Rod Ammon: Welcome to the CFITrainer.Net podcast. We've listened to your request for case studies, and today, on this episode, we have just that. We're going to discuss recent litigation in a fire loss case that involves subrogation, spoliation, expert qualifications, and working with hired origin and cause experts. There are some important lessons within this story that we hope you can apply to your work, whether you're in the public or private sector. In a small rural town in Western Virginia, a fire occurred in a multi occupancy commercial structure that included an apartment, office, and electrical finishing workshop. Electricity was being supplied to the building at the time of the fire. The property owner reported polishing an old rifle action on a buffing jack, then leaving the workshop area to go to another building on property for several minutes. He was alerted to the fire by the sound of a smoke detector, then observed black smoke rolling out of the workshop building.

In communication with the alarm company, he agreed they should call 911. The local volunteer fire department responded and extinguished the fire. The building sustained over $150,000 in damage. The fire chief's report listed sparks from operating equipment as the fire cause. Five days after the fire, the insurer sent a contracted fire investigator to examine the property. The fire investigator was state licensed and held national certifications. The investigator issued a preliminary report finding that low hanging electrical service wires rubbing against the metal roof of the building wore down the insulation on the cables, causing a sparking electrical arc to ignite the roof's wood framing. The report did not include examination of some of the power company's equipment, which the investigator stated had been removed prior to the examination. The report was devoid of any information about machinery in the workshop area, and it also lacked hypothesis testing or detailed evidence supporting the conclusion and eliminating other potential causes. The buffing jack was not addressed as a potential fire cause.

That investigator later told the court that they informed the insurer that evidence at the scene needed to be preserved and a joint inspection had to be arranged. The investigator assumed that the insurer would make the necessary notifications to other potentially interested parties, and arranged for them to examine the scene. That never happened. A representative from the insurer told the fire investigator not to retain any evidence from the scene. A month after the fire, the insurer told the fire investigator to close their file on the case. The insurer gave the property owner the go-ahead to raze the building. The owner did so about six to eight weeks after the fire. Two months later, the insurer sent a letter to the power company placing it on notice of a potential subrogation claim. Based on the fire investigator's opinion, the insurer claimed the power company's electrical conductor caused the fire. The power company's origin and cause expert went to the scene but was unable to conduct a thorough examination because the building had been razed and no evidence remained. The power company O&C expert reviewed the report written by the insurer's fire investigator, and subsequently detailed how the report was deficient and incorrect. The court granted the power company's motion to exclude the testimony of the insurer's expert and strike their report. The court also directed the insurer to provide an updated report, which they subsequently did, but it was substantially similar to the already challenged preliminary report. The power company again moved to exclude the testimony of the insurance company's expert because it did not satisfy Federal Rule of Evidence 702, and was an unreliable opinion, not based on sufficient facts or data.

The power company provided a brief, detailing existing evidence and data that disproved the opinion that the low hanging electrical cable caused the fire. The power company asked the court to dismiss the insurer's claim due to spoliation because the insurer allowed the building to be razed before it notified the power company of a possible claim, thereby preventing the power company from having the scene and its evidence examined by the power company's expert. The insurer argued that the power company was on notice when it came to the building to complete repair work after the fire. The court's order cited precedent that found the argument of implied notice is insufficient to avoid sanctions for spoliation. The court agreed with the power company and dismissed the insurer's subrogation claim as sanction for spoliation of evidence. With us to discuss the issues in this case is Chris Konzelmann. He's a senior partner in the subrogation department of White and Williams. Chris regularly acts as a lead counsel in significant subrogation matters throughout the United States, with a special emphasis on fire-related losses. He's an active member of the National Association of Subrogation Professionals and a regular presenter at both the annual and spring conferences. He's a co-chair of the IAAI's Insurance Advisory Committee, and an instructor for the IAAI's Expert Witness Courtroom Testimony program. Chris has developed an eight hour educational program entitled Giving Stronger Deposition and Trial Testimony and he presents it across the country. If that's not enough, Chris is also a captain of the Moorestown Fire Department in Burlington County, New Jersey. He's a certified interior structural firefighter, certified fire officer, and IAAI certified instructor. Chris, that's quite a CV. Thanks for taking the time to talk to us today, and welcome to the podcast.

