Diversity in Practice: Intentional Impact – The Battle for Reproductive Rights

In part one of this year’s Fellows subseries, Wetmore Fellow Nisha Bajania hosts a discussion with MoFo Partner Alexander Lawrence and Melissa Murray, NYU School of Law’s Frederick I. and Grace Stokes Professor of Law and Faculty Director of the Birnbaum Women’s Leadership Network, about the ongoing battle for reproductive rights.

The 3-part subseries on “Intentional Impact,” is designed to look at the ways in which the firm demonstrates its continued commitment to advocacy for people and communities who would otherwise be shut out from access to justice. Each episode is hosted by a 2021 Wetmore Fellow and/or SEO Law Fellow.

Transcript

Speaker: Welcome to MoFo Perspectives, a podcast by Morrison & Foerster, where we share the perspectives of our clients, colleagues, subject matter experts, and lawyers.

Natalie Kernisant: Welcome to the Diversity in Practice Podcast—a part of MoFo Perspectives. My name is Natalie Kernisant and I am the chief Diversity and Inclusion officer for Morrison & Foerster. This podcast series is designed to provide a space to discuss a wide variety of issues related to diversity in the law and to introduce you to some of our talented, diverse attorneys, their areas of legal expertise, and the work that they and their MoFo allies do in furtherance of diversity, equity, and inclusion. It’s also our hope that by sharing D&I best practices, wherever possible, we can help make the legal industry a more inclusive place for those who are, in the words of our MoFo former chair, Bob Raven, just a little bit different.

Nisha Bajania: Hello, my name is Nisha Bajania, and I’m a 1L Wetmore Fellow in MoFo’s San Francisco office. Joining me today are Alexander Lawrence, a litigation partner in MoFo’s New York office, who was co-lead counsel on a previous Texas abortion rights case, Whole Woman’s Health v. Hellerstedt and Melissa Murray, Frederick I. and Grace Stokes professor of law and the faculty director of Birnbaum Women’s Leadership Network at New York University School of Law. Melissa filed an amicus brief in Whole Woman’s Health v. Hellerstedt. Alex, Melissa, welcome to the podcast.

Melissa Murray: Thanks so much for having us.

Alexander Lawrence: Yeah, thanks for having me.

Nisha Bajania: I must say we are really excited to have you both join us today to talk about the crucial work you do in furthering reproductive rights—from being involved in litigating against the newest attacks on reproductive rights in Texas to publishing influential work on the intersection of racial and reproductive justice. Before we jump into the subject of today’s podcast, I’d love to take a moment to get to know each you a little better. Can you both tell us about your trajectory and how you started doing the work you do now? Melissa, why don’t we start with you?

Melissa Murray: So I decided to become a law professor after a summer spent at a New York law firm where I decided that for my career, in keeping with my own personality, it was probably better if I had a job where I was my own boss and no one was telling me what to do. And so when I looked around my law school, it became clear that professors had a great deal of autonomy. They really enjoyed their work. And I decided that was the life that I wanted for myself. So I got to work focusing on an academic track. I clerked for the second circuit and in the district court in Connecticut, and then went on to Columbia Law School to do a teaching fellowship. And from there, I landed a position at the University of California, Berkeley, where I began my career in 2006. And then in 2018, I got this terrific opportunity to switch my life up and go to New York to work at NYU, and it’s been absolutely tremendous. I began my work in reproductive rights at Berkeley, where I was the second faculty director of the Berkeley Center on Reproductive Rights and Justice, and I’ve been able to translate a lot of that work to what I do at NYU.

Nisha Bajania: And Alex, what about you?

Alexander Lawrence: Yeah. So my starting point is I grew up in a family of trial lawyers. My dad is a trial lawyer. My mom is a trial lawyer. My grandparents were trial lawyers, and it’s what I always wanted to be was to be a lawyer who tried cases. My grandmother and my mother and actually one of my cousins had a firm together in our hometown in Chattanooga, Tennessee, and my grandmother, for years, represented the abortion clinic in our hometown in a fight to keep it open. It was a multi-decade struggle to keep that clinic open, to keep protestors off the grounds, to keep access open in our hometown. And it’s a very conservative place. And there were protestors outside of her law office. And the impression I got was I’d like some of that, I like the idea of putting up the good fight and it showed a lot of bravery and a lot of dedication to do what was right. For the first few years of my career, I didn’t work on reproductive rights cases.

