By Greg Freeman
Receiving notice of a lawsuit can ruin any risk manager’s day, but how you respond can dictate the ultimate outcome. The best approach is to have a plan in place and execute it carefully once you receive the news.
The number one thing that defendants tend to overlook until lawyers get involved is implementing a document hold, says Heather A. Lee, JD, senior counsel with the Foley & Lardner law firm in Tampa, FL.
“It’s very important to immediately pause all routine document destruction policies. Sometimes, in responding to a lawsuit and making sure that you have counsel on board, that sort of thing that can be missed,” she says. “Implement a document retention right away just to make sure that documents are not accidentally destroyed in the ordinary course, which could later be relevant in litigation. Then that will lead opposing counsel to make arguments about spoliation of evidence.”
Lee notes that the preservation order should include any text messages on personal phones that might relate to the case.
It also is important to be mindful of deadlines, she says. Make sure you pin down the exact date of service, and if you are unclear, reach out to opposing counsel right away, Lee says. Make sure that there is clarity on the deadline for response to avoid a default judgment and that the increased costs that can come with having to get that default judgment are set aside.
“You should also check the docket to make sure that there’s no scheduling order that the court entered kind of immediately after service of the lawsuit,” she says. “More recently, we’ve seen courts are implementing these standard case management orders right away, even before return of service may be filed.”
Checklists can be helpful in responding to lawsuits, but Lee cautions that no two responses will be exactly alike. The action plan will vary according to the type of lawsuit, jurisdiction, and whether the case will be in federal or state court.
“You can have policies on the books that you can roll out to the appropriate teams and the appropriate people. For a sales matter, speak with the sales team. If it’s a contracting matter, speak with the department who might turn in that contract, that sort of thing,” she says. “They should have a routine litigation hold sort of in the can and ready to go. And then they should have the insurance contacts.”
If outside counsel will be retained for the lawsuit, start soliciting those pitches right away and get somebody on board sooner rather than later, Lee says.
Deadlines May Apply
The need for speed depends on a few factors, Lee says. If you are in federal court, absent unique circumstances, you will have 21 days to respond to the complaint, Lee says.
“It can be a pretty quick turnaround, particularly when you consider that that response may be a motion to dismiss, where your retained counsel needs to evaluate arguments based on jurisdiction, failure to assert a claim, all those sorts of things. That 21 days comes and goes pretty quickly,” Lee says. “Now, you can always reach out to opposing counsel and try to get an extension of that initial response deadline. But that’s kind of the number one deadline that you want to be mindful of, your time to respond to that complaint, and that’s why it’s so important to contact your registered agent right away, make sure that you’ve got the date of service correct.”
Opposing counsel might reach out and offer to waive service, Lee notes. Typically, she advises clients to accept that offer.
“You are not waiving any of your defenses in federal court, except for defenses that would relate to defects of service itself, but you’re redeeming all of those jurisdictional defenses so you can still do a motion to dismiss. You get extra time to respond to the complaint. If you waive service in federal court, you get 60 days to respond, as opposed to 21 if you’re served traditionally, so typically, we do suggest clients waive service. In many state courts, you get extra time as well, so it’s something to be mindful of.”
Inaction Can Harm Your Case
The first mistake many defendants make is not doing anything, says Colin J. Zick, JD, partner with the Foley Hoag law firm in Boston.
“You say, ‘Well, you know, it’s unpleasant. I don’t want to deal with it. I’ll just set it aside,’” he says. “Time is of the essence when you’ve got notice of a lawsuit, even though you may think, ‘They’ve already sued me, so nothing can change.’ A lot can change still.”
The day that notice of a lawsuit is received should not be the first time you consider how to respond, Zick says. He recommends tabletop exercises to practice deciding who should be notified, what orders should be distributed, and what time limits apply. Checklists covering different scenarios can be useful. A key step in any lawsuit response is notifying the insurer, Zick says. Insurers typically have an abundance of resources that can help guide responses and defenses, he says.
“Something else you want to think about is what lawyers you want to use. Do you want to use the lawyers who are supplied by the insurer, or do you want to use somebody else, or some combination thereof?” he says.
