Melanie Gillette
Partner
Expertise Overview
Melanie’s practice focuses primarily on commercial liability defense, including premises liability, products liability, automobile liability, negligence, catastrophic injury, and liquor liability (dram shop) claims.
Prior to joining Smith Freed Eberhard, Melanie worked at a defense firm in Portland where her practice focused on insurance coverage and bad faith litigation. Prior to that, she worked at insurance defense firms in both Portland and Seattle where her practice included defense of third-party claims.
During law school, Melanie worked as a law clerk for the Oregon Department of Justice, Civil Litigation Section and externed for the Honorable Ronald B. Leighton at the U.S. District Court for the Western District of Washington. She was also an Associate Editor-In-Chief on the Washington Journal of Environmental Law & Policy.
Education
University of Washington School of Law, J.D., 2015
University of Washington, B.A., 2011
Professional Certification & Accolades
Member, Oregon State Bar Association
Member, Washington State Bar Association
Black Belt Trial Advocacy Training Program
Admitted, U.S. District Court of the District of Oregon
Admitted, U.S. District Court of the Western District of Washington
Admitted, U.S. District Court of the Eastern District of Washington
Super Lawyers, Rising Star 2024 - 2025
Best Lawyers in America: Ones To Watch, 2024
Success Story
Commercial Liability Defense Negligence Premises Liability
Pierce County Judge Agrees Scope of Duty Owed by a Non- Possessory Landowner is Limited: MSJ Win in Premises Liability Case
Monday May 12, 2025
Success Story
Automotive Defense Personal Lines
Trial Win: Defense Counters $5 Million Claim in MVA Case
Thursday January 16, 2025
Success Story
Breach of Contract Breach of Express Warranty Jurisdiction Negligence Strict Liability
Secured Motion to Dismiss: Personal Jurisdiction in RV Collision Case
Monday July 29, 2024
Success Story
Commercial Liability Defense Dog Bite Negligence Tenant Landlord
Preserving Precedent: Defending Commercial Landlord Liability Through Recent Victory in High Exposure Dog Bite Case
Thursday October 26, 2023
Success Story
Bad Faith
Billion Dollar Bust
Thursday June 2, 2022
Success Story
Negligence Personal Lines Tenant Landlord
Court Strikes Opposing Party’s Counterclaims Due to Failure to Comply With Discovery Orders
Wednesday October 13, 2021
Success Story
Property Loss Tenant Landlord
4th and 10… An Improbable Comeback Win at the Washington Court of Appeals
Tuesday December 1, 2020
Success Story
General Litigation ORS 20.080 Attorney Fee Personal Lines
When to Fight Back with a Counterclaim
Thursday November 19, 2020
Success Story
Commercial Liability Defense
Securing Victory Under Securities Laws
Friday December 20, 2019
Success Story
Automotive Defense Personal Lines
Research Pays Off (to the Tune of $2.2 Million)
Friday December 20, 2019
Success Story
General Litigation
Drawing the (Property) Line
Friday December 20, 2019
Success Story
General Litigation
Multi-National Retailer’s Discrimination Mitigated
Friday December 20, 2019
Success Story
Commercial Liability Defense
Allegations of Misappropriation of Trade Secrets and Employment Law Violations? Denied.
Friday December 20, 2019
Success Story
Automotive Defense Personal Lines PIP
Rejected: A Desperate Attempt to Recover Expenses
Friday December 20, 2019
Success Story
Commercial Liability Defense General Contractors Jobsite Injury
An $18,000,000 Dismissal
Friday December 20, 2019
Success Story
Automotive Defense General Litigation Personal Lines
The Early Bird Gets the Case Dismissed
Friday December 20, 2019
Success Story
Automotive Defense Personal Lines
Preparation Always Pays off: Especially at Trial
Friday December 20, 2019
Success Story
Automotive Defense General Litigation Personal Lines
The Case of the Mysterious Torn Medial Meniscus
Friday December 20, 2019
Success Story
Automotive Defense Personal Lines
Hit and Run Dismissed
Friday December 20, 2019
Success Story
Automotive Defense Personal Lines
Admitting Liability and Saving Costs
Friday December 20, 2019
Success Story
Commercial Liability Defense Tenant Landlord
A Swift and Speedy Settlement
Friday December 20, 2019
Success Story
Automotive Defense Personal Lines
Know Your Venue: Taking Advantage of Arbitration Rules to Gain the Upper Hand and Mitigate Costs
Friday December 20, 2019
Success Story
Automotive Defense Personal Lines PIP
Pre-Existing Conditions Affirmed, No Additional Recovery Earned
Friday December 20, 2019
Success Story
Dog Bite Personal Lines
Dog Bite Dilemma
Friday December 20, 2019
Success Story
Construction Defect Litigation General Litigation
Cracked Concrete and Damaged Sheetrock
Friday December 20, 2019
Success Story
Commercial Liability Defense
Due Diligence and Maintaining Position Leaves Ashley with a Happy Client
Thursday December 19, 2019
Success Story
Commercial Liability Defense
Can You Picture a Better Outcome?
Thursday March 21, 2019
Success Story
Commercial Liability Defense Construction Defect Litigation Premises Liability
Avoiding the Septic Storm
Friday February 8, 2019
Success Story
Automotive Defense Personal Lines
Small Claims, Big Headache
Thursday December 27, 2018
Success Story
Commercial Liability Defense Negligence
Diligent Preparation and Spotting Fatal Flaws in the Other Side’s Case Leads to Favorable Outcome
Thursday March 22, 2018
Success Story
Commercial Liability Defense
Persistence and Staying Focused on the Facts Leads to Unanimous Defense Verdict
Wednesday January 10, 2018
Success Story
Commercial Liability Defense
Litigation Success: Due Diligence and Maintaining Position Leaves Ashley with a Happy Client
Thursday December 28, 2017
Success Story
Commercial Liability Defense Personal Lines PIP
Occam’s Razor at Work
Wednesday February 17, 2016
Success Story
Automotive Defense Personal Lines
Cleaning the Slate: Using Witness Strengths to Dispel Juror’s Pre-Conceived Notions
Wednesday February 17, 2016
Success Story
Commercial Liability Defense First & Third Party / SIU Personal Lines
Whose Fault is it Anyway?
