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By: Beverly Hills Bar Association

Listen to Beverly Hills Bar Association's nationally recognized CLE content, featuring timely topics and speakers from across the country. You don’t need to be an attorney to tune in, but if you are, you’ll get CLE credit while you listen! Full details at www.bhba.org/podcasts.

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Arbitration Essentials for In-House Entertainment Counsel
#245
Yesterday at 11:30 PM

This program will explore the critical importance of close collaboration between in-house and outside counsel to ensure alignment on strategy, cost management, and risk mitigation throughout the arbitration process. Participants will gain practical strategies for controlling costs, managing timelines, selecting arbitrators strategically, and ensuring that the arbitration process supports broader business objectives. Topics will include: Deciding which arbitration rules to apply for your dispute type. Types of arbitration clauses and which ones typically lead to cost overruns. Hiring the right outside counsel. Working with outside counsel to select the right arbitrator. How involved should in-house counsel be in the arbitration...


Trends and Tips for Success Mediating Employment Law Disputes
#181
Yesterday at 2:00 PM

The employment mediation landscape has changed, and knowing how to navigate it makes all the difference. Christine Kurek of Kurek Dispute Resolution, Cynthia Sandoval of Sandoval Mediation, and Julie Arias Young of Julie Arias Young Mediation examine the trends reshaping how employment cases settle, including the rise of emotional distress verdicts, the growing use of anchoring, how to navigate financial difficulty disclosures during the process, and more. Attendees will leave with practical strategies they can apply in their next employment mediation. Audio versions of Beverly Hills Bar Association programs are eligible for Self-Study CLE credit in California. Visit www.bhba...


Patent Litigation Defense in the Trenches: Venue, Local Rules, and the Defense Playbook
#244
Last Wednesday at 11:37 PM

Where a patent case is filed can be almost as consequential as the merits. Local patent rules, individual judges’ standing orders, unwritten “rules,” and judicial temperament vary dramatically across districts. For defendants, those differences can mean everything. Karen Boyd, Thompson Hine LLP, brings a defense-side perspective to the tactical decisions that shape a case from day one: where to fight, how to use early motion practice, and how local rules can be leveraged to narrow the battlefield. Participants will leave with a practical framework for evaluating venue, reading judicial preferences, and making the early procedural moves that strengthen a defense. Audio...


Understanding "Remorse Bias" and the Subjective Nature of Remorse in Legal Processes
#180
Last Wednesday at 2:00 PM

Research shows that legal decision-makers often weigh a defendant's expressions of remorse as highly valuable when estimating character and future behavior during the legal process, particularly during sentencing. Yet assessing remorse in court is a subjective process heavily influenced by the backgrounds of decision-makers and defendants, which fosters and reinforces implicit bias. Dr. Colleen Berryessa, Rutgers University, examines this phenomenon, known as remorse bias, which can lead decision-makers to misread and discount a defendant's true remorse as disingenuous. This can produce adverse outcomes for some defendants in the legal system, especially for those with personal characteristics that are commonly socially...


Tip & Tricks for Enforcement of Family Law Judgments and Orders
#179
Last Tuesday at 2:00 PM

Getting a favorable judgment is only half the battle. Collecting on the judgment it is where the rubber meets the road. Ira M. Friedman, Certified Family Law Specialist, Fellow of the American Academy of Family Lawyers, and partner at Friedman & Friedman, draws on 51 years of enforcement practice to walk attorneys through various tips and tricks of collection tools available in family law matters that has learned over the years in his practice. The program covers foundational methods, including levying on bank accounts and wage garnishments, as well as more advanced remedies such as charging orders, assignment orders, and receiverships. Attendees...


When Seeing Isn’t Believing: Challenging Visual Evidence in Modern Prosecutions
#192
07/24/2026

Video, audio, and digital records have long functioned as anchors of truth in criminal trials. But as AI-generated media, deepfakes, synthetic voice recordings, and manipulated digital evidence become increasingly realistic, that foundational assumption is under pressure. Duncan Levin, Levin & Associates, will examine how synthetic evidence challenges core criminal-trial doctrines, including authentication, chain of custody, voice identification, expert testimony, reasonable doubt, and the jury's ability to decide what is real. Drawing on his experience as a prosecutor, defense attorney, and lecturer on financial crime, Levin will address the current evidentiary framework for digital proof and the limits of existing doctrine in...