Chris Konzelmann: Thanks for having me, Rod. I always enjoy talking about subrogation-related topics, and I'm sure I'm going to enjoy this conversation as well.

Rod Ammon: Well, it's quite a case. Let's start with spoliation. It's clear in this case that spoliation occurred because the power company was not notified that a legal action might be brought before the insurer released the property to the owner to be raised, and the insurer instructed the investigator not to retain evidence. What should have happened here? How should the situation have been handled?

Chris Konzelmann: So I think, Rod, we have to take a look at the bigger picture to start with, right? So we have a justice system obviously here in the United States, and that justice system is generally based on the concept of fairness. In a case such as this, that generally means that all parties should have access to the same evidence. So here, the argument by the power company was that they never had an opportunity to inspect the fire scene before building demolition took place. Their position was, because of that, they were prejudiced in being able to defend the claim. So in the subrogation industry, we deal with this issue on a regular basis. We get an assignment, we retain consultants, we send consultants to the fire scene to formulate opinions as to, I always say the same thing. Area of origin, point of origin, heat source responsible for ignition, and first fuel to burn. So the consultant goes out to the fire scene, performs that preliminary assessment. And during the course of that assessment, he has to make the decision of when to stop, almost. And that decision or that analysis is based on, are there other potentially interested parties that should be placed on notice and be involved in the investigation? And sometimes that analysis is relatively easy and we know the answer to that when the matter comes into the door. So let's assume that we have a room and contents fire, landlord tenant situation, fire starts on the stove due to careless cooking. The insurance company for the landlord hires a consultant to go out there to inspect the fire scene. Based on the preliminary information that we have, we know we have a stove fire and we know that the tenant is the potentially interested or potentially responsible party. So in that situation, the tenant and the tenant's insurance company should be given notice of the site inspection.

But let's take that example one step further. Let's assume that we have an inadvertent stove activation case. The consultant for the landlord, when he originally gets the assignment, goes out to the site, determines that the fire starts on the stove, but also realizes that there may be an inadvertent stove activation situation where that stove did not comply with the applicable standards. In that case, the fire investigator goes out there, makes that preliminary determination, and needs to stop once that potential issue is identified and the stove manufacturer is identified. The notice letter can go to the stove manufacturer. The scene can be preserved until the stove manufacturer has a chance to send a consultant to the site.

So getting back to it, sometimes it's easy. We know going in who the other potentially interested parties are. Sometimes it's not as easy. We don't know who the potentially interested parties are until the initial site inspection takes place. When those other potentially interested parties are identified during the course of the preliminary site inspection, generally there's a stop, notice letters are sent, the scene is held in a joint site inspection scheduled at some point at a future date.

Rod Ammon: So whose responsibility is it to make those notifications? Should the fire investigator in this case have done it themselves, or was it the insurer's responsibility?

Chris Konzelmann: Yeah. Most insurers hire counsel early on for any significant loss. I think the industry generally recognizes that it's subrogation counsel that sends those notices out. And 921 defines for us who an interested party is, and 921 also tells us what those notice letters should say. But again, my view generally is it's done by subrogation counsel. Number one, the backup would be the insurance company claim representative, and it's very seldom do I see a situation where the fire investigator is the one sending out the notice letter. The fire investigator is there to investigate the fire's origin and cause, not necessarily to start communicating with the at-fault parties and coordinating that joint site examination.

Rod Ammon: So there wasn't anything in this case where the fire investigator maybe should have done something to motivate that. You feel as though that should have been handled by the insurer, the people who hired them.