Friday December 11, 2015
Success Story
Commercial Liability Defense Personal Lines
No Tolerance For Tardiness
Monday October 19, 2015
Success Story
Commercial Liability Defense Personal Lines
Using the Right Rulebook
Monday October 19, 2015
Success Story
Personal Lines
Know the Law In and Out: Developing the Right Game Plan to Keep Costs Down
Wednesday September 16, 2015
Success Story
First & Third Party / SIU Personal Lines PIP
The Show Must Go On
Thursday July 9, 2015
Success Story
Commercial Liability Defense First & Third Party / SIU Personal Lines
Turning Over a New Leaf
Thursday July 2, 2015
Success Story
Automotive Defense Personal Lines
Disproving a Self Serving Story
Tuesday June 30, 2015
Success Story
Automotive Defense Personal Lines
Sticking to Your Guns with Trucking Clients
Tuesday June 30, 2015
Success Story
Automotive Defense Personal Lines
Low Impact Accident Leads to Low Verdict
Tuesday June 30, 2015
Success Story
Automotive Defense Personal Lines
Credibility Clenches Case
Tuesday June 30, 2015
Success Story
Automotive Defense Personal Lines
The Buck Stops Here
Friday June 26, 2015
Success Story
Automotive Defense Personal Lines
Burying Your Head in the Sand Will Get You Nowhere
Friday June 26, 2015
Success Story
Automotive Defense Personal Lines
Plaintiff’s Case Lost in Translation
Friday June 26, 2015
Success Story
Automotive Defense Personal Lines
Disc Bulge Dispute
Friday June 26, 2015
Success Story
Commercial Liability Defense Construction Defect Litigation General Contractors Jobsite Injury
Jobsite Injury Claims Dismissed
Friday June 26, 2015
Success Story
Construction Defect Litigation
A Successful Appeal of OSHA Jobsite Violations
Friday June 26, 2015
Success Story
First & Third Party / SIU Personal Lines
Facebook Detective: Using Social Media to Debunk Exaggerated Claims
Tuesday June 23, 2015
Success Story
Construction Defect Litigation General Contractors
Running Out The Clock
Thursday June 18, 2015
Success Story
Construction Defect Litigation
Window Installation
Thursday June 18, 2015
Success Story
Construction Defect Litigation Subcontractors
Design Defects
Thursday June 18, 2015
Success Story
Commercial Liability Defense Construction Defect Litigation Personal Lines
Breaking Bad Advice
Thursday June 18, 2015
Success Story
Commercial Liability Defense
Bringing Down the House (By Proving Plaintiff Brought Down the Door)
Thursday June 18, 2015
Success Story
Commercial Liability Defense
Snowpocalypse: Negligence and Bad Faith
Thursday June 18, 2015
Success Story
Commercial Liability Defense
Trial Venue: Conservative Controversy
Thursday June 18, 2015
Success Story
Commercial Liability Defense Premises Liability
“Excusable Neglect” – Excused
Thursday June 18, 2015
Success Story
Commercial Liability Defense Premises Liability
Lack of Evidence for an Erroneous Equestrian
Thursday June 18, 2015
Success Story
Commercial Liability Defense First & Third Party / SIU Personal Lines
Road Rage Rebuttal
Thursday June 18, 2015
Success Story
Commercial Liability Defense
Hotel’s Liability Hotly Contested
Thursday November 6, 2014
Legal Alert
Dog Bite Personal Lines Statute of Limitations
Timing Is Everything: The Dog Bite Case That Took a Bite Out of Procedural Rules
Wednesday October 15, 2025
Legal Alert
Dog Bite Personal Lines Statute of Limitations
Timing Is Everything: The Dog Bite Case That Took a Bite Out of Procedural Rules
Monday June 2, 2025
Legal Alert
Commercial Liability Defense Construction Defect Litigation General Contractors Jobsite Injury Subcontractors
Washington Contractors: Foreseeable Risks Impose a Foreseeable Duty
Wednesday May 28, 2025
Webinar
Automotive Defense General Litigation Personal Lines Procedure
Race-Neutral Civil Trials: When Does Race Play a Factor in the Verdict?
Tuesday May 27, 2025
Legal Alert
Attorney Fees General Liability ORS 20.080 Attorney Fee Small Tort Claims
Send Clear and Unambiguous Written Settlement Tenders or Face the Fees: Oregon Court of Appeals Rejects Ambiguous Email Settlement Offer as ‘Tender’ in ORS 2...
Thursday May 1, 2025
Legal Alert
Punitive Damages Tenant Landlord
$10 Million Punitive Damages Award Violative of the U.S. Constitution
Monday August 19, 2024
Legal Alert
Negligence
The Term “Negligence” Is Not Required, but Probably Necessary to Shield Contracting Party from Liability
Wednesday July 24, 2024
Webinar
Civil Procedure Commercial Liability Defense Jobsite Injury Negligence Premises Liability Sexual Misconduct Slip and Fall Tenant Landlord Wrongful Death
Commercial Lines in Oregon and Washington: Recent Case Updates
Tuesday July 9, 2024
Legal Alert
Negligence
When Must a University Protect a Student from Harm Inflicted by a Third Party?
Tuesday July 2, 2024
Webinar
Arbitration Automotive Defense ORS 20.080 Attorney Fee Personal Lines UM/UIM
Personal Lines in Oregon and Washington: Recent Case Updates
Tuesday June 18, 2024
Legal Alert
Civil Procedure
The Washington State Supreme Court Rejects the Apex Doctrine
Tuesday April 2, 2024
Legal Alert
Negligence
Plaintiff’s Preexisting Medical Condition Does Not Always Require The “Substantial Factor” Jury Instruction
Thursday February 22, 2024
Webinar
Bad Faith Commercial Liability Defense
Negligent Claims Handling & Extracontractual Damages
Wednesday February 14, 2024
Legal Alert
Jobsite Injury Premises Liability
When is a Landowner Allowed to Delegate the Duty of Care to an Independent Contractor to Ensure Others’ Safety?
Wednesday January 3, 2024
Legal Alert
Negligence
Can a Medical Professional be Liable to a Patient’s Caregiver?
