Lawyer Who Says She Was Chastised for Not Being Sweet Is Allowed to Sue

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Lawyer Who Says She Was Chastised for Not Being Sweet Is Allowed to Sue

Posted Aug 5, 2008, 07:21 am CST
By Debra Cassens Weiss

A federal judge in Manhattan says a managing partner’s remark that a female lawyer wasn’t sweet enough could be construed as discriminatory animus supporting the woman’s bias and retaliation suit.

The ruling allows fired lawyer Catriona Collins to proceed with her suit against intellectual property law firm Cohen Pontani Lieberman & Pavane, the New York Law Journal reports. Collins alleges the firm’s managing partner, Martin Pavane, said she was being insufficiently sweet in dealing with a paralegal.

"A reasonable jury could find that Pavane's statement indicates that (1) he holds stereotypes that women should be 'sweet' and non-aggressive, and (2) that Pavane believed that plaintiff did not fit this stereotype," Judge Kimba Wood wrote in the July 30 opinion (PDF).

Collins alleges she was told she would never become a partner because male partners were “uncomfortable” with her, according to the story.

The law firm says it fired Collins for sending “insulting and unprofessional" e-mails on Sept. 18, 2003, to lawyers and paralegals, and that she had a history of clashing with others at the firm.

But Wood said some evidence suggests the firm decided to fire Collins for an e-mail sent two days before in which she said the firm was “behind the times” because it was not giving enough responsibility to women lawyers. The e-mail concluded that women lawyers at the firm were being "relegated to non-partnership track support roles."

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Posted by Filk Bahr - 4 months, 5 hours, 46 minutes ago

Yes, it is likely case of discrimination on basis of gender.
Posted by associate - 3 months, 4 weeks, 2 days, 8 hours, 41 minutes ago

Most IP work is proseuction. You have to be very subtle in making your point with your clients (customers) and with the PTO Examiners (if you hope to make any headway).

These guys were apparently dead on in their judgment of her. It looks like subtly making her point is not one of her strong suits.
Posted by reader - 3 months, 4 weeks, 1 day, 11 hours, 48 minutes ago

This attorney sounds like an unpleasant person to work with. But no male attorney would EVER be criticized for being “not sweet enough.“ For that matter, no male of any profession would ever be accused of that. Except maybe a hairstylist.
Posted by Larry Larocca - 3 months, 4 weeks, 15 hours, 25 minutes ago

I’m a man and I have to be masculine—otherwise Im critized. Why can’t a female who isn’t feminine be similarly critized and get a lawsuit out of it? Isue. Maybe their shouldn’t be lawsuits allowed on this issue.
Posted by C - 3 months, 4 weeks, 8 hours, 52 minutes ago

Larry,

Because it’s based on the assumption that if you’re a white male you can’t be discriminated against. However, when they do discriminate they slap a label on it and call it affirmative action. So quit being a sexist just accept the fact that you and every other man is part of a widespread, systemic and pervaisve problem. Maybe she’ll get a judge who’s “sweet” and sympathetic.
Posted by J - 3 months, 3 weeks, 6 days, 17 hours, 10 minutes ago

“So quit being a sexist just accept the fact that you and every other man is part of a widespread, systemic and pervaisve problem.“

And this is demonstrated how? By the larger number of male partners?
Posted by silencedogood - 3 months, 3 weeks, 6 days, 17 hours, 3 minutes ago

I think many of you would take a different view if you substituted “you are not being sweet” with “you are being an a-hole”. How many org’s have a “no a-hole” policy?