Chris Konzelmann: Yeah. Well, when I talk to fire investigators about this specific issue, they generally don't want to get involved in sending out the notice letters. Sometimes they don't have the resources to identify who the notice letter should go to. They may not have the documentation identifying who the potentially responsible party is. And if we take an example, if we have a fire at a construction site where there's a general contractor and a lot of subcontractors, somebody's got to gather together all those contracts, sort through those contracts, find out who the potentially interested parties are, track down the appropriate contact person for each of those companies, get the appropriate notice letters out, monitor responses to the notice letters, and ultimately handle the coordination.

And again, most fire investigators that I deal with feel that that's outside their scope of work, and that's why that work generally gets handled by others. Again, subrogation counsel, or possibly and maybe occasionally the insurance company claim representative. But if we're putting on notice five, 10, 15, 20 parties, which we do sometimes, it takes hours to track everybody, it takes hours to coordinate with everybody. It just becomes a time-consuming job, and again, usually something that's outside the scope of what the fire investigators do. Fire investigators are there to determine origin and cause, not necessarily communicate with third parties, based on my experience in the industry.

Rod Ammon: I get it. So I was impressed that 921 had what the notice letter should contain in it. I thought that was great. So just broad strokes on this case, I mean, did this case surprise you, or does this kind of thing happen on a regular basis?

Chris Konzelmann: I would say that it happens periodically. Each of these losses are unique in their own way. It depends how the particular insurance company handles subrogation, or how the particular independent adjuster that's assigned to the claim handle subrogation. Again, different carriers do it different ways. The one thing to keep in mind is that when you are going to be investigating this fire, or a fire such as this, that task does need to be delegated to somebody. Somebody needs to undertake that task. And you mentioned before how 921 addresses notice letters. The key for this whole issue, including spoliation related issues, is section 12, which is called legal considerations. If we refine that further, we can go to section 12.3, which is legal considerations during the investigation. We could take it a step further. Section 12.3.5, which talks about spoliation-related issues. And then a subset of that, again, going one step further is section 12.3.5.4, which tells you what that notice letter should contain. So 921 is obviously a comprehensive document. It covers the vast majority of issues that arise during fire investigations, and notice letters is certainly one of them.

Rod Ammon: Okay. So let's talk about vetting experts, because obviously there's a wide variety of experts that are available out there with different types of certifications. And let's look at how people out there in the industry should vet their experts and talk about the investigator in this case. They didn't have specific electrical examination expertise. They didn't have documented experience with this type of fire case, had never testified, had never qualified as an expert witness. Ultimately, their testimony was excluded. So what qualifications should a private sector organization like insurers set for fire origin and cause experts they hire?

Chris Konzelmann: So preliminarily, it's my experience that there are three types of experts, or fire origin and cause investigators come from three different areas. Number one, we have those that are in the public sector and eventually transition over to the private sector. We have those that are in the public sector and remain in the public sector. And we have those in the private sector that start in the private sector and continue in the private sector. So generally speaking, those are where the fire investigators come from. And in the last, I would say, 10 or 15 years, we've started to see, really, a great number of public sector investigators finish their career and transition over into the private sector. And there's a big difference between the investigation that is done by the public sector and the investigation that is done by the private sector.

On the public sector investigation side, in most jurisdictions, their primary responsibility is to determine whether or not a crime has been committed, whether or not the fire has been intentionally set, or on the private sector side, dealing with subrogation and SIU-related issues, their job is generally to go one step further. They aren't necessarily concerned about a crime. They're necessarily concerned about, is there a potential third-party liability, or did the insured, in an SIU situation, play some role in causing the fire? So that's generically kind of the pool of where we get investigators. If we start to take it a little bit further, we start to look at the qualifications of the investigators. And we know that in every industry, people need to start someplace. Somebody is going to go try their first case as a lawyer. A doctor's going to perform his or her first surgery. A fire investigator is going to go out and do their first origin and cause investigation.

