plaintiff is awarded 8% prejudgment interest on the entire amount of the damage award from the date the complaint was filed if the offer is filed within 18 months of the filing date, or from the date of the filing of the offer, if the offer is filed more than 18 months.

Add a few years for the case to wend its way through the justice system, and you've got some serious bucks and serious leverage in a settlement scenario.

Is the LSAT Discriminatory?

As reported in the Wall Street Journal Law Blog, the American Bar Association was sued for violating the Americans with Disabilities Act because the LSAT discriminates against the blind and visually impaired.  bigstock_Close-up_of_John_Harvard_statu_17337434[1].JPG

The suit alleges that the ABA pressures law schools to use LSAT scores to evaluate applicants, threatening those schools that waive the LSAT with a loss of its ABA-approved status.  About one-fourth of the LSAT consists of "analytical rezoning" questions -- those horrific logic games -- that require diagramming to answer correctly.  According to the complaint, blind or visually impaired applicants are "unable to concieve of spatial relationships or diagram answers in the same manner as their sighted peers".  This puts the blind or visually impaired applicant at a marked disadvantage vis-a-vis sighted or unimpaired candidates.

Two thoughts (because you know I cannot keep quiet):

1)  The ABA law-school standards do not require the LSAT.  They require schools to take a "valid and reliable admission test."  An alternate test can be used and, I suspect, has been used by many law schools to evaluate qualified blind or visually impaired applicants.

2)  The plaintiff bases his claim on his having been rejected from three law schools in the Eastern District of Michigan.  You read that right -- three.  Most lawyers I know were rejected from at least three law schools. The complaint does not mention his college GPA, while mentioning his having completed high school in 3 years, so I suspect his GPA was not the greatest.  

I'm sympathetic to the plaintiff -- sighted applicants of similar ability have an unfair advantage over him.  But if his college grades are weak, he has to cast the net wider than three schools.

Choosing Litigation Counsel: Does Size Matter?

And At What Point Does Professional Civility Clash with Zealous Representation?

I have worked for a small city firm of six lawyers up to my current gig of ±500 lawyers.  In each setting, I have found myself pondering the size and civility questions.  They intersect and overlap and I don't have answers. 

The Size Issue

I don't think I would get much pushback if I posit that you have to hire a firm with the critical mass to handle the lawsuit.  This means having a sufficient number of attorneys, with sufficient skill, to address the legal issues of the lawsuit in a timely manner.  It also means either having sufficient staff to handle administrative issues or appropriate relationships with outside vendors.

There are few cases that a large firm is incapable of handling.  Economics is often the limiting factor, rather than capacity or skill. 

Having started my career with the six-lawyer firm, I do not underestimate litigators in smaller firms the way some of my BIGLAW compadres do.  Many small firm lawyers are highly skilled, were trained at top firms, and chose to work in the small firm.  

There are an awful lot of knuckleheads too.  When my adversary is from a large firm, I rarely have to explain to my client that opposing counsel was supposed to do X, and that it will not make a difference with the court anyway even if it means a further delay in our case.  

Still, I wonder whether the knuckleheads are concentrated in small firms or simply that large firms keep their knuckleheads from interacting with the outside world.   

The Civility Issue

We all agree that as professionals we litigators could be a whole lot nicer to each other.  There is no reason to run to court with a motion for sanctions because your adversary served discovery responses a day late.  There is no reason to oppose a reasonable request for an extension of time.  And there is absolutely no reason to let it get personal (even if opposing counsel is a big dumb jerk deserving of his comeuppance from me). 

But beyond this it gets sticky.  One lawyer's incivility is another's zealous representation.  The stereotype within the profession pits the small town country lawyer against the big city shark.  Justice is denied the small town client because the shark won't play fair.  The shark, on the other hand, has to cut through the clubbiness of the local bar every court date. 

Lawyers under a certain vintage go to bar events and hear about how much more pleasant it was to practice in the good old days -- the days of carbon paper and "for services rendered" bills and predominantly white male bars.  But was it really all that good?  I doubt I would have been a lawyer in the good old days.  Neither would many in my firm.

The Intersection and Overlap

Where these issues trouble me most is when I see stereotypical behavior that, in turn, affects the client's rights. 