Tuesday October 10, 2023
Webinar
Attorney Fees Commercial Liability Defense UM/UIM
The Risk of Attorney Fees in UIM Cases: A Brief Update on Recent Case Law
Tuesday September 5, 2023
Legal Alert
Breach of Contract Insurance Defense
Surprise Scope Changes: How a Resulting Loss Clause Can Bring Unexpected Damage Back into Coverage
Wednesday July 26, 2023
Legal Alert
Commercial Liability Defense Premises Liability
Don’t Walk on Thin Ice: The Defense of Implied Primary Assumption of the Risk May Render Unavailable in Snow and Ice Slip and Fall Cases
Thursday June 8, 2023
Legal Alert
Construction Defect Litigation Statute of Limitations
A Contractual Defect: Washington Supreme Court Rules Contractual Time-Limitation Provision Unenforceable in Construction Defect Case
Thursday May 25, 2023
Legal Alert
Negligence Premises Liability Procedure
Plead it or Weep: You Can’t Assert a New Theory of Liability in Response to a Motion for Summary Judgment
Thursday May 18, 2023
Webinar
Commercial Liability Defense Jobsite Injury Negligence Products Liability
Commercial Lines in Washington: 2022 Year in Review
Wednesday May 10, 2023
Webinar
Commercial Liability Defense Negligence Premises Liability Timber Trespass Trucking & Transportation
Commercial Lines in Oregon – 2022 Year in Review
Monday April 24, 2023
Legal Alert
General Litigation
Washington Supreme Court Examines the Use of Racial Bias in a Civil Jury Trial
Thursday April 20, 2023
Legal Alert
Construction Defect Litigation Statute of Limitations
The Action Accrues at Breach: The Oregon Court of Appeals Refuses to Apply the Discovery Rule to Breach of Contract Cases
Friday April 14, 2023
Legal Alert
General Liability Procedure
Millay Preserved: Washington Court Rules No New Standard for Equitable Tolling
Tuesday April 11, 2023
Legal Alert
Arbitration General Liability
The Court Needs Your Autograph: Washington Court Rules A Party Must Personally Sign Requests for Trial De Novo in Arbitration
Thursday April 6, 2023
Webinar
Arbitration Automotive Defense ORS 20.080 Attorney Fee Personal Lines UM/UIM
Personal Lines in Oregon and Washington: 2022 Year in Review
Wednesday April 5, 2023
Legal Alert
Negligence
Oregon Court of Appeals Rules Special Relationship Required for Purely “Psychic Damages” in Negligence Claims
Wednesday February 1, 2023
Legal Alert
Products Liability
When Can a Claimant Sue a Retailer In Lieu of a Product Manufacturer and Who Has The Burden Proof Under the Washington Products Liability Act (“WPLA”)?
Wednesday January 18, 2023
Legal Alert
General Litigation Policy Interpretation
Washington Supreme Court Analyzes Coverage in Tunnel Litigation
Tuesday January 17, 2023
Legal Alert
Negligence
Of Horse and Man: Can a Malnourished Horse Sue Its Owner?
Friday January 13, 2023
Legal Alert
General Litigation Negligence
Not All Spoliation Spoils A Claim
Wednesday December 14, 2022
Legal Alert
Arbitration General Liability
Fun with Arbitration: Washington Rules LLC’s Bound to the Arbitration Clauses in Their Own Operating Agreements
Friday November 18, 2022
Legal Alert
Arbitration General Liability
An Interest in Interest: Arbitration and Post-Judgment Interest Under ORS 82.010
Wednesday November 9, 2022
Legal Alert
General Liability Policy Interpretation
Does Covid-19 Trigger Coverage under a Property Insurance Policy?
Thursday November 3, 2022
Legal Alert
Arbitration General Litigation
You’ve Got Mail: Don’t Miss Your Deadlines Because You are Waiting for Mail
Monday October 24, 2022
Legal Alert
Jobsite Injury Premises Liability
Delegating a Duty of Care: When Can a Land Owner Delegate a Duty to Keep Others Safe to an Independent Contractor?
Thursday October 20, 2022
Legal Alert
Negligence
By Failing to Fully Admit Liability, The Door to Distracted Driving Evidence (Cell Phone Use), May Be Opened
Monday October 10, 2022
Legal Alert
Jobsite Injury Negligence
What Risks Are Assumed in Construction Work and When Can It Bar Recovery?
Monday October 3, 2022
Legal Alert
Construction Defect Litigation General Liability
Time’s Up: Washington Rules Some Nonretroactive Insurance Policies Unenforceable
Monday September 19, 2022
Legal Alert
Personal Injury Wrongful Death
Oregon’s Wrongful Death Statute and ORCP 44C: Who is a “Party”?
Thursday September 8, 2022
Legal Alert
Jobsite Injury
Maintaining Safe Workplaces: Whose Duty Is It?
Wednesday August 31, 2022
Legal Alert
Commercial Liability Defense Sexual Misconduct
Schools Are Held to A Higher Standard of Duty When It Comes to the Safety of Students, But Plaintiffs Must Still Prove That Risk of Harm was Foreseeable
Thursday August 25, 2022
Legal Alert
Arbitration General Litigation
Savings Clauses as Life Savers: How to Resuscitate a Contract
Tuesday August 16, 2022
Legal Alert
General Litigation Trespass Unjust Enrichment
When Words Count: Terms of Art in Unjust Enrichment and Trespass Claims
Wednesday August 10, 2022
Webinar
Dram Shop & Tavern Keeper Liquor Liability
Straight Up: Liquor Liability and Litigation Strategies in Oregon
Monday August 1, 2022
Legal Alert
Products Liability
Washington Supreme Court Asked to Recognize an Exception to the Learned Intermediary Doctrine
Monday August 1, 2022
Legal Alert
Tenant Landlord
A Sigh of Relief from Oregon Landlords as Oregon Court of Appeals Determines a Tenant Cannot Receive “Per Violation” Damages
Wednesday July 20, 2022
Legal Alert
Negligence Products Liability
One Defendant’s Negligence is Another Defendant’s Treasure
Monday July 11, 2022
Legal Alert
Negligence
Inherent Risk of a Sports Activity Is Not Always a Slam Dunk Defense
Tuesday July 5, 2022
Legal Alert
General Litigation Statute of Limitations
Delays Have Dangerous Ends
Wednesday June 29, 2022
Legal Alert
Tenant Landlord
The Defenses Landlords Can Raise Are Limited to the ORLTA
Monday June 13, 2022
Legal Alert
General Litigation
Statutes of Limitations: The Importance of Knowing When a Cause of Action Accrues
Thursday June 9, 2022
Legal Alert
General Litigation Negligence
“Damage” vs “Damages”: Using the Incorrect Form Can Damage Your Case
Friday June 3, 2022
Legal Alert
Products Liability
What is Deception and When Does It Cause Injury?