Generally speaking, the newer fire investigators are working with more experienced fire investigators. They learn the trade that way, and they also learn the trade by attending training programs that are put on by the IAAI and many other organizations that are out there. So you gradually increase your knowledge, increase your knowledge. What we find sometimes though is that fire investigators start to get outside of their area of expertise, they start to get outside of their lane. And that's where we see the rule 702 challenges come up. So if you're a fire investigator, you may well be qualified to provide testimony on area of origin, point of origin, heat source responsible for ignition, and first fuel to burn. You are probably not qualified to provide testimony on standard of care of a contractor that may have been involved in causing the fire.

And going back to the case that we had talked about previously, that case required an electrical engineer, because we were doing electrical engineering issues, heat transfer issues from when that cable allegedly fell and impacted the building, creating the fire, generally an electrical engineering issue. And if you're going to pursue a contractor, a utility, or somebody else, generally, you need a separate consultant to tell you what the standard of care is, what that contractor did or did not do correctly, which was a proximate cause of the loss. So fire investigators need to stay in their lane, they need to limit their report and testimony to items on which they are qualified, and then defer to others with other subject matter expertise for some of the other issues that may be related to, or may be important to, the analysis of what went wrong, what caused the fire, why did certain things happen, and why did certain things not happen.

Rod Ammon: Okay. Is there anything the insurance company could have done differently here once they realized that there were issues with the initial expert?

Chris Konzelmann: The preliminary part of that is whether you're a law firm, whether you're an insurance company, whether you're an independent adjuster, you want to look at the qualifications of the expert that you're hiring. How many fires have they done before? What is their education? What are the certifications that they have, or are they qualified for that particular task? So there's necessarily a vetting process that goes on when consultants are hired. And when you're hiring a consultant, you want to check on their qualifications, you want to make sure that this is not their first job, that they've been doing this for years, that they understand the industry, that they understand 921, that they understand 1033, that they continue to take educational programs to learn, because this is an evolving industry.

If you look at how 921 was years ago, versus how it is today, it's a much different document. And if you're in this field, you need to keep yourself abreast of all those changes. And we look for consultants that do that, that definitely have a vested interest in the industry, that are committed to the industry, that undergo and attend the training that's available to the industry.

Rod Ammon: You went to my follow-up question, and I appreciate that because I think that gives really good advice to some of the guys and gals that are listening to us right now in the fire investigation community. What I was wondering about though was also the insurance company. Once they've got a problem like that, where there's issues with their initial expert, are there options for them once they've got a problem with this?

Chris Konzelmann: There are options, and we have to look at that two different ways. Number one, do we still have a fire scene to inspect? Number two, is the fire scene gone? So let's assume that a consultant gets hired, he goes out, processes a fire scene. And then for whatever reason he disappears, somebody realizes he may not be qualified. You can certainly then hire a second consultant, and in essence, do a redo. Have him redo the investigation. The problem arises when you realize that there's a problem with the initial investigator and the scene no longer exists. What do you do at that point? So if the scene was properly documented in accordance with 921, that second consultant may be able to go back and formulate opinions based on the, I'll say the record that was created by the first consultant. Sometimes that can happen, sometimes that cannot happen. It depends again on how the scene was documented, what the issues are in the case, whether any physical evidence was retained, whether there any eyewitnesses to the fire, things along those lines.

So there is a bit of a fallback that is available to us in appropriate circumstances. And the other thing to keep in mind, Rod, is, I'll say in the last three or four years, this industry has changed a lot just because of the video surveillance that's available out there. On more and more fires, I'm getting video surveillance showing the fire in its incipient stages. So if I have video giving me the area of origin, or even the point of origin for that matter, and then there is a problem with that initial consultant, that's a great piece of data that the second consultant can rely upon. We now have a starting point for, again, area of origin, possibly point of origin. And as long as the evidence in the area of origin was retained, it's relatively easy then for a second consultant to come on board and take over where that first consultant left off.

