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Darshan

Hey everyone, welcome to another episode of DarshanTalks. I am your host Darshan Kulkarni. It's my mission to help patients trust the products they depend on. As some of you know, I'm an attorney. I'm a pharmacist and I advise companies with FDA regulated products. So if you ever think about drugs, you wonder about medical devices. You consider cannabis or obsessional pharmacy is the podcast for you. I do these video podcast because there are a lot of fun and I find myself learning something new each time. It'd be great if some if I knew someone was listening as well. So if you like what you hear, please like leave a comment, please subscribe, you can find me and asked me questions on DarshanTalks on Twitter, or just go to our website at DarshanTalks calm. today's podcast, today's podcast is gonna be amazing, because the guests that I have today is the litigation lawyer extraordinare. I've known him for several years, I've known him through the American Bar Association. He has represented pharmaceutical companies in the context of litigation in general and fraud. And I discovered today his practice is actually much broader than I even knew. So our guest for today is counsel at Baker donathan. He wrote the treatise and pharmaceutical law for the American Bar Association. And he's got an eye. He's he was one of the people invited me to actually write some of the chapters for He is my editor in chief. I, is that the title editor in chief?

Michael

I think that's right. Yeah, I think that I'm the editor in chief Exactly.

Darshan

Also, because, you know, he felt he was bored. He's also editor in chief on for another book on corporate criminal liability with Thomson West as well. So if you're looking for someone who knows what he's talking about, around litigation, around fraud around pharmaceuticals, this is probably the conversation we're listening on. So our guest today, Michael Clark. Hey, Michael, good to see you.

Michael

It was great to see you. I was thinking Gosh, on the last time we saw each other in person was in San Diego at a function which I don't know how many years ago that was, but you know, go ahead and remote zooming and all the other mechanisms, it's great to see you.

Darshan

It's really wonderful to see you, I'm actually surprised that it's been that long. I kind of feel like 2020 almost is the year that never happened. Because I don't know how to count it.

Michael

It's been a, it's been a long, strange road as a Grateful Dead, sad, and one of their classic songs. Yeah, I'm glad it's in the rearview mirror, I'm all vaccine up and COVID is in the in the past, I got it last July. And don't recommend it for those who haven't had just not a whole lot of fun. But, you know,

Darshan

I had covered myself last year and I got the vaccine earlier this year, I thought it wouldn't like it will be unnecessary, because I already had the bug. Once I was wrong, that's much. But this is wonderful. And and the reason it's wonderful, is because we are seeing a major change around litigation, especially in the context. Well, one of the things we haven't talked about is actually your experiences around teaching people on how to litigate. And could you talk a little bit about that before we go down that path?

Michael

You know, I've been a all my career, I've been a trial lawyer, I'd started out wanting to learn how to try cases. And one of my mentors said, Go work for a prosecutor's office. And so I did that for the local district attorney, and, you know, probably overstayed my welcome five years doing that and, and then I became a US Attorney, assistant US attorney and came at the right time, because when when I joined the office in the Southern District of Texas back in 87, I guess we had 53 a USA is and I was number 54. And then the savings and loan crisis hit in Texas where we bank failed at least once, oftentimes twice or three times because the government was basically bundling failing institutions and the bigger failing institutions, which would then fail again. And so we got hit with this incredible number of failed bank institutions and savings and loans and we were charged with trying to figure out now what do we do and taught ourselves you know how to how to handle those cases. So I quickly got promoted, which was a good thing for me as a career advancer and I became one of the one of the chairs of financial litigation division and flew around Texas helping coordinate those cases. And you know, then was thinking about wonder lost again, and then I got promoted to be the head of the Criminal Division at the district, which I did for four years and then had to make a decision. Do I stay or do I go and I looked at the idea of being a Fed until I was probably in my early 70s and said, I just can't do what I had kids come in. And so you know, along the way, probably I stopped counting at 100 jury trials, I thought, okay, that that was enough. And I've been out in private practice marshawn since 98. I came in as a lateral partner for a large law firm and didn't really think at that time they knew what to do with somebody like me as a white collar when joined with a few friends that were former USA is a little bit older than me. And after a decade, I realized one partner was turning 80, and one was turning 70. And here I was 50 and not a good long term configuration. So now, through the machinations I'm now with Baker Donaldson. And, you know, one of the reasons I joined this firm is because I have a strong Health Law Group Practice And along the way, I kind of gravitated into health law, as you know, got active in the ABA Health Law Section worked my way up to be the chair, and have now kind of gone on to pasture. I'm on the past chairs committee. But you know, I've taught at the law school, I got a master's in health law, and actually, what might be of some interest to you in the audience, I got hooked into teaching an online course on pharmaceutical fraud. Uh huh. And I did that for the University of Florida College of Pharmacy, master level, pharmacy students. And that was kind of cool doing that online. I did that for about five years and kind of decided that, you know, the extra curricular activities needed to give way a little bit. So but you know, pharmaceutical fraud is a is a really hot and interesting area, you know, it's going back to the idea of follow the money, and obviously, the money's in this industry.