Do Not Wait for Formal Notice
Formal notice of a lawsuit is not the only trigger for your response plan, says Christopher Lucca, JD, member of the Clark Hill law firm in Philadelphia. The plan should be enacted whenever formal notice is received in the form of a summons, complaint, demand letter, or other legal document, but also when litigation is threatened in some other manner. That may include conversations with an attorney or threats from a patient that they retained an attorney and might sue, he says.
The response also should be triggered when a patient requests complete medical records following an adverse outcome, multiple complaints from the same patient through formal channels are received, a patient refuses to pay bills while citing quality of care concerns, or a serious adverse event occurs with clear potential liability exposure, Lucca says.
Lucca recommends these key steps in a lawsuit response plan:
Notify Key Parties
- Make sure the general counsel’s office is involved.
- Contact relevant insurance carriers.
- Document all notifications with date and time.
Preserve All Records
- Immediately institute a litigation hold and make sure such a notice is sent to all people involved in the incident.
- Suspend routine document destruction policies.
- Secure the complete medical record and prevent alterations (paper and electronic).
- Preserve electronic data, including emails, text messages, and electronic health record metadata.
Initial Assessment
- Review the allegations.
- Identify all involved healthcare providers and potential witnesses.
- Gather all relevant medical records.
- Create a preliminary timeline of events.
- Interview potential key witnesses before memories fade.
- Assess the potential merits of the claim (compliance with standards of care, potential damages).
Communication Control
- Do not discuss the case with the plaintiff or plaintiff’s representatives.
- Limit discussion of the case to privileged communications with counsel.
- Never alter records or create new documentation about the care after receiving notice.
- Medical providers should not access the medical records unless necessary for treatment because audit trails will identify the access.
- Avoid discussing the case on social media or in emails outside of counsel.
Lucca notes that the response plan will need to account for different types of claims. Medical malpractice claims often are governed by specific state statutes with pre-filing requirements, and they typically require expert testimony to establish standard of care, he notes. They may have damage caps depending on the jurisdiction, and they often involve complex medical causation issues. In medical malpractice claims, early expert review is critical. Clinical documentation quality becomes paramount, and the provider’s participation in defense is more intensive, he says. Peer review and quality improvement records must be protected, and the standard of care analysis takes center stage.
With non-malpractice healthcare litigation, there are different categories with different response needs. Lucca offers this explanation:
Employment Claims
- Response led primarily by human resources (HR) and employment counsel
- Focus on documentation of employment actions and policies
- Less emphasis on clinical records (unless relevant to employment action)
Premises Liability
- Emphasize facilities management documentation and inspection records
- Focus on compliance with safety regulations
- Environmental services and maintenance records become central
Privacy/HIPAA Violations
- Information technology systems and audit logs become critical evidence
- Access records and authorization documentation take priority
- Training records and policy documentation become key defense elements
Billing/Fraud Claims
- Financial records become the primary focus
- Coding documentation and compliance processes are central
- Emphasize demonstration of compliance programs
Any response plan should include a checklist of individuals to notify, Zick says. That checklist should cover these needs:
Core Team Members
- Legal counsel: Coordinates the overall response, ensures legal protections, interfaces with outside counsel and insurance
- Relevant clinical leaders: Provide clinical context and expertise
- Tech/records custodian: Ensures proper preservation and production of records
- Administrative leadership: Makes key decisions about resources and settlement authority
Extended Team (as needed based on severity of case)
- Communications/public relations director: Manages external messaging
- HR representative: Handles staff concerns and performance issues
- Compliance officer: Addresses regulatory implications
- Quality improvement specialist: Identifies systemic issues
Team Activation Protocol
- Establish a notification cascade with backup contacts (general counsel should coordinate)
- Schedule an initial assessment meeting with team/relevant providers
The initial response phase can significantly affect the trajectory and ultimate outcome of litigation, Zick says. The most common errors are a delayed response, inadequate preservation of documents, poor witness preparation, inconsistent messaging, and “finger pointing” between providers, he says.
Other mistakes to avoid include failure to preserve documents, altering records or creating records after the fact, and delaying reporting the case to insurers, he says. Discussing cases with colleagues outside the privilege also is a big mistake because text messages between providers can be very damaging, Zick says.
“Evidence preservation ensures critical evidence isn’t lost or altered, preventing adverse inferences. Early case assessment allows for more informed settlement decisions,” Zick says. “Early identification of clear liability cases can reduce litigation expenses and encourage early settlement. Identifying systemic issues can prevent similar claims.”