Rod Ammon: Yeah, makes sense. So in the first situation where you called in that second expert, you could potentially use the photographs and that person as a fact witness, I guess. Chris Konzelmann: That's what you do, you then reclassify that person as a fact witness. That person can provide testimony on the observations he made at the fire scene, the data that he collected at the fire scene, the photographs that he took at the fire scene, and then had that factual information evaluated by a second consultant. And again, that second consultant then has data points to rely upon in formulating his or her opinion as to what happened. It can't be done in every case, but it can be done in the appropriate case.

Yeah. And I think it's just good to think about it, because I'm sure there's situations where this happened, and it's nice to know that you can sort of make a turn or loop back and make an attempt at getting it done the right way. So let's talk about multiple experts and different opinions. There was a public sector investigator in this case, I guess he was an investigator, the fire chief who marked operating equipment as the cause of the fire on his... Not operating. Yeah, I guess operating equipment. Equipment in the shop, as a cause on his fire report. And there's the insurer's fire investigation expert who said it's the power company's equipment that's at fault. There's probably should have been, I think you already said, an electrical expert called in. Then there's an expert hired by the power company who examines what's left on the scene. How should all these various experts be interacting in a case like this, when you have different access and different opinions?

Chris Konzelmann: It's somewhat jurisdiction specific. So let's just kind of walk our way through this. Let's assume that we have a house fire. The public sector is going to send an investigator out there to go take a look. That investigator may have 30 years experience, or that investigator may have two years of experience. You don't necessarily know until you dig into it a little bit. But that public sector investigator has first access to the site, presumably before anything is disturbed. And hopefully during overhaul, that scene is left intact for the follow-up insurance company related investigators. What generally happens in the industry is public sector does a preliminary investigation. Maybe it's detailed, maybe it's not, again, geographic specific as to what happens.

The homeowner submits the claim to the insurance company. The insurance company retains subrogation counsel. Subrogation counsel retains a consultant. That consultant then calls the public sector investigator and says something to the effect of, "Hello, I've been assigned to investigate the fire at Mr. Smith's house. I understand you've already investigated the fire. What information did you develop?" Get some factual information. The private sector investigator then usually tells the public sector investigator, "I'm going to be going back to the house and performing my own investigation on this particular day. I just wanted to give you the courtesy of the call, in case you want to attend as well while I'm processing the fire scene." So now we have the public sector communicating with the private sector. Private sector investigator goes out there. Does he get to the point where he identifies a potentially responsible third party? Maybe, maybe not. If he does, the investigation is halted, notice letters are sent. The parties put on notice refer the matter to their insurance companies. Their insurance companies hire their own consultants. The joint site inspection is then scheduled, and the joint site inspection then takes place.

Taking it one step further, a decision is generally made at the fire scene when all of the consultants are there as to what evidence is going to be retained, who's going to retain it, and what's going to happen next. Is there going to be a lab exam? Is there not going to be a lab exam? And in this industry, what I generally find is all of the investigators know each other, all of the lawyers handling fire cases know each other. And I will say that in the vast, vast majority of claims that I'm involved with, it's a very professional process. Everybody goes out there. They do their job. They do their job the right way and the work gets done. And ultimately some conclusions are reached, and maybe there's going to be litigation, maybe there's not going to be litigation. But it's really very much a structured process, and everybody that's been doing this work for a little while knows the process. They follow the process. And again, the work gets done the right way.

Rod Ammon: Yeah, it sounds good. And from all the folks that I have seen working on these things together, I think you describe it well. It does seem to be a professional systematic approach that goes on. What do we learn about from this case though, about what needs to happen when multiple experts are involved who have different conclusions?