Darshan

So let's start with the first step. And it's an interesting comment you ended on follow the money, the money's in this industry. But you started with the savings and loan crisis, how does a financial litigator go into healthcare fraud, what drives you?

Michael

What actually got me hooked into this? Many years ago, when I was at the US Attorney's Office, there were cases coming in the door about health care fraud, and nobody knew how to do them. And so I said, Look, you know, I, I wanted to be a doctor one time this is closest I'm going to get but those you know, back in the old archaic days, the health care fraud cases we were getting were much different. I mean, you wouldn't go into medical necessity prosecutions. The only medical necessity prosecutions we would handle would be drug diversion. And, you know, at that time, I was seeing doctors that were, you know, abusing triplet prescriptions, which was kind of brain dead anyhow, because there's three records I've read. And you know, even though the idea of you know, looking at the, the trend lines and who were the big prescribers was really rudimentary, it was pretty obvious, you know, who was prescribing heavy duty narcotics. I had one doctor, for example, that I tried twice. The first trial was hung jury 11 to one after about a four week trial. And I knew I was in trouble when the jury sent out a note saying one of our jurors refuses to deliberate without his lawyer present to advise him and I said, Okay, this one is not going well. And you know, what, hung up 11 to one, so I retried it and have this anecdotal story make a quick, the doctor in the first time I tried it. His argument as to the drug he was prescribing, which was basically pharmaceutical methamphetamine was that he was using it for refractory depressed patients, you know, because there was some literature in the early 60s that this drug could be used for refractory depression. That didn't go over well, obviously, in the first trial, other than the fact that they had a nut juror that I managed to like be on the jury panel. So when I tried it the second time, his his reasons for prescribing shifted dramatically, and it became not refractory depression, but as a weight maintenance program. It didn't go over well, I think we got him convicted of 100 and plus counts of, you know, prescribing drugs for improper purposes, you know, outside of the ordinary course of medical practice, not for legitimate medical purpose. So that was kind of my introduction.

Darshan

I have to ask questions, because there's so many questions that come out of that. The first question I have to ask, though, is doctors aren't allowed to prescribe off label. In this instance, you were talking about a drug that was basically a method, a type of method for methamphetamine? Was it methamphetamine or was it something else?

Michael

No, it was it was a desoxyn is the drug, which is pharmaceutical methamphetamine based,

Darshan

right. Okay, so so I guess my question is, theoretically, it's an off label use by a physician who was allowed to prescribe off label. So what was the what? What was the gap? Because you'd be talking to physicians all the time, and and their response to us when I talk to them is, I'm allowed to do this. I'm not?

Michael

Well, once you look at our badges of fraud, right, and so one of the badges of fraud that we were able to emphasize was the fact that this gentleman didn't have any linen service to, you know, take care of his medical office. And you know, so basically, it's not what you'd expect a doctor be doing. I mean, we got evidence that people would line up, before the medical practice would open. And there happened to have been within, I don't know, maybe a block or two, a pharmacy that filled all these prescriptions, and they would just kind of shuttle over from one building to the other. And so you know, these are the types of things that Yeah, you can you can take your defense and stake it out there. But you have to be able to think through logically, what would a reasonable juror expect that a reasonable doctor would be doing and, you know, the fact that this guy was a nice guy, but you know, he obviously wasn't doing what was expected. And I had one witness who was a firefighter, for the city of Houston, who was a drug addict. And, you know, I basically was able to ask him, Well, you know, why were you getting the socks? And well, you know, because it's pharmaceutical grade methamphetamine, you know, I mean, it's the best, you know, he was a former fireman, I should say that. You know, and then we saw some evolution of the types of cases outside of just the DEA diversion. We, you know, we had cases that came in the door. And then when I was the criminal Chief, the health care fraud push started. And we were asked to develop healthcare fraud cases, which, you know, seem kind of counterintuitive to me at the time. You know, one of the things about being a fad is that you don't have to worry about client development, ostensibly. But here, we were charged with trying to develop health care fraud cases. And so you know, that, that has continued obviously, over the years. And, you know, my practice has evolved since I went into private practice. I do a False Claims Act, defense and things of that nature. But as you and I talked about briefly, and that kind of a bizarre practice, I am a litigator, and I've never wanted to be pigeonholed is one way or the other. And, right now, it seems that I'm doing more white collar, but you know, I also do basic, General commercial litigation. And, you know, I've done environmental litigation, I've done securities litigation, basic contract cases, bet the company cases. And I'm getting to thank, you know, I'm in my early 60s, this is becoming the, you know, at some point, looking back, saying that he had spent a long, strange path I've taken but it's been enjoyable.