Wednesday May 18, 2022
Legal Alert
Products Liability
Two Experts, One Reasonable Conclusion: Washington Court of Appeals Grants Summary Judgment Despite Competing Expert Opinions
Thursday May 12, 2022
Legal Alert
Commercial Liability Defense Negligence
Don’t Expose Yourself to Liability for the Actions of a Third Party
Wednesday May 4, 2022
Legal Alert
Commercial Liability Defense Construction Defect Litigation General Litigation
A Partnership Does Not Automatically Create Joint and Several Liability
Monday April 25, 2022
Legal Alert
Premises Liability
Oregon Court Determines When the Exception to Recreational Immunity Applies
Thursday April 7, 2022
Webinar
Bad Faith Commercial Liability Defense
Moody v. Oregon Community Credit Union: An In-Depth Discussion
Tuesday April 5, 2022
Legal Alert
Construction Defect Litigation
Contractors in Washington, Don’t Lose Your Right to Sue. Get Registered Before You Work.
Tuesday March 29, 2022
Legal Alert
Construction Defect Litigation
The Dangers of Covenant Judgments: Insurers Must Typically Show Fraud or Collusion to Reverse a Determination of Reasonableness
Tuesday March 29, 2022
Legal Alert
Wrongful Death
Passion and Prejudice: When an Appellate Court Can Hold a Jury’s Verdict as Excessive
Tuesday March 29, 2022
Legal Alert
Bad Faith ORS 20.080 Attorney Fee
Pre-litigation Bad Faith Conduct Leaves Losing Party Fronting the Bill
Thursday March 24, 2022
Legal Alert
General Litigation Sexual Misconduct Wrongful Death
Spoiler Alert: Washington Court of Appeals Rules Spoliation Combined With Discovery Violations Are Sanctionable by Default Judgment
Thursday March 17, 2022
Webinar
Commercial Liability Defense Negligence Premises Liability Tenant Landlord Wrongful Death
Commercial Lines in Washington – 2021 Year in Review
Thursday March 10, 2022
Legal Alert
General Litigation Negligence
Did the Trial Court Err When it Refused to Give the Substantial Factor Jury Instruction?
Wednesday March 2, 2022
Webinar
Commercial Liability Defense Negligence Premises Liability Timber Trespass Trucking & Transportation
Commercial Lines in Oregon – 2021 Year in Review
Thursday February 24, 2022
Legal Alert
General Litigation Negligence
Au Contraire: Even the Smallest Contradictions in Deposition Testimony Can Make or Break a Case
Tuesday February 22, 2022
Legal Alert
Bad Faith Commercial Liability Defense Negligence Personal Lines
First-Party Bad Faith in Oregon? Are the Floodgates About to Open? Violations of the Oregon Insurance Code Held to Give Rise to the Pursuit of Emotional Dist...
Thursday February 10, 2022
Legal Alert
Commercial Liability Defense Premises Liability Slip and Fall
Airbnb and Hot Tub Liability: Read This Before Your Next Vacation
Thursday February 3, 2022
Webinar
Automotive Defense Commercial Liability Defense Dog Bite ORS 20.080 Attorney Fee Personal Lines PIP Premises Liability Tenant Landlord UM/UIM
Personal Lines in Oregon and Washington – 2021 Year in Review
Wednesday January 26, 2022
Legal Alert
Insurance Law
Silence Isn’t Always Golden: When do Insurers Have a Duty to Remind Their Insured of Their Subrogation Rights?
Tuesday January 25, 2022
Webinar
Commercial Liability Defense Products Liability
Oregon Product Liability Law
Thursday January 20, 2022
Legal Alert
Insurance Law
Insurers Downwind of Lawyer Theft: Must Send Notice Directly To Claimant Whenever They Settle Their Claim
Wednesday January 19, 2022
Legal Alert
Negligence Products Liability
Have You or A Loved One Been Exposed to Damages Inconsistent with the Pleading?
Wednesday January 5, 2022
Legal Alert
Cannabis Law
Cannabis and Insurance Coverage: Don’t Bogard That Hemp!
Wednesday December 15, 2021
Legal Alert
ORS 20.080 Attorney Fee Personal Lines
A Costly Miscalculation: Can Multiple Settlement Offers be Aggregated When Awarding Attorney Fees?
Thursday December 2, 2021
Legal Alert
Personal Lines
Love Thy Neighbor, but Don’t Ignore Your Property Rights
Monday November 22, 2021
Webinar
Commercial Liability Defense Premises Liability
Oregon Premises Liability Law
Friday November 12, 2021
Legal Alert
General Litigation
Double Jeopardy: Can Contempt of Court in a Civil Case Also be a Crime?
Thursday November 11, 2021
Legal Alert
General Litigation
Oregon Federal Court Joins Growing List of Courts to Decide Whether Lost Business Income From COVID-19 Closures Are Covered Under Insurance Policies.
Wednesday September 1, 2021
Legal Alert
Commercial Liability Defense General Litigation Professional Lines (EPL,D&O,E&O) Trucking & Transportation
Indemnification Promises: The Risks of Risk Transfer
Thursday August 12, 2021
Legal Alert
Premises Liability
Premises Liability: Oregon Expands the Application of Comparative Fault
Thursday July 29, 2021
Legal Alert
Construction Defect Litigation General Contractors General Litigation
Washington Supreme Court Says Termination of a Contract, Not for Default, Equals a Termination for Convenience
Wednesday July 21, 2021
Legal Alert
General Litigation Property Loss
You Didn’t Start the Fire, but Does that Mean the Insurer has to Pay Out?
Wednesday July 7, 2021
Legal Alert
Commercial Liability Defense Tenant Landlord
Limitless: How are Statutes of Limitations Tolled When the Cause of Action is Concealed?
Monday July 5, 2021
Legal Alert
General Litigation ORS 20.080 Attorney Fee
A Substantial Benefit Leads to Substantial Fees
Monday July 5, 2021
Webinar
Bad Faith Commercial Liability Defense Jobsite Injury Negligence Premises Liability
COVID-19 in Review: How Emerging Lawsuits Will Impact Future Litigation
Friday July 2, 2021
Legal Alert
Jobsite Injury Premises Liability Slip and Fall
Premises Liability: The Impact of the “Going or Coming” Rule on Tort Liability
Wednesday May 19, 2021
Legal Alert
Dog Bite Premises Liability Tenant Landlord
Pit Bull Attack: Is Landlord Liable for Dog Bite on Leased Property?