Alexander Lawrence: I was a young associate in a law firm learning the skills of being a trial lawyer. I guess it was 20 years ago; I got introduced to the Center for Reproductive Rights. One of my areas of specialty was actually intellectual property law, trademark law, and there was an individual in New Orleans who put an ad in the yellow pages, something that used to exist, right? You would actually have a book with the yellow pages. And Pete was basically masquerading as an abortion clinic, and women would call, and he would lead them on saying that he was going to schedule an abortion for them. And he was quoting a price that was amazingly low for the procedure. And you could imagine the people who call, and this is true across the board. It’s people with limited means.

Alexander Lawrence: And the idea that you could get this procedure done for this amount seemed very appealing. He would lead them on saying the doctor’s out, I’ll call him, and we’ll schedule your appointment. And he just kept leading them on until it was too late, under Louisiana law, for them to actually have the procedure. So we were contacted by the Center for Reproductive Rights and the local clinic there, which name was Causeway, to basically bring a Lanham Act claim against him, which is basically an unfair competition trademark claim against this individual. And the reason to do that is it gives you access to federal court. So we were able to stay out of Louisiana state court, sue this individual, get an injunction against him, and basically shut down a really malicious scheme that he had going on. And that was my first introduction to the Center for Reproductive Rights. And over the years, we worked together on many cases in both Louisiana and Texas, starting in Texas, about 10 years ago, challenging a law that required all patients to have a sonogram before other procedure, and ultimately up to the case that we filed last week, challenging this new law in Texas, which I know we’ll talk about later.

Nisha Bajania: Thank you both for sharing your insightful backgrounds as to how you both got to where you are now. But before we dive into our conversation, I thought it would be helpful to provide some context to our listeners about how we got to where we are today in the reproductive justice movement. In the early 1960s, many states had blanket bans on abortions and others had some exceptions for the mother’s health. People were still getting abortions, but the procedures were dangerous and exclusive to the wealthy. In 1965, the U.S. Supreme court decided Griswold v. Connecticut, which recognized that a constitutional right to privacy applied in the context of married couples using contraceptives. In 1973, came Roe v. Wade, which applied the privacy right to encompass a woman’s decision whether or not to terminate her pregnancy. In 1992, Planned Parenthood v. Casey replaced the trimester breakdown that was established in Roe v. Wade and instead recognized a pre-viability versus post-viability framework.

Nisha Bajania: Viability would mean whether a fetus can survive outside the womb, though the justices did not actually provide a medical definition of viability. Under Roe, states had what was called a compelling interest to regulate at the third trimester, which is approximately 27 weeks, but now can regulate heavily at post-viability, which starts at approximately 23 weeks. The decision also established the Undue Burden Test, meaning that states can regulate pre-viability abortions as long as it’s not an undue burden on the woman’s access to an abortion. So what does undue burden mean? That’s often contested as it was defined as a significant obstacle, which is just as vague as undue burden. More recently, Gonzales v. Carhart in 2007, banned a procedure called Intact DNE abortion, a surgical abortion procedure that takes place after the first trimester of pregnancy. The court decided Whole Women’s Health v. Hellerstedt in 2016 and June Medical Services, LLC v. Russo in 2020, which essentially mirrored the law in Whole Woman’s Health. Now let’s delve into the topic of today’s discussion. Alex, as a partner at MoFo, can you tell us a little bit more about the role of pro bono work in Morrison & Forester’s mission as a law firm, including how decisions are made about what projects to pursue and why reproductive justice is one of those areas?

Alexander Lawrence: Yeah. So pro bono work at Morrison & Foerster is a core tenet here. In my view, it’s unlike a lot of firms in that regard. It’s always encouraged people, if there’s something that is meaningful to you, to get involved. And whether that’s reproductive rights for me, or immigration law for others—voting rights, whatever it may be that you’re passionate about that if it meets with the core mission of pro bono at the firm, get involved. Do it. It’s good for the firm because it provides enrichment to the attorneys who practice here. It’s one of the main reasons that I’ve been here for over 20 years is that given the opportunity to do something thing that is meaningful to me and enriches me and enriches the associates I work with is something that is a plus for everybody at the firm. Over the years, I’ve had the opportunity to work on a lot of reproductive rights cases.