So does this whole case really come down to the choice to use the word “sweet”? If so, can I please get the official P.C. list of words which are assigned to various groups so I don’t inadvertantly run afoul of them?
Posted by Bob - 3 months, 3 weeks, 6 days, 16 hours, 53 minutes ago

My law firm has a no “a-hole” policy that works quite well. We lose some of our “best” lawyers that way! But any partner who tells a female associate she is not “sweet” enough is, really, behind the times. I doubt that is what happened, actually, and the larger story is a frustrated, unhappy, ambitious associate who would probably be way better off spending her time finding a firm that appreciates her, um, talents.
Posted by Lysander - 3 months, 3 weeks, 6 days, 16 hours, 51 minutes ago

A male probably wouldn’t be criticized for not being “sweet” enough, but he might be criticized for being overly aggressive, abrasive, or harsh. Any lawyer who has trouble getting along with colleagues or clients may need to be criticized. I think we all need to be a little less thin-skinned, accept criticism with a little more humility, and stop looking for a lawsuit at the drop of a hat. It sounds as if this woman was not being a very effective lawyer, so now she’s going to make the firm pay for it. She should get over it and figure out how to get along with people better.
Posted by Lyman - 3 months, 3 weeks, 6 days, 16 hours, 36 minutes ago

Well, OBAMA calls women “sweetie”. Where’s the outrage? Cognitive dissonance strikes again. I agree with Lysander.
Posted by Jade - 3 months, 3 weeks, 6 days, 16 hours, 28 minutes ago

Isn’t it common knowledge that if people don’t like you, then you won’t make partner? That’s true if you’re female OR male.
Posted by Jade - 3 months, 3 weeks, 6 days, 16 hours, 23 minutes ago

Larry, if your boss tells you you have to be more masculine, perhaps YOU should sue as well.
Posted by Hadley V. Baxendale - 3 months, 3 weeks, 6 days, 16 hours, 13 minutes ago

A Federal case over a poor choice of words? It appears that the plaintiff acted in an overearing manner to a subordinate. The partner was right to correct her. What if the firm were sued by the subordinate for the associate’s abusive behavior?
Posted by Jenny - 3 months, 3 weeks, 6 days, 15 hours, 51 minutes ago

Hmmmm. Sounds like the judge simply denied a 12(b)(6) motion here, folks. I’d want to see the pleadings, but I imagine I’d do the same. There’s probably a bigger story to tell here, and the judge is simply allowing Collins to do it. Most of the comments ignore that she was fired, not just “corrected.“ The firm says they fired her because her 9/18/03 email was “insulting and unprofessional”, but the email language quoted in this article seems pretty mild to me (difficult, confrontational, and unwelcome, certainly, but sometimes a hard truth needs to be told). Perhaps the ABA Journal reporter has ignored—or discovery has not yet produced—the terrible insults and unprofessional language Collins supposedly hurled at her colleagues. But suppose it’s not there—she gets fired for pointing out that women don’t get enough responsibility at the firm and that they were being relegated to non tenure track roles. Doesn’t that raise “retaliation” red flags for anyone? And in that context—the specific factual context in which this woman was fired—might we hear the demand for “sweetness” just a little differently? She hasn’t won the case; she just gets a chance to conduct some discovery and make her proof.
Posted by Sally - 3 months, 3 weeks, 6 days, 15 hours, 42 minutes ago

I’ve been through this - the staff at my firm were guided by the partners to be of the view that, as between men and women, the men came first. It was reflected in the way that secretarial support was allocated, the tone of voice used by the partners in speaking to the women associates, and the fact that partners would often observe a secretary blowing off a female associate and take no action. For example, one member of the staff routinely told me that no conference rooms were available, but if I had my junior male associate call for a room moments afterwards, suddenly there would be a wide choice available. Similarly, our word processing department would routinely fail to complete my work, saying they had insufficient staff to handle it, but if I had my junior male associate submit it - even without reserving time in advance - it was routinely completed without incident. At first, I was bewildered by this - it never occurred to me that, in the late 1990’s, this would be an issue. So the problem wasn’t that I was angry or abrasive. I do know now, having spoken to the same people from a different perspective, that they found me arrogant simply for thinking I was entitled to a conference room when I had clients coming in. Later, of course, when I realized what was going on and that the partners weren’t going to lift a finger to help me - and in fact, said that the reason for the problem must be that I wasn’t “nice” - I did get angry. Then, I admit, I wasn’t “sweet”; I came to the conclusion that I could get my job done, or I could have all the staff think I was “nice”, and since their behavior was unfair, I was not so worried about them liking me so I’d get my job done. Nonetheless, this is an impossible position to be in. At one point, our head of secretarial services, the person who was responsible for instructing the staff on what their jobs were and how to do it, explained to me that she fully sympathized with staff who didn’t want to work for women, because after all, they shouldn’t have to do menial work for women. I repeated this to the supervising partner; he thought it was funny, and did not recognize at all the pervasive impact this was having on the women lawyers trying to get their work done (or the fact that I was the only female associate in my class by the 5th year, the only one not smart enough to get out).