When I worked in the small firm, and a new litigation matter came in, the partners advised to call Lawyer X and work it out.  Lawyer X was inevitably someone from the local bar, who had a certain reputation within the local bar, and maybe referred business to the firm.  It was all very civil, but was it effective?

Just calling Lawyer X was not my strength -- I was just a baby lawyer, and I am analytical and introverted by nature.  I could not imagine why Lawyer X would simply capitulate if it was not otherwise in his client's interest, and was not terribly good at schmoozing capitulation out of him on the strength of my charming personality. 

Ultimately, litigation tottered along indefinitely because no one had the wherewithal to bring it to a head.  The fees were relatively low, but cases were never resolved.

In the large firm stereotype, a new litigation matter comes in, and the immediate response is to aggressively defend no matter if a simple call to your adversary could start the wheels rolling to bring about a resolution.  In the rush to grab the advantage over your adversary, sideroads to settlement can be missed. 

Is the client's interest really served if, after 10 months of acrimonious litigation, you reach an agreement that could have been reached after two?  Not really.

I keep these pitfalls in mind whenever I evaluate new cases.  I really don't have the answer. 

#1 Way to Lose Your Right to a Jury Trial in CT

It's Simple:  Confuse Joining of Issues of Fact with Closing the Pleadings


Thumbnail image for bigstock_The_Jury___258885[1].JPG


Claiming a lawsuit for the jury trial list is yet another trap for the unwary in Connecticut state court practice.  Because a party must pay $425 to file a jury claim, it is rarely (if ever) filed when the case is filed.  Because no case makes it to the trial list until a certificate of closed pleadings is filed, and the certicate contains a nifty box to check indicating that you are also filing a jury claim form (and paying the fee), many practitioners make the mistake of thinking that the due dates are the same.

They aren't.

There is no due date for the certificate of closed pleadings.**  The certificate of closed pleadings just lets the court know that you are ready to have your case added to the queue for a trial.  Most plaintiffs want to file the certificate of closed pleadings as soon as possible because the queue can last a few years.  Most defendants do not care because the longer the wait until trial, the better.

The time to file is jury claim, however, is governed by Connecticut General Statutes § 52-215, which states (after 5 single-spaced lines mandating the keeping of a docket, the date by which a case must be docketed, and what information the docket must contain), "When, in any of the above-named cases an issue of fact is joined, the case may, within ten days after such issue of fact is joined, be entered in the docket as a jury case upon the request of either party made to the clerk." 

Translation:  the jury claim must be filed within 10 days after the last issue of fact is joined.  And they mean it!  I just won an objection to an untimely jury claim.  Plaintiff NEEDED that jury, but he isn't getting one.  (Cue maniacal laughter.)

So when is the final issue of fact joined?  It depends.  If the defendant does not raise special defenses, the issues of fact are joined upon filing the answer.  If the defendant does raise special defenses, issues of fact are joined upon filing a reply to the special defenses.  If parties file counterclaims, cross-claims, or third-party claims, it is the same -- the answer or the reply to special defenses.  It gets a little tricky with amended complaints because the court has to look at the substance of the amended pleadings to see if new issues of fact are actually raised, but the concept is the same.

The Moral of the Story:  In Connecticut Practice, if you want a jury to hear your case and you are relying upon your understanding of the "gist" of the Practice Book or Title 52, alert your carrier.


**Well, technically there can be a due date, but it is not set until the case is about to be dismissed for dormancy.  Then, the administrative judge of your judicial district orders you to close the pleadings by a certain date or the case will be dismissed. 

5 Things My Dad Taught Me That Make Me A Better Litigator

Lessons My Father Never Set Out to TeachDad en route to Japan 0451cropped.jpg

This week marks the 14th anniversary of my father's death.  Bernard P. Codd had been sick for many years and his death was expected.  Of course, I wish he were alive today, but not alive and in pain.  

Anyway, I started thinking about the Frans he never got to know -- the lawyer Fran, the mother of 3 girls Fran, the obsessive knitter Fran -- and realized that his life provided a better model of how to be a good lawyer and litigator than I realized.  (That his life modeled how to be a good person is beyond question.)