Alexander Lawrence: Clearly one of the most important ones that I’ve worked on is one that you just mentioned, which is Whole Women’s Health v. Hellerstedt. Just background about the case, Texas passed a law in, I believe it was 2013, called HB 2, and it had a number of aspects to it. And the ones that I was involved in challenging—one was a—basically an admitting privileges law. And what an admitting privileges law says is that for an abortion clinic to operate, the physicians who are performing abortions there must have admitting privileges at a hospital within 30 miles of the clinic. And for some people that might—may sound reasonable to say, okay, wouldn’t you rather have a doctor who has admitting privilege so if something goes wrong, you can have easy access to a hospital. But the reality is that abortion is amazingly safe. Complications are exceedingly rare, and it’s very rare that you would have a complication if you did.

Alexander Lawrence: You’re probably not going to have it in the clinic. So you may not deal with the doctor who actually performed the procedure in actually getting care. So it adds very little to no medical benefit. And in reality, in a state like Texas or Louisiana, where they pass these laws and elsewhere, it’s very hard for a doctor who performs abortions to get admitting privileges at an area hospital. There’s a lot of pressure not to give those doctors admitting privileges. And there’s also barriers institutionally to that because it’s so rare that you would admit a patient that hospitals really don’t want to have doctors who very rarely admit patients because most hospitals are for profit and they want doctors who admit patients. So essentially this is what we call a trap law, which is set up to have a veneer of reasonableness, but to essentially shut down clinics. And there was another aspect of the law that basically required all abortion clinics to have the same physical structure as ambulatory surgical centers, which are basically mini hospitals.

Alexander Lawrence: And again, that may sound reasonable to some, would you want to have a new facility that has eight-foot-wide hallways that gurneys can go down and have all of the attributes of a hospital. But in essence, it’s just to increase the cost of providing abortions in the state of Texas and to shut down clinics. And that was the effect of the law. It was allowed to go into effect and clinics across Texas shut down. We challenged the law and ultimately we were able to obtain an injunction in a district court, took that through the Fifth Circuit where we were unsuccessful at the Fifth Circuit, but were ultimately able to prevail at the United States Supreme Court.

Melissa Murray: Nisha, it might be helpful to perhaps put these trap laws in a broader longitudinal perspective. And as you noted in your introduction, Roe was decided in 1973 and offered a right to an abortion that was rooted in the right to privacy that had previously been identified in 1965 Griswold v. Connecticut. But as you say, in 1992 in Planned Parenthood v. Casey, the court really trimmed that back. And it’s worth noting that when Casey was decided in 1992, it was widely anticipated that it would be the case to overrule Roe v. Wade. And in fact, the Bush administration, the first Bush administration, had asked through its solicitor general, Kenneth Star, that the court do just that: overrule Roe v. Wade. The court, of course, didn’t. A very fragile plurality emerged. I believe it was brokered. We don’t know exactly because none of this is public, but it seems clear from the writings that emerged from Casey, that it was brokered by the sort of, of centris juris, Anthony Kennedy, Sandra Day O’Connor, David Souter, and this plurality sought to save Roe in principle, but of course, really trim back on the right that Roe had identified.

Melissa Murray: So as you say, Nisha, it did away with Roe’s trimester framework in favor of this pre-viability post-viability marker. And it also reduced the standard of review from strict scrutiny, which is typically the standard of review for fundamental rights to the undue burden standard, and broadly, it also identified a wider range of room for the states to regulate abortion. And at this point, I think, you have to understand the trap laws that emerged in the wake of Casey as part of a concerted strategy on the part of the pro-life movement. Earlier, before Planned Parenthood v. Casey, a memo emerged that was written by a young lawyer in the Department of Justice to then-Solicitor General Rex Lee, and basically the memo identified various ways to deal with the question of abortion. And one of the issues was should they pursue a frontal challenge to Roe v. Wade—actually asking the court to overrule Roe v. Wade?