Darshan

Let's pick on something you said, which is, so I'm not a litigator. As you know, I tend to be a transactional regulatory lawyer, you use the term developing a healthcare fraud case, what does that actually mean?

Michael

Well at it, you know, we have a lot more activities now in data mining, looking at Abra and prescribing practices, average billing practices, those are those are certain areas, obviously, that that are out there. The the techniques that were developed by federal prosecutors and drug cases have kind of meshed over into health care fraud. You have use of undercovers now. undercovers were fairly normal and drug diversion cases because DEA would be known to send in a a bogus patient and give the doctor an opportunity to act as a legitimate doctor would and then they would use things like street names for the drugs Why are you here to see me well I want some Mollies and some you know, whatever. And you know, so these were testing the integrity of doctors but you know, now it's not unheard of to have people that have been squeezed if you would and are trying to work off their exposure by you know, testing the integrity if you would of professionals. And you know, so this is easy to do. You have people that agree to make phone Call some call and say don't remember when we did this or something of that nature to get them to say something in criminal matory. That happens you have, it's not as easy to do, but you do have title three wiretaps, it gets set up in healthcare fraud cases, wow. And then because of the stored Communications Act, is easier. That applies to, you know, social media, things that are stored like email this older than 180 days and things of that nature, you don't need to get a search warrant, per se, you can get a court order, it's a much easier process. So there's a lot of ways that these cases are being developed. But the other aspect of that we haven't talked about, with the advent of the healthcare fraud statute as part of HIPAA, and private pay or fraud big now a potential federal case, you have a lot of former FBI agents, they get hired on by insurance companies in their Special Investigations Unit. And they shop their cases, to their friends at the FBI. And so that's the level client development right there. I mean, if you think about it, if I'm a large insurer, it's a lot easier to get the federal government to become my collection agency, and I don't have to worry about filing lawsuits, right, you can just basically say, let's make this a crime. And if you have a friend who, you know, is in the FBI, and this friend of your former colleague, who's now in your special investigative unit, I mean, it's kind of a slimy pathway, quite frankly. But you know, there are some practical issues out there that you have to be aware of.

Darshan

So what I'm hearing you say is that, you know, we've we've gone from trying to, from, per se, or near obvious types of fraud is using techniques like data mining, and looking at aborn prescribing and Abra marketing to basically find scenarios, and now that we're almost I don't even know if that's a word, but making it extremely lucrative fluidizing, if you will, the idea of having insurance companies or having other other individuals come out and basically create a fraud claim that the government can take on, and you identified this as being problematic. But do you think you've moved from the plaintiffs? Well, the prosecution side to the defense side? How do you address that? Do you tend to take on cases after the fact as always, because that makes the most sense. And people reach out to you going, I'm in trouble? Or do you tend to guide people on these are things you should be looking for that, considering you are now in a position where these types of things are happening? Is it? Is your practice ever proactive?