I was lucky; for a variety of reasons, I made it through and made partner, despite a constant stream of complaints from support staff that I wasn’t “nice” and partners who took those complaints on board without once looking into whether there was any reason that I might have had to exert pressure in order to get the staff to do their jobs in order to permit me to do mine. I’ve now been a partner for about 8 years. A year or so ago, the head of our office staff told me that the staff thought I was so much nicer now, and thought it was great how much I’ve changed. I told her that I could be a lot nicer now that the staff did not tell me to f*** off every time I asked them to do their jobs. She was startled, but after we talked about it a while (we get along pretty well), she “got it”, and I’ve actually seen further improvement. One of the things I’ve focused on as a partner is advocating for women when they get stuck in these positions. Women are often still faced with the choice between being “nice” and getting the support that every white guy expects to get, and gets, just by walking into a room.

Note that I’m not accusing all the white guys of causing this problem, though the inability to see it when it happens does permit it to continue. But the problem here may well not be a poor choice of words. This may be just a relatively concrete example of the kind of bind I was in for all the years I was working as an associate - if I was “nice”, I could not get my work done, so I was ineffective as a lawyer. If I was not “nice”, I was criticized for not being nice. And even if I was “nice” by any standard applied to any of my male colleagues, it was still perceived as “not nice” because it was considered “not nice” for me to assume that my work would be given the same priority as that of my male colleagues.

Yes - if people don’t like you, you won’t make partner and that’s life. But if the reason they don’t like you is because they impose different standards on you and handicap you for reasons based on your gender, that can be discrimination.

Like most serious issues, these situations don’t lend themselves to sound bites, which makes them unfortunate blog topics. I don’t know who’s right in this case, but I suspect this lawyer’s situation is similar to what mine was, and if that’s the case, there is discrimination here.
Posted by Jenny - 3 months, 3 weeks, 6 days, 15 hours, 42 minutes ago

One correction on my comment above—this was a summary judgment ruling, so some discovery has occurred. Still, remember that the standard for obtaining summary judgment is pretty onerous—is there “no genuine issue as to any material fact” here? Again, putting all these events together, based only on the little I’ve read in the media reports, the judge’s ruling seems pretty reasonable.
Posted by Melissa - 3 months, 3 weeks, 6 days, 15 hours, 39 minutes ago

Thank you Jenny for pointing out what all of us lawyers should have noted instead of being so quick to judge…
Posted by Diamond Jim - 3 months, 3 weeks, 6 days, 14 hours, 51 minutes ago

Isn’t this the same Kimba Wood who was nominated by Bill Clinton as Attorney General because she was such a “sweety”?
Posted by John P. Horan - 3 months, 3 weeks, 6 days, 14 hours, 50 minutes ago

It costs one nothing to be kind and respectful. A young lawyer should not act like a jerk. If a young lawyer is being a jerk, a partner should correct the behavior in a kind and respectful manner. These basic rules apply to partners and associates of both sexes.
Posted by DCEsq. - 3 months, 3 weeks, 6 days, 14 hours, 49 minutes ago