Alert Team Quickly
The first step is to make sure all members of the team are aware of the notice and that each team member is aware of and carries out their particular roles/duties and assignments, says Craig Creighton Conley, JD, shareholder with the Baker Donelson law firm in Memphis, TN. Counsel, as well as any insurance carrier, should be notified and provided a copy of the notice.
“The notice will need to be reviewed in order to determine if it is compliant with any notice statute/requirements. It will also need to be reviewed for any preservation requests,” he says. “Along these same lines, a litigation hold should be implemented. The chart should be reviewed for completeness, and key caregivers should be identified and interviewed in order to preserve their recollection. In addition to completeness, the chart should be reviewed in order to determine if there are any issues in relation to care. If determined that pre-suit resolution may be amenable, then steps should be taken to attempt same.”
A full response should be triggered only after receipt of an official notice unless circumstances warrant otherwise, Conley says. Depending on the circumstances, it may be advantageous to attempt to reach a resolution with the patient or family prior to either retaining counsel or submission of a notice of intent, he explains. While there is no universal checklist to follow, each provider should develop a checklist to ensure there is consistency in the way of receiving and addressing a notice of intent, he says. This should ensure that key steps are not missed and that each notice receives the same process and procedure in addressing and responding so nothing falls through the cracks, he says.
There should be a standing team to respond with pre-assigned duties, Conley says. “There should be a point person who is in charge of oversight and delegation of duties in relation to the notice. Each team member should have pre-assigned duties as noted [earlier],” he says. “The team lead should be someone in risk management or in claims within the organization. Other team members should include individuals within those departments as well as someone in medical records and in a clinical role. You may also want to include a lead person on the unit or floor in question in order to coordinate interviews, etc.”
How much the response plan affects the outcome of the lawsuit will vary depending on the claim, underlying facts, issues, and counsel submitting the notice, he says. If opposing counsel is reasonable along with the patient or family, early resolution may be possible. Moreover, if the notice and required attachments are not compliant, an organization needs to be careful in responding not to waive any potential defenses related to the notice statute/requirements, he says.
“Key mistakes include not responding to a notice on a case that needs to be resolved pre-suit, failing to implement a litigation hold and preserve documents, failing to evaluate and investigate in order to determine if early resolution is warranted, failing to provide notice to any insurance carrier and failing to get counsel involved, and responding to a notice that is not compliant with statute/requirements,” Conley says.
Preparing a response plan in advance will give more confidence when it is needed, Conley notes. Having a plan will help avoid freezing or dismissing the notice without any action, he says.
“A lot of organizations ignore the notices, thinking that they will not result in a lawsuit because a number of notices do not,” Conley says. “When they do result in a lawsuit, and the proper response and preservation of document don’t happen, it may lead to a negative outcome if a lawsuit is pursued.”
Contact Insurer or Broker
Forward any legal papers you receive directly to the claims department of your insurance broker and/or liability carrier, advises Eric S. Strober, JD, partner with the Rivkin Radler law firm in New York. If you send the paperwork to a broker, ensure that they give the carrier the papers immediately.
“Make sure you have the patient chart, appointment logs, billing records, communications, and any other documents pertaining to the patient or claim secured,” he says. “Do not edit them in any way.”
Strober says a response is needed only when there is a legal complaint filed and served, and that should be done by counsel. However, once a doctor is aware of a potential claim, the carrier should be notified.
“This does not mean the carrier has to be notified of every records request, but rather when there is a reason to believe a claim will be filed,” he says. “There is nothing specifically wrong in a conversation with a patient with questions about their treatment, but once a relationship becomes adversarial, there should not be any direct communication.”
If there are staff who may be involved or can be helpful, advise them of the suit and need for their assistance, but Strober says to be careful not to coach them or discuss the merits of the claim. If a patient calls or comes in after treatment has been called into question, there is a possibility they are recording the conversation or interaction, so act accordingly, he says.
“Once a patient has decided to go to an attorney and proceed with a lawsuit, reaching out to the patient is a mistake. They are represented by counsel, and direct communication is improper,” he says. “They are not going to drop the case and will likely hang up on you. If you do have a conversation, it will be possibly recorded and will be reported to their counsel. If you express annoyance or regrets with them, it will be used against you later.”