1.  Do What is Right for Your Client.  My father served as a field medic for the U.S. Army during the Korean War.  He was awarded the Silver Star for his actions one night, when the enemy overran his field hospital.  Everyone who could evacuate, did evacuate.  But some of my father's patients were too sick to be moved.  My father volunteered to stay behind to care for them, risking his life because it was what his patients needed

As litigators, we rarely risk our own lives for our clients.  But we often have to choose between what is easiest for us and what is right for our clients.  Do I want to stay in the office late to write the unbeatable brief when the judge will probably get it right with a half-way decent brief?  Heck no.  But I'm not doing what is right for my client if take that chance.

2.  Know What You are Up Against.  That fateful night in Korea, when my father stayed behind, he had to play dead to avoid being killed or worse.  He knew the practices of his enemy, and took steps to avoid falling victim to them.

Silver Star Citation.bmp

As litigators we have to do the same, albeit with lower stakes.  You have to know your adversary, know the judge, and know your client.  On a superficial level, you do a Google search, visit firm websites, and learn basic biographical information that gives you a pretty good idea of who you are dealing with.

But on a strategic level, you can use what you find to shape your litigation tactics.  For example, if I am in Connecticut state court against a solo practitioner who went to a local law school, I know that the solo will have a hard time responding to a barrage of motion practice.  I also know that lawyers and judges in the judicial districts can be clubby and if I try to overwhelm a solo with paper, I am going to get smacked.

On the other hand, if I am in federal court against a firm of 700 Harvard-Harvards, I need to prepare myself for the motion war, and maybe make a preemptive strike. 

3.  Figure it Out For Yourself.  Growing up, my father often spoke these 6 words: 

Look it up in the dictionary.

I cannot begin to express how much I hated to hear that.  If I asked him how to spell something, how to pronounce something, what a word meant, he'd direct me to the dictionary.  As if he didn't know himself and couldn't tell me!  (My 15-year old self could barely contain her rage at this slight.)

But, 25 years later, I get it.  If I am in court, and my answer is "Uh, that's what I was told by [the clerk, another lawyer, my dog]," I am toast and I deserve to be toast. Bernie and Evelyn.jpg

4.  Be Persistent.  Legend has it that my father was riding a bus on Staten Island, saw my mother, whom he recognized from a church group, and decided he would marry her.  Soon, they started dating, and soon my father proposed.  Mom did not decide immediately (or, as we would say, lacked knowledge sufficient to form a belief as to the advisability of marriage).  Dad waited and they continued dating.  Some six months later, my mother realized that she could not imagine life without him.  They were married for 44 years, had 8 children, who have their 26 grandchildren, and 1 great-grandchild.

The lesson:  when you know something is right, don't give up.  Judges are human and get things wrong.  Make your record and bring your appeal.  More senior attorneys in the office want you to do things their way even if the case doesn't call for it.  Clients think that every boo-boo is million-dollar injury. 

Stay calm.  Be persistent.  It will all work out in the end.  Even if you have to go to trial.

5.  Check Multiple Sources.  Every day, my father read the NY Daily News, the NY Post, the NY Times, and the Staten Island Advance.  On weekdays, he added the Wall Street Journal.  I could not imagine why he would need to read the same news 4-5 times.  Seemed like a waste of time when he could have, you know, watched TV instead.  We had, like, 7 channels!

Now I understand that everyone has his or her own perspective, and it changes the story.  We cannot take everything our clients tells us at face value.  This has nothing to do with the truthfulness of our clients.  It is just that someone else watching the same events unfold brings a different life experience with her, and could perceive things completely different from what our clients saw. 

Keeping this in mind, you will not paint yourself into a corner with the court or your adversary before discovery is complete. 


6.  Edit Yourself.  My dad had an exquisite command of the English language.  In high school, he regularly threatened to edit my essays, and I would do anything to avoid his red pen.  Years later, in practice, he was my one-stop source for all things grammatical.  (By then, I had earned straight answers to my questions.  Of course, by then, I would have welcomed a good, comprehensive reference book for grammar.)

But the real lesson was knowing when you've said enough.  I had originally planned 10 lessons from Dad, and but I've reached the outer limits of filial adoration and I risk descending into saccharine sentimentaility if I go on any longer.

Thanks for indulging me.