Michael

I try to be and yet, you know, that's always an issue. It's an issue of how risk risk averse your clients are going to be? Yeah. And, you know, I would much rather be proactive and and I have some clients that I was able to keep from being wiped out in False Claims Act cases where we've come back in and said, you know, let's, let's get you bullet proof that this doesn't happen again. And and so that that part, you know, I don't like having to take a client in the courtroom and civil or criminal, you know, it's just an ordeal even, even if they come out on the back end ahead. It's never the same. So yeah, I do. I do like to be proactive and explain to them that the fraud and abuse, civil or criminal, it's kind of like Alice in Wonderland, going down the rabbit hole where you're dealing with the Red Queen, and it's a new reality. And, you know, it's just it's a very difficult situation. I think I mentioned to you that I'm now representing a, I got a few physicians, clients that are facing criminal investigations. And, you know, I look at these cases and think, you know, back in the day when I was doing this type of work on the on the prosecution side, I wouldn't have brought these types of cases. But it seems like I'm seeing medical necessity cases that are, you know, the government's willing to bring in some experts as medical witnesses and try to show that the, you know, that the physicians were not acting appropriately. So, it It's an evolving world, but what used to be abuse is now being called fraud. And then there's new tools as you as you know, I mean, there's asset freezes and other things that can be done to keep, you know, keep companies or individuals from being able to successfully mount their defenses and you know, separating the attorney from their clients by seizing all the money, it becomes a real problem.

Darshan

So how do you deal with things like asset freezes, because I actually have a client right now I'm dealing with where all the money that he could access is being blocked, because of it's not a criminal case or anything like that. But it's,

Michael

well, that's the productivity of it, though, you know, you've got to convince the client, that there's a real need to leverage their money. And if you if you think about the, the forfeiture laws in particular are very scary, because the theory that the government has been able to get courts to agree with is that, you know, when a fraud was committed, title invested in the United States. So while they may think they have a million or $2 million, you know, the sliquid. The government's position is no, it's our money. And so what you've got to do is you've got to put it to work by putting it into an iolta account that they can have the attorney bill against, even that is not bulletproof. I mean, back in the day, when we had Enron, we had one of those, one of those defendants and another lawyer brought us in me and my partners, and there was a seven figure sum that was earmarked for the trial. And the dang government sees that out of an altar account, we were able to basically beat them up in the courtroom, because their tracing methodology was wrong. So he backed off, but it does happen. And it's, you know, it's not very gentlemanly to take lawyers money away from them, but we'd stay in compliance, right. So, you know, companies, companies are different. I mean, you know, if they are heavily into federal program reimbursement, the spigot is going to get turned off. I mean, that's that's a clear thing. And then, you know, private insurers will follow suit. So it is a practical problem. But what do you do? I mean, I put into my engagement agreements, a recitation for the client to certify that all these funds are free and clear, not subject to any liens or encumbrances? I mean, but beyond that, are you supposed to go out and hire private investigators to source the funds for you? Are you allowed to take your clients representations at face value, if you don't have red flags? I don't think we've gotten that far. Or I have to go higher croal to face it out in Europe or something. But I mean, these are practical issues. And I've encountered one of those just recently with a friend who brought me an older case were very aggressive a USA was, you know, seeking ex parte court orders. And and I don't need to spend an hour on it. But I mean, it does make you think, what are what what is reasonable under the circumstance? And it's it's a real problem.

Darshan

How do the courts view that? Let me say more aggressive stance that's being taken in these scenarios? And is state insurance a good way to mitigate these these considerations?

Michael

Well, I think the courts generally allow it and, you know, there's not much in the way of opportunity to attack that. I mean, the the standard is very differential to government. Right? credible evidence, I think is the standard that they have to come up with what the hell is credible evidence? It's beauty is in the eye of the beholder, right. And so that's the prosecutor defining the world. Well, the Supreme Court has said, however, that, you know, there is a line under the Sixth Amendment where you cannot interfere with a person's right to be represented by counsel. And so as long as you can show that these are funds for councils use, there are some opportunities to do that. But you have to structure your engagement in a way that you try to protect it as much as you can, but it's not our cloud. If I don't, if I don't have reason, for example, to know that they're going to claim that these assets are dirty. You know that I think it's a much more manageable situation. Right? Like, if I have reason to know if there's red flags, and I think my obligation, I'm on inquiry notice to go further and you know, that increases.