Monday May 10, 2021
Legal Alert
Negligence
Do Hospitals Owe a Duty to Protect Others Against Violence of a One-Time Patient?
Monday April 19, 2021
Legal Alert
Commercial Liability Defense
Oregon Supreme Court Says an Insurer’s Duty to Defend Cannot be Contracted Away.
Tuesday April 13, 2021
Webinar
Bad Faith Commercial Liability Defense Negligence Premises Liability Products Liability Sexual Misconduct Tenant Landlord Wrongful Death
Washington Commercial Lines – 2020 Year in Review
Friday April 2, 2021
Legal Alert
General Litigation
Don’t Have the Evidence? What Happens if You Pretend To?
Monday March 22, 2021
Legal Alert
Commercial Liability Defense
Sticker Shock – Did a Typo Cost Toyota $36,000 for Violating Washington’s Consumer Protection Act?
Wednesday March 10, 2021
Legal Alert
Timber Trespass
Oregon Court of Appeals Doubles Down on Double Damages Under Timber Trespass Statute
Thursday March 4, 2021
Legal Alert
General Litigation Negligence
Too Emotionally Distressed to File a Claim for Emotional Distress? Don’t Worry You May Still Have Time
Monday February 22, 2021
Legal Alert
General Litigation ORS 20.080 Attorney Fee
Oregon Supreme Court Limits the Impact of an Offer to Allow Judgment
Thursday February 11, 2021
Legal Alert
Automotive Defense Personal Lines
Texting While Driving? Not Relevant!
Wednesday February 10, 2021
Webinar
Automotive Defense Bad Faith Motorist Minor Impact Personal Lines PIP UM/UIM Wrongful Death
Washington Personal Lines – 2020 Year in Review
Friday January 29, 2021
Legal Alert
Commercial Liability Defense General Litigation Negligence
Once Again, Oregon Court Holds Foreseeable Harm Must be Broadly Construed
Wednesday January 27, 2021
Legal Alert
General Litigation Negligence
Qualified for Recreational Use Immunity? You May Still be Liable
Thursday January 7, 2021
Legal Alert
General Litigation
“Cancel Culture” – Not in Oregon! At Least When it Comes to Insurance Policies: Two Insurance Companies Fined
Wednesday December 16, 2020
Legal Alert
Automotive Defense Personal Lines Property Loss
Washington’s Made Whole Doctrine Majorly Expanded
Wednesday December 9, 2020
Webinar
Commercial Liability Defense Dram Shop & Tavern Keeper ORS 20.080 Attorney Fee Timber Trespass
Oregon Commercial Lines – 2020 Year in Review
Thursday November 19, 2020
Legal Alert
Tenant Landlord
Misrepresentations During the Rental Application Process Do Not Preclude a Tenant from Rights and Remedies Under the ORLTA
Friday November 6, 2020
Legal Alert
Construction Defect Litigation Developers General Contractors Subcontractors
A Contractor May Be Able to Escape Liability for Construction Defects but Only if the Defects Solely Resulted from the Deficient Plans or Specifications
Wednesday October 28, 2020
Legal Alert
Personal Lines Tenant Landlord
Oregon Court of Appeals Determines That Even if a Condition Takes Time to Cause Maximum Damage, the Passage of Time Does Not Necessarily Mean That an Instrum...
Friday October 23, 2020
Webinar
ORS 20.080 Attorney Fee Personal Lines UM/UIM
Oregon Personal Lines – 2020 Year in Review
Friday October 23, 2020
Legal Alert
Commercial Liability Defense General Litigation Personal Lines
New Life Given to Offers to Allow Judgment
Tuesday October 13, 2020
Legal Alert
Bad Faith Commercial Liability Defense
Washington Supreme Court Reminds Insurers That the Benefit of the Doubt is Not Theirs in Questions of Coverage Denial
Monday September 21, 2020
Legal Alert
Construction Defect Litigation General Contractors Subcontractors
Washington Court of Appeals Addresses when a Construction Contract Can and Cannot be Terminated Without a Remedy Period
Wednesday August 26, 2020
Legal Alert
Commercial Liability Defense Construction Defect Litigation First & Third Party / SIU General Litigation Personal Lines Professional Lines (EPL,D&O,E&O)
Oregon Supreme Court Issues Final Determination – Oregon’s $500,000 Noneconomic Damages Cap is Gone, at Least for Those Not Gone.
Monday August 17, 2020
Legal Alert
Commercial Liability Defense Construction Defect Litigation First & Third Party / SIU General Litigation Personal Lines
When Good Lawyers go Bad: Washington Supreme Court Defines “Substantially Related” Within The Washington Rules of Professional Conduct
Wednesday August 12, 2020
Legal Alert
Commercial Liability Defense Construction Defect Litigation General Litigation Personal Lines Professional Lines (EPL,D&O,E&O)
Oregon Extends Statutory Limitations Period on Most Civil Claims Due to COVID-19
Thursday July 16, 2020
Legal Alert
Automotive Defense Commercial Liability Defense General Litigation Personal Lines
Washington Will Soon Require Insurers to Inform their Washington Insureds of the Availability of Agency Assistance
Tuesday July 14, 2020
Legal Alert
Bad Faith Commercial Liability Defense General Litigation Personal Lines Professional Lines (EPL,D&O,E&O)
Washington Supreme Court Holds That an Insurance Company Agent with Authority Can Bind the Insurance Company to Provide Coverage
Friday May 29, 2020
Legal Alert
Commercial Liability Defense General Litigation Personal Lines
Washington Supreme Court Strengthens the State’s Made Whole Doctrine – Drawing Lines as to Where an Insured has Truly Been “Made Whole.”
Tuesday May 26, 2020
Legal Alert
Commercial Liability Defense General Litigation Personal Lines
Washington Court of Appeals Confirms that the Tolling Provisions of RCW 4.16.190 in Minor Personal Injury Actions are Person-Specific and Only Apply to the C...
Monday May 4, 2020
Legal Alert
Commercial Liability Defense Construction Defect Litigation General Litigation Personal Lines
Oregon Court of Appeals Determines that Dismissal Without Prejudice Does not Necessarily Deprive a Plaintiff of their Day in Court.