Chris Konzelmann: Well, there's always going to be experts that have different conclusions. So we can talk generically, we can talk about this case in particular. There's sometimes going to be agreement on area of origin. Sometimes there's not going to be agreement. There's sometimes going to be agreement on point of origin. Sometimes there's not going to be agreement. Each case is kind of a little bit different. The idea though is to allow all experts to have access to the same evidence. The discovery process then takes place, and the case ultimately goes where it goes. One person is going to be right, one person is not going to be right. But that's what the litigation process is all about.

It gets back to that notion of fairness that I talked about before. We hope and we believe that the system is a fair system where everybody has access to the same information. The opinions may be different, but the factual predicates should be relatively similar, again, under the notion that everybody has access to the same evidence. So at the end of the day, we may have three different experts with three different conclusions. That's what the litigation process is all about. And that's why we have jury trials. And the reality is the vast, vast majority of these fire subrogation cases and fire litigation in general get resolved well before we start picking a jury.

Rod Ammon: Case and deposition and all the things that I read really said to me, boy, it's really important that fire investigators continue to improve themselves through education and training. Specifically, you teach an IAAI expert witness courtroom testimony course, as well as your own class on deposition and trial testimony. What were some of the issues with the testimony the investigator gave in this deposition? What do you think could have been done better?

Chris Konzelmann: Well, I think when we look at the testimony, we find that he was a relatively inexperienced investigator. He was working for the consulting firm on a part-time basis. This was not his full-time job. And that's okay. Some people have other careers and they're doing the investigative work as a part-time job. The takeaway though is if you're going to do the work on a part-time basis, you still need to handle it like it's your full-time job. Because when you go out there and investigate the scene and prepare a report, people are going to be looking at that report at some point in the future. And a lawyer such as myself is going to rely upon that report. And what we don't like to see happen is, we get a report today, we produce you for a deposition two years from now, and we realize that a lot of things are lacking in qualifications or in the substance of the investigation that was done.

So when I teach these classes, one of the things I always do is I tell the investigators, "Here's where I see the problems in the investigations. Here's how you're going to get jammed up when you're giving deposition testimony or trial testimony because of these problems. And we need to make sure that these problems never arise in the first place." And certainly one of the things that I talk about is making sure you're qualified to proffer the opinion that you intend to proffer, and making sure that the factual predicate for your opinion is sound, and that the analysis was done in accordance with the scientific method. Generally speaking, if you're a 1033 qualified expert and you do not stray from your area of expertise, you shouldn't have any problem with the admissibility of your opinion.

But we still see problems out there. It is nowhere near, in my mind, as bad as it was 10, 15 years ago. The industry, in my mind, has advanced considerably. The sophistication of the investigators has advanced considerably. And that's in large part, I think, because of the training that's available to them, whether it be from the IAAI or many of the other organizations that provide training to consultants. So if you're going to do this job, you need to be all in. A lot of people are going to be relying upon you, and you don't want the situation to arise where two years later, your opinion falls apart because something wasn't done that should have been done, or because your analysis wasn't done the right way.

Rod Ammon: It's funny, I look back at the 20 years that I've been involved with the fire investigator field, and you're right. I mean, I can remember the conversations we had the first week and the number of convictions, that kind of thing when it related to arson. And where we've gotten to today, there have been incredible improvements in the education and training. It's been great to see. In that insurer's expert report, it was stricken from the record because the court deemed it as deficient. And the brief supporting the motion to exclude is pretty detailed in terms of exposing issues in the investigator's report, including methodology, the evidence examination, failure to consider other potential causes, lack evidence to support their opinion. It amazed me how much written detail actually even came from the judge for the ruling. That really surprised me. What should private sector employers expect in reports from their O&C experts? As an attorney, what do you see in fire investigation reports? Where do problems arise? What do you like to see?