Bravo to Sally (post 15) for injecting real life perspective. As always, truth is stranger than fiction and Sally’s Kafkaesque experience could be the same as the plaintiff’s. But it’s hard to tell truth from fiction when 7 sentences are used to describe a court docket. Thus, our ability to comment is basically limited to hypotheticals - shades of law school.
Posted by DCEsq. - 3 months, 3 weeks, 6 days, 14 hours, 45 minutes ago

What is a “jerk”? It seems to be to be a rather vague concept, like “justice,“ and would benefit more from - oh I don’t know - a hypothetical example. As lawyers we are, after all, paid by the word. Well, not really but one may get my point.
Posted by C - 3 months, 3 weeks, 6 days, 14 hours, 34 minutes ago

I’m a young attorney and one of my colleagues scolded me for driving too fast on my way home one day. I’m 27 - he’s 55. Should I sue for age-ism? :)
Posted by Stevie B - 3 months, 3 weeks, 6 days, 14 hours, 22 minutes ago

Reminds me of when I attempted to get a US based MD or DO on top of my JD and MSEE. An incident when I should have sued - but did not, and since I ended up going overseas find I cant get a residency.
Interview at a school in California:
“What do we have here, are you a professional student?“
Posted by Kristy - 3 months, 3 weeks, 6 days, 14 hours, 12 minutes ago

Thank you Jenny and Sally for showing that there are reasonable people in this field. Men don’t understand what women go through on a daily basis to be “equal” in the workplace. They want women to act one way but force them to act another way just to be “equal” then complain about it.

But the fact is, we don’t have the facts here. All these comments about this female attorney being abrasive etc. stem from what the firm said. Well, do you really think the firm is going to admit the were sexist????? Come now, if you don’t have the facts, how can you make a decision. The court was correct to let her make her case based simply on the the phrase because it could lead to more pervasive evidence of sexism in that workplace. Anyone who thinks otherwise, please do not ever become a judge.
Posted by Frankie Hollywood - 3 months, 3 weeks, 6 days, 14 hours, 11 minutes ago

What exactly did the male partner say? The article doesn’t state. Did he state, “You need to speak more sweetly” or did the female say, “So, you want me to speak more sweetly?“, to which the partner agreed? I see a big difference. Her words v. his words. The article doesn’t make it clear. P.S. white males are the devil. THE DEVIL!!
Posted by Cathy - 3 months, 3 weeks, 6 days, 14 hours, 9 minutes ago

This reminds me of the day I was told it would be really difficult for me to make partner because I didn’t have a wife at home to pack my suitcase before a trip and bring me to the airport and synch my personal schedule with my assistant, etc. Coincidentally, I was working in an office with no female lawyers more senior than a 3rd year, and a practice group with no female lawyers other than me.
Posted by Richard Wadsworth - 3 months, 3 weeks, 6 days, 14 hours, 4 minutes ago

Cathy, that is a shame. My wife never does any of those things for me. And I am not a partner either. It must be an unwritten condition of admittance, at least here.
Posted by Sue - 3 months, 3 weeks, 6 days, 13 hours, 50 minutes ago

Cathy, I don’t think it was coincidental that there were no female lawyers more senior than 3rd year at your firm. In fact, it sounds very deliberate.
Posted by Jill - 3 months, 3 weeks, 6 days, 13 hours, 8 minutes ago

Sally, thank you for your articulate insight. I think it would be difficult for anyone in this forum to deny that sexism and racism still exist in our country’s law firms, regardless of differentiating opinions about its prevalence. As such, I am disappointed to see so many quips and sarcastic comments; they only minimize a serious and painful issue. I appreciate you sharing your story.
Posted by JJ - 3 months, 3 weeks, 6 days, 12 hours, 56 minutes ago

Anyone ever hear the saying “you get more bees with honey than with vinegar” ? Maybe that guy said that, and she just misinterpreted the advice so that she could sue?
Posted by R - 3 months, 3 weeks, 6 days, 12 hours, 30 minutes ago

Posts 14 and 16 by Jenny are right on: this was simply a denial of a pretrial motion to dismiss the case. The plaintiff will have a chance to tell her story to a jury (if there isn’t a settlement).