Darshan

Have you been in a situation where you represented a client, it was very clear, as soon as you saw the evidence, and especially after you try the case, that the The prosecution didn't have many grounds to go after your client, have you actually sued? And has that been successful? How has that been viewed, if

Michael

you will, I've had a few clients that have received target letters, you know, we plan to indict you. And you know, in the, in the stratification, you have three categories, witness was just always where you want your clients to be subject, which means that they think you've done something wrong, they don't have enough evidence. Target is just like, it sounds the worst place to be. But I've had a few clients or not, I don't want to do I think, reveal any identities. But I had one position in particular, that he not only got a target letter from the local, US Attorney's, but one from Maine justice, which is DOJ trial division. And we were able to go in and show them that their theory didn't hold water, it had to do with time based codes, that was the theory. But these were not time based codes. So we were able to show them look, you know, we can try but that's not gonna work. And so they just gracefully didn't pursue it. You know, they never tell you, not never, rarely did they tell you we're gonna drop the investigation. But you know it after, after limitations runs, you know, the investigations not gonna go around.

Darshan

Fair enough. So so what I'm hearing you say, Did you recommend a more conciliatory approach as you're doing this? Or do you read the clients? Obviously, when they start off when they're in this position, they tend to want to go hard, and put the fear of Jesus into the into the other side's eyes. But do you find that tactic works? Or have you generally found that it's easier to go more in a conciliatory way and management there?

Michael

Well, who has the power as the first operative question? You know, you have to be pragmatic about it. It's so conciliatory to a point to a point. If people lie to you the time for, you know, conciliatory conduct is gone. But, you know, you pick your battles wisely, right? I mean, I think you can be conciliatory without being showing weakness. But at the end of the day, they have to understand that you have substance and if they push too hard, if you, if your client doesn't have options, then they're going to buy themselves a trial. I, my former law partner, is a very good lawyer out of Dallas named Dan Guthrie, he and I were involved in representing our client in a scorched earth False Claims Act case for six years, we, we fought like hell, I mean, we made everything very difficult for the government, and at the end of the day, had a wonderful outcome. I never want to be a jerk about things, but I want them to know that, you know, if you really want to push the envelope and think the client is going to roll over, it's not gonna roll over, you know, so that's, that's my approach is to, you know, not brag, but show and pleadings and other things that you know what you're doing, and probably know what you're doing better than they do. And you work harder than they do. And, you know, I think it makes a big difference. That's where that's where the quality of counsel I think makes a big difference.

Darshan

Have you have you been in a situation where you've had to bring a malicious, malicious prosecution type argument back?

Michael

I haven't. You know, I might have been able to add a case or two, but it's a high standard. I mean, you've got you've got the Hyde Amendment in the criminal cases, it was passed when the government unsuccessfully prosecuted representative Hyde. And so his, his legacy was they passed this law, basically saying that the standard that's available for civil litigation of Equal Access to Justice Act will apply and certain types of criminal cases, but you've got to show that you substantially prevailed. And, you know, it's it's, it's a pretty hard thing to do. You know, but it's there. I wrote an article about it many years ago, and I think it was called nothing to hide. And it was kind of a play on words, you know, basically talking about there is a remedy, but how real is the remedy? And you know, it's Harvard approved.

Darshan

Very cool. I had promised to keep you on for about 2025 minutes, but already beyond that. Fascinating speaker. couple of questions. The first question is, do you have any question for the audience?

Michael

You know, I I'm always interested in things like this. You know, what resonates? What? What would they like to have heard me talk about you know, I, you know, I thought maybe I would talk about securities fraud issues. And why they're so important in this industry because you know, most, most drugs that have been developed will fail. And there's always a problem of what do you say along the way to keep investors happy? And are you meeting your, your matrix, I've had a, I had a client that was a speculative better who hit the homerun Grand Slam really in a penny stock that involved a new drug development. And it was a fascinating case. And you know, so I'd be very curious about the audience, I'd be happy to answer any questions anybody would have. That's why we do this is to, is to prospect and meet new people. But, you know, it's been a lot of fun. I just feel like I'm doing a monologue, and I apologize for that.

Darshan

Not at all. This was actually a lot of fun. For me, at least. What I do also want to add is now that you mentioned that we need to bring you on, because we need to talk about what could people do around AMC and GMA stocks? And I don't know if you followed that at all, but

Michael

well,

Darshan

so. So that could be just a fun conversation that I have, yes, it doesn't relate to pharma. But you kind of get an example of a situation where that very, very well could be similar to pharma wouldn't want activist investors? So we definitely agree.

Michael

It's, it's a it's a fun, crazy world. You know, I've got this I kept one of my chapters in the treatise after kind of like you get when you said you'd like to write a few, I said, really. And when I, when I first put the treatise together, I ended up by default, doing I think, four chapters. And I said, No, no, that's too dang much. And so I've cut it back to one chapter, which is my securities chapter, securities law chapter. And these cases are fascinating, because you know, there's so many different permutations of where companies get into trouble in this industry, because of investors and trying to please people, you know, sometimes, sometimes it's damned if you do damned if you don't, but I'd love to talk about that at a later time. That'd be a fun topic to go into.