Melissa Murray: Or was there another alternative that they might try? And this young lawyer weighed all of the costs. Obviously a frontal challenge to Roe could be very dicey politically given that there was broad public support for abortion, even if people disagreed on the extent and scope of the right. What might be better, he suggested, was instead to do something like make the right less accessible. So, perhaps a series of restrictions and laws that could make it harder for women or a pregnant person seeking an abortion to actually get one. And that young lawyer in the Solicitor General’s office who wrote the memo was none other than Samuel Alito, who as we know, went on to become a justice on the Supreme Court. But the strategy that he outlined in that memorandum really became the strategy that the pro-life movement really put to paper after Planned Parenthood v. Casey, when it became clear that overruling Roe was not likely to happen on the court and it was not likely to happen because of the politics of it. So instead I think what we’ve seen since Casey is many more restrictions from states to limit access to abortion. And again, the trimming away of this right to the point where for many women, including women of color, women who lack economic resources, Roe is really just a right in name only. And so I think that context is really useful in thinking about this.

Nisha Bajania: Thank you, Melissa, for also talking about the greater movement for reproductive freedom for underserved communities like you just mentioned. Staying with you for a moment, going off of what you were just talking about, how critical is it to have this lens at this moment when the Supreme Court may be looking to review Roe v. Wade?

Melissa Murray: Well, I think it’s a great time to think about that broader trajectory in the pro‑life movement. Because again, I think we’ve seen a shift in the composition of the court when Casey was litigated before the court, the reason why people thought that you could overrule Roe is because a Republican president had appointed new justices. And obviously that didn’t happen, but every time the personnel on the court changes and the court moves further to the right, in terms of its ideological makeup, I think we see more emboldened requests to reconsider Roe. And as you know, now, Nisha with the passing of Justice Ruth Bader Ginsburg in 2020 and the appointment of Justice Amy Coney Barrett, we now have on the Supreme Court a six to three conservative super majority, and we’d already seen an emboldened pro-life movement seeking to pass more restrictive laws on the state level and to really push the question of Roe’s ultimate longevity at the Supreme Court and not surprisingly, one of those cases that has been litigated through the lower federal courts has now emerged at the Supreme Court. The Supreme Court will take this up in October term, 2021, and that’s Dobbs v. Jackson Women’s Health Organization, which is a challenge to Mississippi’s ban on abortion after 15 weeks. And I think under the court’s extent, abortion jurisprudence, Casey and Roe, a ban on abortion at 15 weeks is plainly unconstitutional because it occurs before viability. But the fact that four justices voted to hear this case makes clear that there is some appetite on the court to reconsider that extent jurisprudence, and perhaps even to overrule it entirely.

Nisha Bajania: And speaking of battles, Alex, you’ve joined MoFo’s nonprofit partners on the front lines, including recently filing a complaint in Texas, challenging their new abortion law. Can you tell us more about this law and what the plan is to fight it?

Alexander Lawrence: Yeah, so the new law, it’s S.B. 8 in Texas, and essentially it is a six-week ban, which as Melissa said is plainly unconstitutional. So, you cannot ban abortion under existing law prior to viability. And six weeks is way before viability. And in fact, 90% of the abortions that are provided after six weeks, it’s not common to have a procedure before six weeks and many patients don’t even know that they’re pregnant at six weeks. And there’s so many other restrictions in the state of Texas requirements that you have two visits to the medical center, waiting periods, and other chipping away at access to abortion in the state of Texas over the years, pursuant to these trap laws, that it is effectively a nail in the heart of abortion providers in Texas. If allowed to go into effect, it would eventually shut down clinics in the state of Texas, but it has a twist.

Alexander Lawrence: Most bans at six weeks, and there are other states who that have passed them, have done it by basically saying, if you perform an abortion at six weeks, you’re subject to criminal liability. And so it’s enforced by district attorneys. Government officials within the state of Texas directly enforce these laws. This one is a bit different. What the state of Texas has done is said, okay, we are going to write the law in a way such that district attorneys, law enforcement don’t enforce these laws. What we’re going to do is we are going to make a private right of action. So anyone can sue anyone in the state of Texas who either performs or aids and abets the performance of an abortion in the state of Texas. And if they prevail in that case, they can recover $10,000 per procedure. And they can get an injunction against anyone who performs or aids and abets in the performance of the procedure.