Gaining and Maintaining Jurors' Trust
#178
07/24/2026

Although jurors are tasked with rendering a verdict based on the evidence and arguments presented in court, the unavoidable truth is that they often rely heavily on non-evidentiary factors, particularly when faced with a complex or highly technical case. One such factor is perceived credibility, not just of the witnesses but also of the attorneys themselves. Jurors use the perceived credibility of the messenger to judge the credibility of the message. Jury consultant Alexa Hiley, IMS Legal Strategies, will explore strategies for establishing credibility in the eyes of jurors, with a particular focus on how to preserve credibility while advocating...


AI Bias in Employment Decisions: How to Spot, Assess, and Manage Algorithmic Discrimination Claims
#177
07/24/2026

Gurkan Ay, PhD, Director at Resolution Economics, Paul F. White, PhD, Partner at Resolution Economics, and Kacey R. Riccomini of Thompson Coburn LLP will break down how AI-based tools used in hiring, performance evaluation, and compensation create discrimination risk under Title VII, the ADA, the ADEA, and a growing body of state laws including NYC Local Law 144 and California's Title 2 regulations. Gurkan and Paul will draw on real-world examples — driver monitoring systems, applicant assessment tools, call sentiment analysis — to explain how bias audits work and what disparate impact looks like in practice, while Kacey will connect that analysis to the liti...


Trauma-Informed Depositions: How to Prepare and Defend the Deposition of a Trauma Victim
#176
07/23/2026

Preparing and defending the deposition of a client who has been severing traumatized and suffers from PTSD requires more than the standard technique. Mishandled deposition and preparation of a client who suffers from trauma can cause further harm and result in disengagement. Melissa Hague of the Joel Bieber Firm examines how trauma affects memory, behavior, and communication, and what that means for how attorneys prepare and defend trauma victims in a deposition and the courtroom. The program covers trauma-informed strategies for witness preparation, recognizing trauma responses in real time, and adapting your approach to ensure an accurate record. Attendees will...


Unlocking the Power of Generative AI for In House Counsel
#175
07/22/2026

Generative AI is transforming the way lawyers work, and this interactive presentation explores how you can harness its potential to enhance your legal work. Designed specifically for in-house lawyers, Sterling Miller, Hilgers, explores what Generative AI is and, more importantly, how to craft effective AI prompts that deliver practical, actionable insights for legal research, contract drafting, compliance, and more. What You'll Learn: What is generative AI and why it matters to in-house lawyers. How to create clear, specific, and results-oriented prompts that optimize AI outputs. Techniques to use AI prompts to maximize efficiency in daily tasks. Real-world (live and real-time...


How to Write Briefs Judges Want to Read
#174
07/21/2026

In this program, Ryan McCarl, the author of Elegant Legal Writing, will discuss how attorneys can make briefs more readable and persuasive. Drawing on examples from real litigation filings and concepts informed by cognitive psychology, the program examines how judges process information under constraints of time, attention, and working memory — and how lawyers can structure their briefs to help judges focus on what matters. Topics include using an approachable prose style, managing complexity, improving document design, and deploying visual aids such as summaries, diagrams, tables, and multimedia evidence. Participants will also explore citation strategy and brief structure, leaving with practical to...


Modernizing Severability and Delegation Clauses in Employment Arbitration Agreements
#172
07/17/2026

A standard severability clause and a delegation clause can coexist in the same arbitration agreement, but until recently, California practitioners could not be certain a court would honor both. The Ninth Circuit's March 19, 2026 decision in Sandler v. Modernizing Medicine, Inc. provides important guidance for attorneys drafting, enforcing, or challenging employment arbitration agreements in California. Join Jared W. Slater, Ervin Cohen & Jessup LLP, as he examines the court's holding that incorporation of the JAMS rules constitutes "clear and unmistakable" evidence of delegation, and that a generic severability clause referencing "a court or other body of competent jurisdiction" does not undermine that...


Mastering Brackets in Mediation
#171
07/16/2026

The term “brackets” raises anxiety or ire for many mediators and attorneys because it is susceptible to so many different interpretations. (And, of course, there is the math!) This often leads to a knee-jerk resistance to the use of this powerful negotiation technique. This presentation will cover various forms of “bracketing” such as conditional offers, public and private ranges, specific numbers, etc., as well as the many ways brackets can facilitate resolution. Diana L. Maier, Signature Resolution will discuss common assumptions made, benefits and drawbacks of different bracketing methods, timing considerations, and best practices for avoiding bracketing pitfalls and ethical dilemmas...