Strober notes that some providers, when looking back at their notes, recall things that may not have been noted initially. Adding to or changing patient records is a huge mistake, especially in the age of electronic medical records (EMRs), he says. Plaintiffs’ attorneys often will demand the audit trail for the EMRs, and all access and edits are logged. Reviewing a record is fine, but changing one is not.
“I had a client call a patient to implore her to drop a suit after it had been filed. It only made matters worse and got back to her attorney. I have also had a client redraft entire chart notes after a suit was filed,” Strober says. “This added more problems since the records were suspect — resulting in a complete loss of credibility.”
Consider Immunity Concerns
Prior to the occurrence of any incident, there is a key institutional issue that must be addressed, says Megan E. Bryson, JD, managing partner with the law firm of Coffey Modica in Westport, CT. In some states, such as Connecticut, quality assurance/peer review matters or investigations are afforded statutory immunity, but only in the context of a statutorily compliant body. Generally, in Connecticut, this applies only to a committee of a facility established pursuant to written bylaws, she says.
“Establishing a compliant committee will, in specific jurisdictions, afford a claim of statutory privilege as it relates to the investigation and findings of any such committee. Note, however, that this will not ascribe a privilege to the underlying facts themselves, nor as they relate to any ultimate action taken as a result of the same. So, a restriction of physician/provider privileges would be discoverable, but not the review/thought process underlying the same,” she says. “This mechanism is effective only if in place prior to any such investigation.”
First and foremost, public safety considerations must be addressed, Bryson says. In the context of a nurse accused of sexual assault of a patient, even if the allegations are not deemed credible at the time that they are made, HR personnel should be advised of the issue immediately to ensure appropriate handling both as it relates to patient protection and as it relates to personnel issues, she says. That may include contract/collective bargaining agreement issues, paid/unpaid administrative leave during investigation of complaint, and related issues.
If there is potential criminal/covered conduct at issue, that should be carefully considered, and decision-making regarding reporting should weigh heavily in favor of reporting any issue to appropriate authorities so as not to compound potential civil liability with issues relating to failure to report, Bryson says. This relates to potential criminal reports to local authorities as well as potential mandated reporting of suspected abuse, neglect, exploitation, and/or Department of Public Health reporting for issues such as medication errors.
States may allow for remedial action as a matter of public policy to avoid recurrence without same being theoretically admissible as evidence of negligence, Bryson says. To preserve this type of privilege, all such consideration and resulting adjustments to policies and procedures must be undertaken through proper channels, she says. As soon as there is an indication of potential litigation, a current version of the EMR should be preserved and segregated, she says. Discovery requests for metadata as relates to the EMR are commonplace in modern litigation.
“Equally important: a carbon copy of the records provided pursuant to HIPAA authorization should be preserved with related information regarding to whom and when the records were produced,” Bryson says. “This carbon copy should be preserved in anticipation of litigation to ensure a consistent record for purposes of litigation.”
Given the potential for demands relating to and production of metadata or audit trails, facilities need to ensure that providers update or complete notes in the EMR in a timely fashion, she says.
“In a case a few years ago, a surgeon failed to timely finalize/sign-out his operative note following an intraoperative issue that resulted in a patient’s death several days later. While the narrative note was predominantly drafted at the time of the intraoperative incident and prior to the patient’s death, it was not actually finalized/signed out until after the receipt of a pre-suit demand for records,” she recalls. “The unfortunate result was the automatic timestamping of the operative note months after the surgery at issue and after notice of the imminent lawsuit, based upon the receipt of the HIPAA authorization and demand for records, creating the appearance of an intraoperative report drafted post-patient death in a manner intended to favor the surgeon.”
While this interpretation was completely meritless in the context of the particular case, it created the appearance of impropriety that ultimately becomes problematic in the eyes of a jury, Bryson explains.
Three Key Issues
Bryson offers these three important considerations when responding to a lawsuit:
- Submitting a claim to the relevant insurer/insurance broker to trigger assignment of counsel — the earlier counsel is involved, the earlier attorney-client privilege and attorney work product privileges will afford further protection to investigation of the underlying issue. It is noteworthy that these privileges do not always extend to handling of these issues by in-house counsel (this can vary by state/jurisdiction).
- Involve risk management as soon as possible to ensure compliance with any triggered reporting requirements and/or referral to a statutorily compliant peer review/quality assurance (QA) committee for investigation/review.