Alexander Lawrence: So basically what the state of Texas has done is set up a vigilante system where individuals who are opposed to abortion can go and sue anyone who performs or aids and abets in the performance of an abortion, and it gets worse. So they don’t have to sue in the place where the abortion is performed or where the aiding and abetting takes place. So I’ll give you an example, Texas is a big state, right? So if an abortion is performed in Houston, and someone in El Paso objects to it, they can file a case in El Paso, hundreds of miles away, and force that doctor, or maybe it’s a counselor who has spoken to a patient about their situation and encourages them to follow their instincts and have an abortion and not feel guilty about it. It could be a priest. It could be someone who donates to a fund to help raise funds for patients who don’t have the money to have an abortion. They can be hauled all the way across the state of Texas, sued, have, fined essentially a penalty of $10,000 assessed against them court procedure, and get an injunction against any activity that would violate the law and have their attorney’s fees or the person suing assessed against them without any right to recover their fees if the case is found to be frivolous.

Alexander Lawrence: So it sets up a system that is designed in short order without having the district attorneys or the attorney general enforce the law, get injunctions against anyone who performed a procedure or would assist in having a procedure done and essentially bankrupt them with $10,000 fines per procedure. And that’s the law that we’re challenging.

Nisha Bajania: And staying with this law, Melissa, in your Harvard Review article titled Racing Roe: Reproductive Justice, Racial Justice, and the Battle for Roe v. Wade, you investigated the role of stare decisis and the Supreme Court’s decision on reproductive rights cases. How do you see that playing out in this upcoming Texas challenge and beyond?

Melissa Murray: So the article that I wrote in the Harvard Law Review really focused on reason bans, which are not at issue in the Texas statute, SB 8. A reason ban is a law that prohibits abortion for reasons of sex selection, race selection, or because of the diagnosis of a fetal abnormality. And they have proliferated throughout the country. But one of the reasons that they have proliferated is because they can be harnessed to a broader language and lexicon around racial justice. And so these reason bans are basically touted as anti-discrimination measures for the fetus. This is very different from SB 8, but one of the reasons why I think there is a commonality is that SB 8 is modeled on anti-discrimination legislation that delegates to private citizens the function of basically acting as an attorney general. So it’s a private attorneys general kind of model of anti-discrimination law that authorizes individual citizens to bring particular cases.

Melissa Murray: Obviously SB 8 isn’t about the vindication of civil rights protections per se, but I think the logic of it and its roots in anti-discrimination protection is relevant here. And I think it speaks to the broader initiative throughout the pro-life movement to harness these questions of racial justice and the interest in racial justice and apply it to the fight for reproductive justice. And we’ve seen in the context of these reason bans, arguments that when you think about abortion, you have to think about the implications for the disabilities rights community. The idea that abortion could wipe out entire scores of the disability community in particular kinds of disabilities. And I think all of that is very relevant, certainly worth talking about. But more particularly, I think we’ve seen on the court an effort to really associate abortion with a kind of racial injustice. And this was perhaps most pronounced in Justice Clarence Thomas’ 2019 concurrence and Planned Parenthood of Kentucky and Indiana v. Box where he argued that the reason ban that had been challenged in Indiana was merely the state’s modest attempt to prevent abortion from becoming a tool of eugenics.

Melissa Murray: And he then linked the history of abortion to the history of the eugenics movement, and in particular, Margaret Sanger, who is the founder of the modern birth control movement, and indeed the founder of Planned Parenthood. Margaret Sanger’s history is obviously very different from the history of abortion. She was very much associated with the fight for contraception and contraceptive access as she was actually not a fan of abortion at all, believing that it was a sort of brutal alternative and instead contraception was a much easier way to achieve what she called voluntary motherhood. But I think the idea here is to associate abortion with eugenics, with Margaret Sanger, and also with contraception for the purposes of saying that this too is a tool of racial injustice at a time when much of the country seems particularly interested in vindicating racial injustice and moving toward a more racially just society. And I think the opponents of abortion have tried to link their wagon to that particular movement.

Nisha Bajania: Thank you, Melissa. And I want to hear from both of you, what do you both think is next for the fight for reproductive justice and how can people will get involved in this fight? Alex, why don’t we start with you?

Alexander Lawrence: Over the years, these types of laws have basically become more and more brazen, right? So of all the laws that I’ve challenged over the years, they have a patina of reasonableness—so a sonogram law that you have to have a sonogram before you have a procedure; like we talked about the admitting privileges laws and the ambulatory surgical center. Laws that you have to provide a burial to the fetal tissue. Laws that ban the D&E procedure, which the anti-movement is very opposed to, but which is critical. They, at least in public view, may have some sense of that sounds like something that perhaps there should be some restriction there, when in fact they’re designed to cut at the core of the right. Now, they have become much more brazen, in my view. And this latest law is not only an attack on abortion, essentially a ban on the procedure, but in my view, it’s also an attack on the rule of law—that rather than having enforcement by state authorities, that you would open up vigilante justice, where essentially private individuals are suing their neighbors. That’s a frightening thought and can really be misused. And really, it does seem to be open season in these state legislatures with respect to abortion rights. And we should have hope at the Supreme Court, but clearly there has been a change in composition there. So it’s just a critical time for this fundamental right.