Nuts and Bolts of Drone Law: FAA, Privacy & What Lawyers Need to Know
#167
07/15/2026

As technology rapidly accelerates, drones and drone law move further from being a niche. In fact, drones are generating legal issues that cut across criminal defense, civil litigation, municipal law, real estate, entertainment, and more. Chances are you already represent clients utilizing drones in some capacity and if not, you may soon as the FAA’s new regulations will make them even more widely accessible in commerce and safety alike. In this introductory, sky level overview, Lauren Brown, Civica Law Group, will guide attorneys through the governing legal framework for drone use in California and beyond. Topics include FAA regulations, Fo...


The John Connor Rule: The Ethics of Responsible AI Under COPRAC
#166
07/14/2026

COPRAC's recent advisory makes clear that efficiency does not replace professional responsibility. Powerful AI systems require human oversight, and the lawyer's obligation to supervise, verify, and own AI-assisted work is non-negotiable under California Rules of Professional Conduct Rule 1.1 and ABA Model Rule 5.3. Christian Puzder of Casefriend examines how attorneys can responsibly integrate AI into legal workflows without compromising ethics, confidentiality, or client interests. The program focuses on accountability-first AI use, covering competence obligations, confidentiality risks under RPC Rule 1.6, and practical frameworks for supervising AI-generated work product. Attendees will leave with concrete protocols for integrating AI tools while satisfying their professional...


AI Prompt Writing: Mastering the Art of the Ask for Transactional Practice
#164
07/13/2026

Ashley Jones of LinkSquares will guide participants through the steps needed to compose focused purposeful AI prompts. Tailored to the unique demands of transactional attorneys, these prompts will address everything from clause generation and customization to document drafting and review. Drawing on practical examples spanning NDAs, deal summaries, complex contract review workflows, and more, participants will gain hands-on strategies to start incorporating AI into your daily legal workflows. By the end of this program, attorneys will be equipped to craft and deploy prompts across every stage of a transaction, saving time without sacrificing precision. Audio versions of Beverly Hills Bar...


Trademark Yourself: The Lanham Act and Likeness Protection in the Entertainment Industry
#163
07/10/2026

The Lanham Act is the federal statute at the center of nearly every trademark and brand protection dispute in the United States, and entertainment lawyers run into it constantly. From artist names and band marks to character trade dress and false endorsement claims, studios, labels, and talent are turning to the Act to shut down unauthorized use before it does real damage. The panel will then turn to one of the most closely watched developments in entertainment IP. When Matthew McConaughey registered “alright, alright, alright” as a sound mark and Taylor Swift filed to trademark her voice and likeness, both were...


Face the Music: Takeaways from the Live Nation / Ticketmaster Antitrust Case
#162
07/09/2026

Live Nation's grip on ticketing, venues, and concert promotion made it the target of one of the biggest blockbuster antitrust cases in the last decade. Taylor M. Owings of Wilson Sonsini Goodrich & Rosati, a former senior antitrust official in the U.S. Department of Justice, walks through the findings in the case, explains how the 2010 Live Nation/Ticketmaster merger set the stage for enforcement, and previews how the concert industry could change as a result of the liability finding. The program also covers lessons learned about antitrust enforcement, including the current roles that federal and state enforcers are playing in...


The Top 7 Strategies That Increase Case Value, and 5 Mistakes That Kill It
#173
07/08/2026

Mike Alder of AlderLaw will examine how insurance companies evaluate attorney behavior to assess risk and shape their litigation approach — and how understanding that process helps attorneys build stronger, better-documented cases. Topics include effective discovery practices, proper documentation of damages, and the litigation habits that consistently move the needle on case outcomes. Attorneys will leave with actionable takeaways they can apply immediately to improve results for their clients. Audio versions of Beverly Hills Bar Association programs are eligible for Self-Study CLE credit in California. Visit www.bhba.org/podcasts for more information.