- Carefully consider whether written statements from involved individuals should be taken and will be subject to an applicable privilege in the event of litigation — this is certainly a balancing analysis (the weight of contemporaneous/pre-suit statements on balance with the risk that same will not be afforded a cognizable privilege to protect it from discovery/disclosure in the event that any such statement is ultimately unfavorable.
Generally speaking, the mandatory reporting and peer-review/QA privileges will apply only to medical malpractice claims because there is a gray area as it relates to personal injury actions stemming from falls involving patients, she says. Those can be raised as premises liability claims and/or malpractice claims relating to failures to properly evaluate patient mobility or related issues. Additional considerations with non-medical malpractice claims might include determining whether security camera footage of incidents exist and/or whether an area of a fall (or similar case) is investigated and confirmed to be free from defects, Bryson says.
“Security footage should be preserved whether favorable or not to avoid theoretical spoliation claims,” she says. “In the particular case of an alleged defect that is not identified upon investigation, contemporaneous photos or video can be helpful in the course of future litigation to establish the lack of a defect.”
Timely submission of an insurance claim can have significant implications, Bryson says.
“In one previous case, the physician’s insurance coverage was through the employer hospital as it related to a medical malpractice claim. While the primary policy insurer was notified of the claim, a failure to submit a claim by risk management to the excess carrier resulted in a disclaimer of coverage for the excess policy for late notice, which resulted in a declaratory judgment action, ultimately resulting in a judicial determination of late notice warranting disclaimer of coverage,” she says. “While the claim ultimately settled, it necessarily triggered the threat of a bad faith action by the physician against the hospital and resulted in a settlement above policy limits at the expense of the hospital.”
Hospital or facility policies are not, generally speaking, evidence of the applicable standard of care, Bryson says. That said, in the event of non-compliance with an internal policy coupled with an adverse outcome, it will be very difficult or impossible for a jury to untether the policy or procedure from the standard of care, she says.
“To the extent that disclosure is required, if possible, a protective order should be sought, in part, to limit the use of the policy or procedure to the litigation at issue and to preclude dissemination of the policy or procedure beyond those with a need to know relative to the litigation matter,” Bryson says. “This is done to mitigate the risk of policies or procedures disclosed in one matter from being used in other matters, whether by virtue of overlap of counsel and/or sharing of documentation amongst plaintiffs’ attorneys, to establish a departure from said policy or procedure at the risk of jury conflation of internal policies or procedures with the applicable standard of care.”
As soon as a lawsuit is made known — or before that, a demand or notice of claim — notify the appropriate parties and start collecting relevant records and other documents, says Sara K. Harris, JD, partner with the Jackson Walker law firm in Dallas. Each case is different, but in general she says a “first steps” checklist would include the following:
- Confirm the date the lawsuit was formally served to the registered agent.
- Notify the insurance carrier.
- Notify legal counsel (or obtain legal counsel who can handle this type of matter).
- Prepare and send a document preservation notice to relevant custodians and work with information technology to pause regular document destruction processes.
- Begin working on a case assessment with the help of counsel and appropriate internal or external experts.
- Develop a preliminary case strategy. (For example, will informal settlement discussions with the plaintiff be entertained? What about an early mediation?)
Take Complaints Seriously
It is important to take patient concerns and complaints seriously, says Cheryl Camin Murray, JD, partner with the Jackson Walker law firm in Dallas. In particular, when a patient or family member makes a report — especially in writing — to the licensed healthcare provider or management of the organization, it should be promptly addressed with a well-thought-out, documented response.
“If the patient begins requesting medical records, documentation, copies of policies, or starts taking notes about circumstances, it may indicate that he or she is preparing for a lawsuit,” she says. “It is best to be responsive and address any concerns in a timely manner early in the process to prevent escalation.”
Many of these steps will be the same or similar no matter what type of lawsuit is involved, but, for example, in a malpractice case, an early review of the case by a physician expert can help a healthcare organization assess the facts and minimize unnecessary delays, Harris says. However, malpractice claims can be difficult to resolve early because the dispute often focuses on questions around the standard of care, and that reality often will dictate the broader case strategy, she notes.