Nisha Bajania: And Melissa, what about you in your personal opinion? What’s next for the fight for reproductive justice?

Melissa Murray: I definitely think we are going to see the opposition to abortion joined with the opposition to racial injustice and an attempt to sort of think about reproductive rights as racial injustices to particular communities. And that’s already beginning. And I think we’re are going to see that pick up steam because there is something I think quite compelling about that idea. We all saw the protests around George Floyd’s murder last summer. We have seen the movement for black lives really take root, not just in this country, but around the world. I think it’s incredibly provocative and probably very productive for the anti-abortion movement to frame its claims in the language of racial justice. And I think we’ll see that going forward, certainly through these reason bans. Where can individuals intervene to have maximum impact? I get a lot of questions from people about the federal courts about federal litigation and I always come back to this question.

Melissa Murray: Once you are fighting in the federal courts over this issue, you’ve already really missed your chance. There’s so much work that could be done on the state level, whether it’s in state legislatures or in local legislatures. If you can stop these restrictive laws from being passed in the first instance, then you’re not fighting in the federal courts. And right now, a lot of what we’re seeing throughout much of the country is that there are legislatures, especially in these red states that are absolutely captured by one political party, and that’s why you’re seeing the most restrictive laws coming out of those jurisdictions. They are really playing to a base for whom anti-abortion legislation is paramount. If you want to have a maximum impact, go to those states and get involved in their politics at the local level and prevent those laws from taking root.

Melissa Murray: But that’s a long-term strategy, but it’s one that I think a lot of people are beginning to take seriously. One of my former students at Berkeley Law, Lala Wu, helped found Sister District Project and their whole mission is to identify state legislatures that are on the cusp of turning blue. Like they might be a little purple or maybe they’re red, but on the cusp of turning purple so that there can be a be a better defense against some of these laws. And they really work to put progressive candidates in those places so that they can be successful and so that the legislative commitment to reproductive rights can be realized in those jurisdiction. And I think that’s something that we really have to take seriously—stopping these fights before they even start.

Nisha Bajania: Thank you, Alex and Melissa, I agree. I think that’s a really good point that people should get involved at the local level as opposed to seeing it in the federal level. I think there is definitely a lot more impact at the local level in regarding to state laws, but I wanted to thank both of you for this engaging conversation about reproductive justice and MoFo’s role in the greater movement for equal access to healthcare and reproductive freedom for everyone.

Melissa Murray: Thanks so much for having us, Nisha.

Alexander Lawrence: Oh, thank you for having us.

Nisha Bajania: Of course. And I also want to take a moment to thank my colleagues, Wetmore Fellows, Mary Cao, Kavisha Patel, Melissa Stewart, Jose Urteaga, and SEO Law Fellow Gabby Alvarez for their contributions to this project. Thank you everyone.

Speaker: Immediately following the recording of this episode, a five to four majority of the U.S. Supreme Court, citing procedural irregularities denied a request to enjoin the Texas law that effectively bans abortion at six weeks. The court insisted that it was passing judgment on the law’s constitutionality, which remains a subject of a legal challenge brought by MoFo at its cold counsel. Despite these caveats, the practical effect of the court’s decision is to allow the law to remain in effect in Texas as the legal challenge to its constitutionality proceeds. On September 9th, the U.S. justice department filed its own suit to stop enforcement of the law. And on October 6th, a district court judge in the Western District of Texas ruled in their favor and issued an injunction. Unfortunately, three days later, the Fifth Circuit stayed that decision. As a result, women’s constitutional right to choose abortion has once again been suspended in the state of Texas.

Speaker: Please make sure to subscribe to the MoFo Perspectives Podcast so you don’t miss an episode. If you have any questions about what you heard today or would like more information on this topic, please visit mofo.com/podcasts. Again, that’s M-O-F-O, mofo.com/podcasts.