AI in Tax Practice: Practical Workflows from Tax Research to Tax Court
#161
07/08/2026

Generative AI is moving from novelty to everyday tax-practice tool. This webinar shows what tax attorneys can realistically do today with Claude, ChatGPT, and Gemini, using examples drawn from the work tax lawyers handle every week. Through live demonstrations, Steve will show how AI can help analyze IRS and FTB notices, find and test authority in the IRM and Treasury Regulations, review taxpayer records and bank-deposit data, evaluate agreements against tax issue frameworks such as captive-insurance validity, and prepare a first draft of a Tax Court petition from a Notice of Deficiency. The session will also cover where these tools...


From Engagement to Enforcement: Managing Fee Disputes and Nonpayment for Attorneys
#160
07/07/2026

Aleksandra Hilvert, founder of Vault Legal, provides an in-depth discussion of best practices for avoiding attorney-client fee disputes, protecting your right to payment, and navigating the decision of whether to pursue action when fees go unpaid. Topics covered include key terms to include in engagement letters, setting client expectations around billing, recognizing early warning signs of nonpayment, and understanding options when a client relationship breaks down. Hilvert will also address the practical calculus attorneys face when weighing the financial, reputational, and ethical risks of pursuing collection against the cost of walking away.


LGBTQ+ Allyship for Legal Professionals
#159
07/06/2026

This program explores how legal professionals can move beyond general support of the LGBTQ+ community to practice thoughtful, effective allyship in the workplace. Drawing on the presenter’s perspective as an LGBTQ+ attorney and experience supporting LGBTQ+ advocacy organizations, the presentation covers key terminology and highlights practical examples of effective allyship in the workplace. Attendees gain concrete tools to foster more inclusive environments and promote a culture where colleagues feel supported and empowered to be their authentic selves. Audio versions of Beverly Hills Bar Association programs are eligible for Self-Study CLE credit in California. Visit www.bhba.org/podcasts for mo...


Diminished Capacity? Part Two: Assessing Expert Testimony on Cognitive Impairment at Trial
#158
07/03/2026

Building on the medical framework established in Part 1, this session turns to the practical realities of preparing and presenting expert testimony on cognitive impairment and capacity in the courtroom. Sarah N. Mourra, M.D. and David W. Trader, M.D. return with moderator Judge David J. Cowan to address how experts analyze medical records, structure written reports versus providing oral testimony, and scope their opinions appropriately. The panel explores the critical distinctions between testamentary and contractual capacity, the risks of straying into areas of undue influence or elder abuse that may be beyond their expertise, and how the Sanchez decision...


CTAPP Compliance Reviews: What to Expect, Common Findings, and How You Need to Prepare
#157
07/02/2026

As the State Bar rolls out the Client Trust Account Protection Program (CTAPP) audit requirements, this program will walk you through a sample engagement, present an in-depth review of the first round, explain common findings, and give you ways to better prepare for a CTAPP audit. The session is designed to be collaborative, with a focus on trust accounting and reporting requirements within the CTAPP compliance framework. Audio versions of Beverly Hills Bar Association programs are eligible for Self-Study CLE credit in California. Visit www.bhba.org/podcasts for more information.


Kidfluencers, Child Labor, and Privacy Law Closing the Gaps for a New Generation of Child Workers
#156
07/01/2026

Elinor Haddad, USC Gould School of Law student and Executive Postscript Editor of the Southern California Law Review, presents her award-winning article on the legal gaps leaving child social media influencers unprotected. Kidfluencers operate at the center of a billion-dollar economy with no working hour limits, no permit requirements, and no meaningful privacy rights standing between them and the adults profiting from their content. Using the Piper Rockelle lawsuit as a case study, this program examines the limits of existing law, including the FLSA, the Coogan Law, and COPPA, alongside recent state legislation and the case for a federal response...


What’s New in Influencer Marketing in 2026
#155
06/30/2026

Influencer marketing continues to be one of the most powerful tools for connecting with consumers – but it is also under unprecedented scrutiny. In this program, Allison Fitzpatrick, Advertising + Marketing partner at Davis+Gilbert, will walk through what brands, agencies, and counsel need to know about the rapidly evolving legal landscape governing influencer campaigns. Drawing on recent FTC updates, NAD enforcement actions, and high‑profile class action lawsuits, this session will focus on how to maximize the value of influencer partnerships while minimizing regulatory, reputational, and financial risk. Attendees will gain a deeper understanding of:


It's All in the Timing: How to Win Your Case with Depositions
#154
06/29/2026

Timing is one of the most underused tools in deposition practice. This program shows trial lawyers how to use the seven-hour rule, the order of depositions, and the pacing within each session to gain strategic advantage. From "jack-rabbiting" through testimony to knowing when to slow down and ask for more time to prepare, attendees will learn how the right deposition at the right time can shape the outcome of a trial — or drive a favorable settlement. The program also covers the rules that govern when, and how, courts will limit deposition questioning, and the consequences when deposition limits are exceeded or...