Is it “likely” discrimination as post 1 (Filk Bahr) said? Way too early to say, and too little information. The jury will decide.

One thing’s for sure: It’s pretty unusual for lawyers to be suing fellow lawyers for employment discrimination. I’ve heard some lawyers say it’s professional suicide. However, we’ve all seen the movie “Philadelphia” and other examples of how lawyers are not immune from horrible discrimination.

Under prevailing legal standards, I don’t think a one-time remark by one supervisor that a person isn’t “sweet” enough would be grounds for a finding of discrimination. If that’s all she can come up with when all is said and done, that same Judge Wood might grant a directed verdict or judgment notwithstanding a planitiffs’ verdict - or a plaintiff’s verdict would be vulnerable to overturning on appeal.

But maybe there’s more. We’ll see. (Or more likely, we won’t see and it’ll be settled on a confidential basis and the plaintiff will move to a new town to try to re-establish a professional career.)
Posted by Unree - 3 months, 3 weeks, 6 days, 12 hours, 23 minutes ago

The guys lining up here to side with the firm over the lawyer—knowing ZILCH about what happened beyond the few details of the story, but confident there’s no such thing as male privilege anywhere—are doing legal analysis at its finest.

Sally at #15 is exactly right: the gentlemen who run law firms think it’s cute the way female support staffers disparage and blow off female lawyers. That just PROVES it’s not sexism, right? I mean, a woman is doing it.

And JJ, according to that smarmy cliche what you get with honey aren’t bees, but flies.
Posted by Bob West - 3 months, 3 weeks, 6 days, 12 hours, 19 minutes ago

I agree with Jenny, Post #14 - this appears simply to be a 12(b)(6) ruling—based on what is revealed in the article, correctly. There are too few facts to judge either the attorney or the firm. A short artilce like this cannot possibly summarize all the facts of such an employment and contractual dispute, that is what juries are for. In my experience, usually good legal talent is recognized and appreciated—but let’s face it folks, the private law firm is a model of pure, exploitive capitalism, and most of the available evidence (salaries, partnership ratios, lead assignments, and, as Sally in post 15 eloquently describes, firm resources) suggests that law firms still have quite a way to go to achieve objective gender equality. I think it will take a generation. Half my law school class that graduated in 1984 are women, and I actually feel more comfortable being supervised by women, and arguing to women judges. The profession breeds contempt, and contemptuous men are celebrated; contemptuous women are not. But then, I entered law to help people, not make money, and I have never worked a day in a private law firm, precisely because of the exploitive model of partners profiting off the labor disproportionately performed by associates. That women can be and are oppressed and exploited in private law firms is not new, simply history repeating itself. If Ms. Collins prevails in her lawsuit—actually both the firm and the lawyer would be smart to settle their dispute—perhaps law firms will learn that they need to display objective signs of gender equality, starting with partnership ratios, salaries, and resource allocation. Then they would have reduced fear of a “he-said, she-said” lawsuits like this one. But please remember that our legal system is designed to allow the very type of lawsuit brought here, so that each litigant can have its day in court.
Posted by Randi Barnabee - 3 months, 3 weeks, 6 days, 12 hours, 8 minutes ago

For those who don’t understand the court’s ruling, please review the U.S. Supreme Court case Price Waterhouse v. Hopkins, 490 U.S. 228 (1989). This latest case involves behavior that is substantively no different that that to which associate accountant Ann Hopkins was subjected to - being told that to make partner she had to: “walk more femininely”, “talk more femininely”, “wear makeup”,“wear jewelry”, and “go to charm school”.
Posted by Andy the Lawyer - 3 months, 3 weeks, 6 days, 11 hours, 51 minutes ago

“Don’t be rude to the paralegals and the other staffers—we can replace you more easily than them” is gender neutral.