Thursday April 16, 2020
Legal Alert
Commercial Liability Defense General Litigation Personal Lines Tenant Landlord
Oregon Legal Update: Oregon Supreme Court Addresses Whether it is Prejudicial to Defendants to Allow a Plaintiff to Amend their Pleadings Two Days Before Trial.
Thursday March 19, 2020
Legal Alert
Commercial Liability Defense Professional Lines (EPL,D&O,E&O)
Oregon Court of Appeals Examines “Employee Dishonesty” and “Prior Insurance” Clauses in a Claim Arising from an 8-Year, $800,000+ Embezzlement by Claimant’s ...
Wednesday February 19, 2020
Legal Alert
Commercial Liability Defense Personal Lines
Washington Supreme Court Reverses Summary Judgment Ruling in Favor of Insurer – Reminds Courts of their Limited Duties at Summary Judgment
Tuesday February 18, 2020
Legal Alert
Commercial Liability Defense
Washington Case Update: Washington Court of Appeals Sides with Insurer in Dispute Over How Much a Church Was Entitled to in Compensation Under its Policy Fol...
Thursday May 30, 2019
Webinar
Commercial Liability Defense Tenant Landlord
Oregon Landlord Tenant Law for Commercial General Liability Insurers and Claims Representatives
Thursday May 16, 2019
Legal Alert
Commercial Liability Defense Jobsite Injury Products Liability
Oregon Case Update: Oregon Supreme Court Determines that the Noneconomic Damages Cap Does Not Apply in Any Case Involving Workers’ Compensation
Thursday April 25, 2019
Legal Alert
Negligence
Washington Case Law Update: Unusual Injury Suffered While Riding a Roller Coaster Allows a Plaintiff to Utilize the Doctrine of Res Ipsa Loquitur
Thursday April 18, 2019
Webinar
Minor Settlement Personal Lines Wrongful Death
The When, Where, Why, and How of Settlements Involving Minors, Estates, and Liens
Thursday April 4, 2019
Legal Alert
Dram Shop & Tavern Keeper
Oregon Case Law Update: Disturbing Court of Appeals Decision Reversed – Oregon Supreme Court Reaffirms That Restaurants and Taverns Do Have Immunity Fo...
Thursday April 4, 2019
Legal Alert
Personal Lines
Oregon Case Law Update: Oregon Court of Appeals Reminds Litigants That Medical Bills Alone Do Not Prove That Their Treatment was Reasonable
Thursday March 28, 2019
Legal Alert
Commercial Liability Defense
Washington Case Law Update: Material Facts Available in the Public Domain Lead to Dismissal of Real Estate Buyer's Lawsuit
Thursday March 14, 2019
Legal Alert
Commercial Liability Defense
Oregon Case Update: What Qualifies as an Excess Policy in the State of Oregon?
Thursday February 21, 2019
Legal Alert
Commercial Liability Defense Timber Trespass
Oregon Case Law Update: Oregon Court of Appeals Requires an Insurer to Indemnify its Insured for Intentional Timber Trespass Claim Despite an Exclusion for I...
Thursday February 14, 2019
Webinar
Commercial Liability Defense Personal Lines Slip and Fall
Liability Waivers – Should We Wave Goodbye?
Thursday January 31, 2019
Legal Alert
Automotive Defense Personal Lines
Washington Case Law Update: Plaintiff Must Attempt Service at ALL Known Addresses of Defendant – Whether in Washington or Elsewhere – Before Substitute Servi...
Wednesday January 23, 2019
Legal Alert
Personal Lines
Oregon Case Law Update: Oregon Trial Court’s Award of Reduced Attorney Fees Subject to Remand Due to Insufficient Explanation
Thursday January 17, 2019
Legal Alert
Personal Lines
Washington Case Law Update: Summary Judgment Affirmed After Plaintiff Fails to Provide Evidence Showing the Cause of a Fall
Thursday January 10, 2019
Legal Alert
Personal Lines
Washington Case Law Update: Insured’s Bad Faith Lawsuit is Revived after the Washington Court of Appeals Interprets Ambiguous Insurance Terms against the Ins...
Thursday January 3, 2019
Webinar
Personal Lines
2019 – Year In Review – Personal Lines in OR & WA
Thursday December 20, 2018
Legal Alert
Personal Lines
Oregon Case Law Update: Plaintiffs Must Show Diminished Property Value in Order to Prevail on a Timber Trespass Claim Involving Ornamental Trees
Thursday November 8, 2018
Webinar
Commercial Liability Defense Dram Shop & Tavern Keeper Jobsite Injury Negligence Premises Liability Products Liability Slip and Fall Tenant Landlord Timber Trespass Trucking & Transportation Wrongful Death
2018 – Year In Review – Commercial Lines in Oregon
Thursday November 8, 2018
Legal Alert
Personal Lines PIP
Washington Case Law Update: Damages and Attorney Fee Exposure Can Make a Mistaken Coverage Denial a Costly Error
Thursday November 1, 2018
Legal Alert
Commercial Liability Defense
Oregon Case Law Update: Oregon Court of Appeals Reminds Litigants That Destruction of Evidence Can Warrant Serious Sanctions
Thursday October 25, 2018
Legal Alert
Commercial Liability Defense Slip and Fall
Washington Case Law Update: Washington Court of Appeals Affirms Summary Judgment Against Unrepresented Plaintiff for Failing to Follow Procedural Rules
Thursday October 11, 2018
Webinar
Automotive Defense Personal Lines UM/UIM
Attorney Fee Exposure in UM/UIM
Friday October 5, 2018
Legal Alert
PIP
Oregon Case Law Update: Oregon Court of Appeals Identifies Threshold Level of Evidence Required to Prove an Injury is Permanent
Tuesday September 25, 2018
Legal Alert
Oregon Case Law Update: Servicemember’s Wrongful-Death Claim Tolled While on Active Duty
Thursday September 13, 2018
Legal Alert
Commercial Liability Defense Trucking & Transportation Wrongful Death
Washington Case Law Update: Policy Limit Settlement Exposes Insurer to Bad Faith Claim
Thursday September 6, 2018
Legal Alert
Dram Shop & Tavern Keeper
Oregon Case Law Update: Court of Appeals Confirms Stance on Complicity Doctrine in Case Involving a Passenger Injured by Intoxicated Driver
Thursday August 30, 2018
Legal Alert
Construction Defect Litigation
Washington Case Law Update: Determining Whether Communications Between Attorneys Constitute a Settlement Agreement