Nuts and Bolts of Non-Competes in California (2026 Edition)
#153
06/26/2026

Rachel Green of Katz Banks Kumin, will review foundational legal limitations of non-competes and related restrictive covenants and demonstrate how California is one of the most protective jurisdictions in the country for workers and workplace mobility. The program will also cover recent state and federal legislative and administrative updates, from AB 692 to the FTC’s retraction from the Biden-era nationwide ban on non-competes, and what it all means for California practitioners. Participants will gain practical tools needed for advising employees seeking to challenge restrictive covenants and awareness of the employee perspective, valuable for those advising employers crafting restrictive covenants. Audio ve...


International Family Law - Italy and the U.S. in Practice
#168
06/24/2026

International Family Law examines how family law disputes are handled across different legal systems, cultures, and jurisdictions. Through in-depth conversations with leading international practitioners, the series explores forum selection, property and support regimes, child custody, enforcement challenges, and conflicts of law, with each discussion grounded in practical comparisons to California family law.

In this episode, Alessandro Gravante of Giambrone & Partners and Marzia B. Ghigliazza of Studio Legale Internazionale Ghigliazza-Rugani explore international family law disputes between Italy and the United States. The conversation covers forum selection and the role of EU instruments including Brussels II-ter, international child abduction...


California Privacy Law on End to End Encryption of Direct Messages
#151
06/24/2026

Meta's March 2026 decision to remove end-to-end encryption from Instagram direct messages has reopened fundamental questions about privacy of social media communication under California law. This program examines what the CCPA requires of businesses handling user communications, where the definition of "personal information" draws the line, and how platform terms of service interact with statutory protections. Don R. Dennis Jr., Law Office of Don R. Dennis Jr., brings current case law and regulatory guidance to the discussion, which extends to connected devices and the unresolved question of third-party exposure when recordings capture more than the consenting user. The program also takes...


Preserving Error for Appellate Review
#152
06/23/2026

In litigation, “wait and see” is not a strategy. Should a trial judge enter an erroneous adverse ruling that prejudicially affects your client, you should have a ready plan and be prepared to implement it immediately to preserve an appellate challenge. This need for quick action arises because, with limited exceptions, appellate courts will not consider issues raised for the first time on appeal. We will tackle the steps required to preserve state court error for appellate review and identify some contexts that call for attention and scrutiny at the trial level. Audio versions of Beverly Hills Bar Association programs are...


In Conversation with Professor Edward Lee: Vibe Coding, AI Authorship, and the Future of Copyright
#150
06/22/2026

We're excited to offer members a rare chance to engage directly with Professor Edward Lee of Santa Clara University School of Law, one of the leading voices on AI, copyright, and the legal questions posed by disruptive technologies. The conversation will focus on his recent paper on vibe coding and copyright authorship, including whether fully AI-generated code retains copyright protection. Audio versions of Beverly Hills Bar Association programs are eligible for Self-Study CLE credit in California. Visit www.bhba.org/podcasts for more information.


Finding Common Ground: Mediating the Complex Financial Case
#149
06/22/2026

Christopher C. Melcher, partner at Walzer Melcher & Yoda LLP, Hon. Joshua D. Wayser of LASC, and Anthony Storm, founding partner at Storm Palyan LLP, will examine how mediation can work in family law cases where the financial stakes are high and the issues are genuinely complicated. Melcher and Storm will draw on their litigation and settlement experience to address the structural and strategic challenges these cases present, from business valuations and complex asset divisions to the dynamics that push parties toward or away from resolution. Judge Wayser will offer a judicial perspective on what courts are looking for, how mediators...