Darshan

We're definitely bringing it back for that topic, we may need to do it sooner rather than later because it's so topical right now. As I mentioned, we do do a couple of rapid fire questions. Are you ready?

Michael

I'm ready.

Darshan

What was the best part of your job this week,

Michael

my best part of my job, this word. I finally got got through dealing with a claim on some monies that I had with a client and I got to get him Adios. And that's another story. It's just sometimes you deal with the lowest common denominator. And you know, that that that was my, my big accomplishment nonbillable dealing with a pain in the backside person who thinks that they're far more powerful than they really, really are.

Darshan

I have so much to unpack there, but not the second. What did you learn this month?

Michael

Well, I've, I can't say anything in particular jumps out that I've learned this month, that that's really a huge revelation. I've been, I've been looking into with a new client, this therapy that has to do with the use of magnets to deal with refractory depression. And, and that's, that's fascinating. For me, I had one time I wanted to be a doctor, and I actually wanted to be a psychiatrist. So, you know, my proxy, as I mentioned, getting into this area has been fascinating, and I enjoyed that. So learning about this treatment, and you know, how it's used and how actually successful it is have been kinda interesting.

Darshan

That that is exactly the type of question I was asking. It doesn't have to be about law. It is just fascinating. But magnets,

Michael

we got to keep learning. I mean, we can't stagnate.

Darshan

100%. So what I do like to do is I like to do a quick summary of the conversation we've had. So during this conversation, we landed up speaking actually, actually, before we got on, we then have speaking about the variety of work you do, including and I'm going to do a quick overall description, healthcare fraud. Immigration violations, which I was totally surprised by, you're working on a deposition and a contract breach claim, all of which I would think would be each specialties on their own. So I'm fascinated to do all of them. You talked about your experience, starting with savings and loan crisis, you talk about how you went from financial litigation, considered being a Fed got into health care fraud, actually started off with with what you'd consider more true, true or if you will, healthcare fraud situations. And now you Are you you're seeing the development into medical necessity prosecution. And we talked a little bit about the quote unquote badges of fraud example no linen service, apparently, which I would not have thought was one of them. But there we go, we learned something new. We talked about data mining, and barend, averin, Aberaeron prescribing, which are examples of the techniques we now use. You talked a little bit about that case around the linen service, which I thought was fascinating things like, as you pointed, pointed out the nolin service, but also patients lining up and people saying that they were there for Molly, I think was an example you gave, which I think was fascinating. We talked about your experience, both developing the online healthcare fraud case, and actually developing healthcare fraud cases in general. So healthcare fraud course and developing health care fraud cases, you talked a little bit about your experience around the False Claims Act, you talked about some of the techniques associated with, with what the FDA with what the DOJ and the US Attorney's offices do, which to me comes straight out of James Bond, and I'm looking forward to the next James Bond movie that has healthcare fraud in it, because apparently, we have undercover people, we have wiretaps, we have asset freezes, and so much more. And we talked about malicious prosecution where you talked about the credible evidence standard, which means absolutely nothing. Did I miss anything?

Michael

You haven't missed a thing. It's been a real pleasure. Real pleasure.

Darshan

This was wonderful. Michael, thank you so much. I hope we can have you on again soon. By the way, where can they reach you Michael?

Michael

My email us am Clark at Baker donaldson.com. And I'm continuing to work remotely. So that's been kind of a nice thing. And you know, anybody that wants to reach me, I'm more than happy to chat. This is, again, why we do these things. But more and more importantly, it was been fun catching up with you, and thank you for the invitation, but a real pleasure,

Darshan

of course, and thank you. For those of you who want to reach me. You can reach me on DarshanTalks on Twitter, or go to our website at DarshanTalks calm. If you'd like this podcast, please like leave a comment. Please subscribe. Please reach out to Michael if he can help you. So thank you, everyone. Thank you, Michael. This was wonderful.

Michael

Thank you. This is the DarshanTalks podcast, regulatory guy, irregular podcast with host Darshan Kulkarni. You can find the show on twitter at DarshanTalks or the show's website at DarshanTalks.com

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