Thursday August 16, 2018
Legal Alert
Dram Shop & Tavern Keeper
Oregon Case Law Update: Court of Appeals Provides Insight on the Complicity Doctrine in Liquor Liability Suits
Thursday August 9, 2018
Legal Alert
Commercial Liability Defense
Oregon Case Law Update: Court of Appeals Reaffirms Position on Noneconomic Damages
Thursday July 26, 2018
Legal Alert
Dram Shop & Tavern Keeper
Washington Case Law Update: Bar Owner Brings Suit against Police Alleging Harassment of Patrons and Staff
Thursday July 19, 2018
Webinar
Automotive Defense Commercial Liability Defense Personal Lines
How To Brave the High Seas of Mandatory Non-Binding Arbitration and Live to Tell the Tall Tale
Thursday July 5, 2018
Legal Alert
Automotive Defense Personal Lines
Oregon Court of Appeals Issues Decision on Expert Witness Qualifications
Thursday June 28, 2018
Legal Alert
Commercial Liability Defense
Washington Legislative Update: Washington’s New Law Restricts Access to Medical Records in Discrimination Suits
Thursday June 21, 2018
Legal Alert
Commercial Liability Defense Wrongful Death
Washington Case Law Update: Wrongful Death Claim Invalid After Survivorship Claim Against Same Defendants
Thursday June 7, 2018
Legal Alert
Commercial Liability Defense Dram Shop & Tavern Keeper Negligence
Oregon Appellate Update: Oregon Supreme Court Grants Review in Two Important Cases -Tort Cap and Dram Shop
Thursday May 24, 2018
Legal Alert
Personal Lines
Washington Case Law Update: Washington Legislature Expands Mandatory Civil Arbitration to $100,000 Claims
Thursday May 3, 2018
Legal Alert
Automotive Defense Personal Lines
Washington Case Law Update: Statutory Costs Included When Comparing Arbitration Award with Trial Judgment
Thursday April 26, 2018
Webinar
Automotive Defense PIP UM/UIM
An Introduction to the Updated Rules and Regulations for First Party Claims
Tuesday April 24, 2018
Legal Alert
Commercial Liability Defense Dram Shop & Tavern Keeper Negligence
Oregon Case Law Update: Patron Not Prohibited from Filing Third Party Complaint Against Alcohol Provider
Wednesday April 18, 2018
Legal Alert
Automotive Defense Personal Lines
Washington Case Law Update: In Absence of a Special Relationship, Insurer Owes No Duty to Advise on Adequacy of Coverage
Thursday March 29, 2018
Legal Alert
Commercial Liability Defense
Washington Case Law Update: Injured Worker Responsible for Defective Condition Barred from Recovery from Landowner
Thursday March 15, 2018
Legal Alert
Commercial Liability Defense Negligence
Washington Case Law Update: Can a Firefighter Who Is Injured at an Accident Scene Recover from Parties That Caused the Accident?
Wednesday February 28, 2018
Legal Alert
Commercial Liability Defense
Washington Case Law Update: When is a Visitor Deemed to be a Business Invitee?
Wednesday February 21, 2018
Webinar
Commercial Liability Defense General Litigation
Handling Sexual Abuse Claims in Oregon and Washington
Tuesday February 13, 2018
Webinar
Commercial Liability Defense Construction Defect Litigation First & Third Party / SIU General Litigation Professional Lines (EPL,D&O,E&O)
Recent Landmark Decisions on the Noneconomic Damages Cap in Oregon
Thursday January 11, 2018
Legal Alert
Commercial Liability Defense
Washington Case Update: Internal System for Inspecting Equipment Saves Owner from Premises Liability Claim
Wednesday January 10, 2018
Legal Alert
Washington Case Law Update: Store Owner Cannot Escape from Vicarious Liability for Faulty Escalator
Thursday January 4, 2018
Legal Alert
Commercial Liability Defense
Oregon Case Law Update: Plaintiffs Can Be Barred from Recovery if Engaged in Felony
Thursday January 4, 2018
Legal Alert
Commercial Liability Defense
Oregon Case Law Update: Court Upholds Defamation Claim for Tweets and Customer Website Reviews
Thursday December 14, 2017
Legal Alert
Commercial Liability Defense
Oregon Case Law Update: Plaintiff Who Voluntarily Consumed Alcohol May Sue Social Host. The Effect On Business Unclear
Thursday November 30, 2017
Webinar
Commercial Liability Defense General Litigation Personal Lines
Tough Calls: Ethical Claims Handling in Oregon and Washington
Monday November 27, 2017
Legal Alert
Commercial Liability Defense
Oregon Case Law Update: Oregon Court of Appeals Takes a Swipe at the Statutory Cap on Non-Economic Damages
Thursday November 16, 2017
Legal Alert
Oregon Case Law Update: Court Upholds Liability Limitation in Commercial Lease Agreement
Wednesday November 8, 2017
Legal Alert
Commercial Liability Defense
Washington Case Law Update: Proving Causation: An Expert in a Premises Liability Claim May be Sufficient
Wednesday November 1, 2017
Legal Alert
Oregon Case Law Update: When is Police Officer Testimony Admissible?
Wednesday October 25, 2017
Legal Alert
Personal Lines
Washington Case Law Update: Assert Your Counterclaims in a Timely Manner or Forfeit Them Forever
Thursday October 19, 2017
Legal Alert
Commercial Liability Defense
Oregon Case Law Update: Using an Expert Witnesses to Defeat a Motion for Summary Judgment
Thursday October 5, 2017
Legal Alert
Commercial Liability Defense
Washington Case Law Update: When Will Courts Set Aside a Default Judgment?
Thursday September 28, 2017
Legal Alert
Commercial Liability Defense
Washington Case Law Update: Can Third Parties Sue Insurance Companies Under the Consumer Protection Act?
Thursday September 21, 2017
Legal Alert
Commercial Liability Defense
Washington Case Law Update: When is a Losing Party Entitled to Relief from Judgment?
Thursday September 14, 2017
Legal Alert
Commercial Liability Defense
Washington Case Law Update: Is the Statute of Limitations Tolled if the Wrong Defendant is Served?
Thursday September 7, 2017
Legal Alert
Commercial Liability Defense
Washington Case Law Update: When is a Statement Considered an Offer to Compromise?