2026 - Trust, Probate, & Conservatorship Annual Litigation Update
#148
06/19/2026

Scott Rahn and Nicholas Van Brunt provide a survey of appellate decisions concerning or relating to trusts, estates, and conservatorships in the last 12 months that are relevant to estate planners, administration counsel, and litigators. Credits: 1.00 Hours. Credit Type: General. Specialty Area: Estate Planning, Trust & Probate Law. Original Air Date: 05/19/2026. Program Materials: https://drive.google.com/file/d/1b5RAa06WXbXoWNR4tC1WlX-8fj7anEqb/view?usp=sharing Audio versions of Beverly Hills Bar Association programs are eligible for Self-Study CLE credit in California. Visit www.bhba.org/podcasts for more information.


Space Law 101 - What Attorneys Need to Know About the Legal Framework Governing Commercial Space Act
#147
06/18/2026

Mary-Christine (M.C.) Sungaila, a partner in the Complex Appellate Litigation Group and Space Law & Policy professor at LMU Loyola Law School in Los Angeles, will provide a foundational overview of the international and domestic legal frameworks governing outer space activity. Drawing on the Outer Space Treaty of 1967 and U.S. commercial space laws, she will cover core principles -- from state liability and private actor oversight to resource mining, orbital debris, and conflict resolution -- and flag the open legal questions that remain unsettled as commercial space activity accelerates. Attorneys will leave with a practical grounding in how space...


International Family Law – Navigating Japan–U.S. Family Law
#169
06/17/2026

International Family Law examines how family law disputes are handled across different legal systems, cultures, and jurisdictions. Through in-depth conversations with leading international practitioners, the series explores forum selection, property and support regimes, child custody, enforcement challenges, and conflicts of law, with each discussion grounded in practical comparisons to California family law.

In this episode, Makiko Mizuuchi of Legal Profession Corporation CastGlobal explores international family law disputes between Japan and the United States. The conversation covers forum selection and jurisdictional strategy, child custody frameworks and the concept of sole custody post-divorce, international child abduction and Hague Convention...


California Workers’ Compensation: A Basic Overview
#146
06/17/2026

Workers’ compensation issues come up more often than you think, even if you don’t practice in workers’ comp. Join Alex McKay of NorCal Advocates, for a practical, straightforward overview of the California workers’ compensation system. Understanding how California workers’ compensation works can help you spot issues, avoid missteps, and better advise clients (and yourself). Whether you represent clients in personal injury, employment, business litigation/transactions, construction, civil litigation, etc. or you run your own firm with employees, this CLE offers practical value for attorneys at every level. Audio versions of Beverly Hills Bar Association programs are eligible for Self-Study CLE credit...


Family Law Transfers . . . All Good Maybe Not – Clawback Litigation in Bankruptcy
#144
06/15/2026

Attorney James (Jim) Menton explores the complex intersection of bankruptcy and family law when there is threatened or actual preference or fraudulent transfer litigation by the trustee in bankruptcy. In this insightful [article/program], Jim unpacks how this litigation could potentially impact transfers between spouses and at divorce and outlines what family law attorneys need to know. Key topics include: Preferential transfers under § 547 of the Bankruptcy Code. Domestic support obligation exception to bankruptcy preference laws. Fraudulent transfers under §§ 544 and 548 of the Bankruptcy Code. Practical considerations for handling preference and fraudulent transfer issues in divorce and bankruptcy proceedings.


Brown Act 2026 Updates
#145
06/14/2026

The newest provisions to the Brown Act aim to modernize teleconferencing options and expand public access to government meetings. Kelly Doyle, Attorney at Cole Huber LLP, reviews the latest updates to the Brown Act under SB 707, with a focus on adapting meeting practices to fulfill the newest legal requirements. Participants will leave with an understanding of best practices for hybrid meetings, policies to handle disruptions, and expanded language access provisions.


What Every Construction Lawyer Should Know about Mandatory Mediation Under SB440
#143
06/12/2026

With the enactment of SB 440, owners, contractors and subcontractors and their counsel must now navigate a mandatory claim dispute process defined by newly-enacted SB 440 (Civ. Code sections 8850 and 8851). The Legislature has made clear that it is in the best interest of the “state and its citizens” to ensure that claims on many private construction projects are “paid in full and in a timely manner”. This program will provide construction lawyers, their clients, insurers, and neutrals with a practical overview of the mandatory dispute resolution process enacted in SB 440, the strategies for how to best use those procedures, and the opportunities created...