Chris Konzelmann: So it starts with doing the investigation the right way initially. It starts with properly documenting the investigation initially. Once all that's done, and once the facts are on the table through deposition testimony, or whatever other fact gathering methods are available, you really got to put your thoughts to writing. And when you litigate these cases, in many jurisdictions, the court rules tell you what need to be in your report. So oftentimes if I have a case where I'm asking an expert to write a report and I'm in federal court, I will send that consultant the section of the federal court rule which says, "Here's what your report needs to contain." And when we're in federal court, it's generally going to be a complete statement of all the opinions that you intend to proffer, the facts or data that you considered or relied upon, the exhibits that you're going to use to summarize your opinions, the qualifications, and a list generally of when you have given testimony in the past.

So I will provide the requirements to the consultant. I will get the report. I will review the report to make sure that there's compliance, because if we take care of it at that stage, the chance of us getting a 702 motion to suppress the opinions of the expert becomes somewhat limited. If a consultant is working with an attorney, my view is that the attorney, to some extent, is the backstop to make sure that any potential errors in the report get corrected or get caught before that report is finalized and published or made available to the other parties.

So again, it's a matter of doing the job right in the first place, devoting sufficient time to properly include in the report what the court rules say it should include. And then having that backstop in place, primarily counsel, to make sure that the i's are dotted and the t's are crossed. I've seen some outstanding reports in my line of work, and I've seen some reports that aren't so good. The not so good reports require us to spend a lot of time cleaning them up. And as an attorney, that gets to be a little bit frustrating, because I think the view of our industry is we shouldn't have to do a lot of cleanup on reports that we're going to be producing in active litigation.

Rod Ammon: As an attorney, out of everything that happened in this case, what stands out to you? What's the biggest thing you'd like to share with the audience about what happened here?

Chris Konzelmann: My view is that when a potentially responsible party is identified, they need to be put on notice. They need access to the fire scene, and that joint examination needs to be scheduled, again, so everybody has access to the same information that's out there. If that doesn't happen, we run into potential problems with spoliation. Like a lot of other things in our industry, spoliation is not as big of an issue as it was 10 or 15 years ago because of the training that takes place, but it still does pop up its head every now and then.

There needs to be good communication between the interested parties. That includes the insurance company claim representative, the consultant, and if counsel is involved, counsel. On claims that I handle, I generally get a call from the field on what the preliminary observations are or what the preliminary conclusions are. I immediately ask that consultant to send me his or her photographs that evening. I review the photographs. We have another conversation, and decisions are then made on what we're going to do, if anything, going forward. It's all about communication. It's all about making sure the investigation is done in compliance with 921, so we avoid any problems down the road.

Rod Ammon: Well, Chris, thank you very much for coming on the podcast today. We appreciate it. It always fazes me how many possible complicated issues can come out of one of these cases, and I think you've helped bring some clarity to this. And well, I hope the audience can take some of this away for their work. Again, thanks for your help, and I wish you a good year.

Chris Konzelmann: Thank you, Rod. Thank you very much.

Rod Ammon: What's left of it. All right, Chris. And just a quick update from the IAAI's office. The international office, that is. The 74th ITC, International Training Conference and Expo is being held in Cherokee, North Carolina. It's coming up soon in April. It's April 23rd through the 28th. You can register now and get in there and make sure you've got a place. The place looks beautiful out in Cherokee. I think everybody's going to really enjoy that. Go to www iaaiitc.com and you can get information about the classes that are available, different packages that you can purchase, and more information about Cherokee, North Carolina itself. Again, that's April 23rd through the 28th, 2023. It'll be here before you know.

This podcast and CFITrainer.Net are made possible by funding from the Fire Prevention and Safety Grant, from the Assistance to Firefighter Grant program administered by FEMA and the US Department of Homeland Security. There's also support from the Bureau of Alcohol, Tobacco, Firearms and Explosives, and voluntary online donations from CFITrainer.Net users and podcast listeners.

Thanks for joining us today on the podcast. Stay safe. We'll see you next month. For the International Association of Arson Investigators and CFI Trainer, I'm Rod Ammon

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