The individuals involved in the response team can vary depending on the size of the organization, Murray says. A smaller practice may need to include the owner of the practice, the office manager, and outside counsel on their response team. A larger organization, such as a health system, would include their general counsel or in-house attorney, compliance officer, risk management executive, marketing or communications representative, chief information officer or information technology representative, director of HR, as well as key representatives from the executive leadership team.
The way you respond to a new lawsuit can absolutely affect the ultimate outcome of the case, Harris says
“Most obviously, if a defendant does not file any response or answer the lawsuit by the deadline, a default judgment may be entered against the defendant,” she says. “A proactive approach will position a defendant to respond within the prescribed timeframe, preserving key defenses that could otherwise be waived, and will set the organization up to navigate the litigation process without avoidable complications.”
Likewise, an inadequate response — whether that is being unprepared, slow to notify the carrier, or simply taking an early position that is based on emotions and frustrations — can not only hinder the ability to make certain legal arguments, but it will inevitably lead to delay, and delay leads to increased expense, Harris says. Murray says it is important that informal concerns and complaints are addressed quickly and taken seriously. Waiting too long to respond to a patient issue easily could result in that person or their family member seeking alternative, more litigious ways to resolve the matter.
Health practices and companies need to ensure they understand how emails and documents must be preserved and maintained if there is a threat of litigation. In addition, understanding which communications may be considered attorney-client privileged is key, Murray says. Not all communication with in-house and outside counsel is privileged, she notes. The communication must be in connection with the rendering of legal advice and cannot be shared with individuals outside the privilege.
“It is also important that any corporate policies, procedures, and compliance plans are followed when involved in a dispute. There may be protocols and risk assessments that need to take place when a complaint is made by a patient or family member,” Murray says. “Team members need to be trained on these policies and procedures so they know how to handle these high-pressure situations quickly and effectively.”
Healthcare organizations often experience turnover and may be understaffed, making it difficult to promptly respond to patient concerns, Murray says.
“In particular, we have received demand letters or requests for documents and information from clients that are 30 or more days old or received after the deadline to respond,” she says. “It is crucial that emails and letters are regularly reviewed and directed to the appropriate internal or external team member to prevent concerns from developing into full-blown litigation.”
Harris says organizations that take the matter seriously and follow their internal protocols for handling legal matters put themselves in the best position to defend the lawsuit. This includes proactively explaining certain best practices to employees who are aware of the case or who will be involved in the response.
“As one example, defendants who are thoughtful about communications that occur outside the protection of attorney-client privilege can save themselves a lot of headache and embarrassment. It can be tempting to vent frustrations, but what employees say about the dispute in emails, messaging apps, or text messages may be discoverable in the lawsuit,” Harris says. “In our experience, those communications, as well as comments about the lawsuit on social media or to a reporter, are often used against the company later in the litigation.”
Sources
- Megan E. Bryson, JD, Managing Partner, Coffey Modica, Westport, CT. Telephone: (475) 326-5394. Email: [email protected].
- Craig Creighton Conley, JD, Shareholder, Baker Donelson, Memphis, TN. Telephone: (901) 577-2290. Email: [email protected].
- Sara K. Harris, JD, Partner, Jackson Walker, Dallas. Telephone: (214) 953-6074. Email: [email protected].
- Heather A. Lee, JD, Senior Counsel, Foley & Lardner, Tampa, FL. Telephone: (813) 225-4156. Email: [email protected].
- Christopher Lucca, JD, Clark Hill, Philadelphia,. Telephone: (215) 864-8073. Email: [email protected].
- Cheryl Camin Murray, JD, Partner, Jackson Walker, Dallas. Telephone: (214) 953-5726. Email: [email protected].
- Eric S. Strober, JD, Partner, Rivkin Radler, New York. Telephone: (212) 455-9560. Email: [email protected].
- Colin J. Zick, JD, Partner, Foley Hoag, Boston. Telephone: (617) 832-1275. Email: [email protected].
Greg Freeman has worked with Relias Media and its predecessor companies since 1989, moving from assistant staff writer to executive editor before becoming a freelance writer. He has been the editor of Healthcare Risk Management since 1992 and provides research and content for other Relias Media products. In addition to his work with Relias Media, Greg provides other freelance writing services and is the author of seven narrative nonfiction books on wartime experiences and other historical events.
Receiving notice of a lawsuit can ruin any risk manager’s day, but how you respond can dictate the ultimate outcome. The best approach is to have a plan in place and execute it carefully once you receive the news.
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