Thursday August 31, 2017
Legal Alert
Commercial Liability Defense Personal Lines
Oregon Case Law Update: Amendments Retroactive if Legislature Indicates
Thursday August 24, 2017
Legal Alert
Commercial Liability Defense
Washington Case Law Update: How Do you Determine if a Statement is Defamatory?
Thursday August 24, 2017
Legal Alert
Washington Case Law Update: Employer Not Strictly Liable for Missed Meal Breaks
Thursday August 17, 2017
Legal Alert
Oregon Employment Law Update: Oregon’s New “Predictive Scheduling” Law
Thursday August 17, 2017
Legal Alert
Commercial Liability Defense
Washington Case Law Update: Contract Provision May Entitle Prevailing Party to Attorneys’ Fees
Thursday August 10, 2017
Legal Alert
Commercial Liability Defense
Washington Case Law Update: Participating in Litigation May Constitute Waiver of Certain Arguments
Thursday August 3, 2017
Legal Alert
Oregon Employment Law Update: Oregon’s New Minimum Wage Law Now in Effect
Thursday July 27, 2017
Legal Alert
Commercial Liability Defense Negligence
Washington Case Law Update: Parent’s Negligent Supervision not Tortious, Cannot Reduce Child’s Recovery
Thursday July 20, 2017
Legal Alert
Personal Lines
Oregon Law Update: Oregon’s $500,000 Noneconomic Damages Cap Remains Untouched by Legislation
Thursday July 20, 2017
Legal Alert
Construction Defect Litigation
Washington Case Law Update: No Damages Recoverable under New Home Sale Agreement for Improperly Installed…
Thursday July 6, 2017
Legal Alert
Personal Lines
Washington Case Law Update: Plaintiff Must Be “Foreseeable” to Bring Negligent Infliction of Emotional Distress Claim
Thursday June 29, 2017
Legal Alert
Oregon Case Law Update: No Attorney Fees for Unlawful Withholding of Wages Where Defendant Acted in Good Faith
Wednesday June 14, 2017
Legal Alert
Oregon Case Law Update: Loss-of-Chance Theory of Recovery Established in Oregon
Wednesday June 7, 2017
Legal Alert
Oregon Case Law Update: Oregon Trial Court Rolls Back BOLI Guidance on Overtime Laws
Thursday May 25, 2017
Legal Alert
Automotive Defense Personal Lines
Washington Case Law Update: Post-Arbitration Sanctions Are Not Considered When Determining Whether a Party Improved its Position at Trial De Novo
Thursday May 25, 2017
Legal Alert
Washington Case Law Update: Recreational Immunity Applies Only if Land is Held Open to Public Solely for Recreational Use
Thursday May 18, 2017
Legal Alert
Construction Defect Litigation
Oregon and Washington Case Law Update: Insurance Coverage Cases with “Okay” and “Awful” Results
Wednesday May 17, 2017
Legal Alert
Oregon Case Law Update: Plaintiff Must Provide Substantiating Information with ORS 20.080 Demand to Recover Attorney Fees
Wednesday May 10, 2017
Webinar
Commercial Liability Defense First & Third Party / SIU General Litigation Personal Lines Professional Lines (EPL,D&O,E&O)
Utilizing Probability Analysis in Claims Evaluation: A Systematic Approach
Thursday May 4, 2017
Legal Alert
PIP
Oregon Case Law Update: Evidence Required to Establish Excusable Neglect
Tuesday April 25, 2017
Legal Alert
Washington Case Law Update: Speculation Does Not Create Issue of Material Fact
Thursday April 20, 2017
Webinar
Commercial Liability Defense Minor Settlement Personal Lines Wrongful Death
Minor Settlements and Wrongful Death in Oregon & Washington
Friday April 7, 2017
Legal Alert
Washington Case Law Update: Borrowed Servant Doctrine is Jury Question Where Complete Control is Disputed
Thursday March 9, 2017
Legal Alert
PIP
Oregon Case Law Update: Ninth Circuit Scraps Lawsuit against Rape Accuser under Oregon’s anti-SLAPP Law
Thursday March 2, 2017
Legal Alert
Employment Update: FLSA Overtime Rule Blocked Until May 2017
Wednesday February 22, 2017
Webinar
Commercial Liability Defense
2016 – A Year In Review, Oregon and Washington Commercial Lines
Wednesday February 15, 2017
Webinar
Construction Defect Litigation Design Professionals Developers General Contractors Slip and Fall Subcontractors Wrap Policies Surety
Oregon & Washington Construction Law Master Class
Thursday February 9, 2017
Legal Alert
Washington Case Law Update: When Does Employer Immunity Protect the Employee?
Thursday February 9, 2017
Webinar
Personal Lines
2016 – A Year In Review Oregon and Washington Personal Lines
Friday February 3, 2017
Legal Alert
Oregon Case Law Update: Defendant’s Constructive Knowledge of Abuse Sufficient to Overcome Summary Judgment
Thursday January 26, 2017
Legal Alert
Wrongful Death
Washington Case Law Update: Wrongful Death Claim Accrued Upon Murderer’s Conviction
Thursday January 26, 2017
Legal Alert
General Litigation
Washington Case Law Update: Service by Mail Requires Evidence that Defendant is Avoiding Service
Thursday January 19, 2017
Legal Alert
Commercial Liability Defense Negligence Premises Liability Wrongful Death
Oregon Case Law Update: Oregon Expands Liability for Negligent Infliction of Emotional Distress
Thursday January 19, 2017
Webinar
Commercial Liability Defense Construction Defect Litigation
Laying the Foundation: The Basics of Oregon and Washington Construction Law
Tuesday January 3, 2017
Award & Recognition
Commercial Liability Defense Construction Defect Litigation Dram Shop & Tavern Keeper Jobsite Injury Personal Lines Premises Liability Professional Lines (EPL,D&O,E&O)
Four Smith Freed Eberhard Attorneys Recognized as 2020 Super Lawyers and Rising Stars.
Thursday February 20, 2020
Award & Recognition
Commercial Liability Defense Construction Defect Litigation Personal Lines
2019 Super Lawyers Recognizes 7 SFE Attorneys!
Monday December 30, 2019
Award & Recognition
Commercial Liability Defense Construction Defect Litigation Personal Lines
The Best Lawyers in America© 2019 Announced
Thursday November 21, 2019
Award & Recognition
Commercial Liability Defense Construction Defect Litigation Personal Lines
Smith Freed Eberhard Named Best Law Firm in America 2020.
Thursday November 21, 2019