If this partner had had the sense to give this lawyer that feedback in that manner and with that language, there wouldn’t now be a lawsuit.
Posted by Stella - 3 months, 3 weeks, 6 days, 11 hours, 35 minutes ago

My experience (about 10 years earlier) was strikingly similar to Sally’s. I did make partner and am still with the same law firm. I have always thought that my firm was not unique in this attitude towards the demeanor of female attorneys and the response of the support staff and general inability/refusal of the male attorneys to notice it. It is unfortunate that these gender bias attitudes persist. I did, however, have a senior partner who told me my first year to have the members of the word processing department see him if they had a problem doing my work. At least, he saw a problem. Women still generally have to be nicer (always say please and thank you, which is a good habit anyway, but is sometimes lost when you have clients or a higher up demanding something in an unrealistic time frame) or they are a b***** whereas a man is tough or hard nosed.
Posted by Karen Aviles - 3 months, 3 weeks, 6 days, 11 hours, 12 minutes ago

To shed light on Sally’s and Stella’s comments, I offer the following about a recent study presented reviewers with scenarios and then asked the reviewer to evaluate the behavior of a person in a scenario. The majority of reviewers (and this included woman reviewers) judged the behavior of a person in a scenario more negatively when the person had a female name. So, if a person in a scenario forcefully gave out orders and the person had a female name, the reviewer tended to rate such behavior as aggressive or bossy. But, if a person had a male name in the exact same scenario, the reviewers tended to rate the person as extremely competent or having leadership skills. And a woman who took sick leave to take care of a child was viewed as not dedicated to her job, as opposed to the man who took sick leave, who was not viewed negatively. Thus, the issue is not about being “nice” at work. Instead, it is whether the female associate was criticized for behavior which would not have been criticized if a male associate had acted the same way.
Posted by Bruce - 3 months, 3 weeks, 6 days, 10 hours, 59 minutes ago

I had a rather unique associate experience in a top tier NY law firm. The partners I worked for were a woman and a confirmed bachelor. My fellow associates (more females than male) took issue with the “style” of the female partner. I got along fine with her, but I was definitely putting in a concerted effort to make that the case…I was being “sweeter”, which is a habit I have learned works well with many (not all) relationships in the legal world. I left the law firm practice partly because too many people were too personally miserable, unthinking and unkind too much of the time. We may like to think of ourselves (the legal community) as a “cut above” the norm in sophistication and intelligence, but the stark reality of the unhealthy emotional environments that prevail in larger firms made me conclude, sadly, that, overall, large and even medioum-sized, law firm lawyers have (sorry for the age old, over-used metaphor) lost the forest for the trees as far as the importance of being a decent human being is concerned and the fact that acting in that way consistenly is a win-win for ALL involved. The men are from “sweet enough” too.

While none of us can have an informed opinion on this case just now (and tehrefore the case should go forward), I recognize the bind that female lawyers (associates) are in. It sucks. I expected more from those that are supposed to understand and follow the law. I find too many of them interpersonally unevolved and with emotional blinders on, men and women alike.
Posted by Chris - 3 months, 3 weeks, 6 days, 10 hours, 40 minutes ago

Karen, If I am the one providing guidance and direction, am I bossy or competent? What about my fiance, Pat?
Posted by Karen Aviles - 3 months, 3 weeks, 6 days, 8 hours, 4 minutes ago

LOL.
FYI- There is a similar study on race.
Posted by Rick - 3 months, 3 weeks, 5 days, 23 hours, 25 minutes ago

Well, Chris, your fiancé Pat would likely be found competent, according to the study, and you would be bossy. Now, if it were your fiancée Pat, she would probably be judged bossy.

Similarly, a self-deprecating blonde would be a “ditz” or an “airhead,“ but a self-deprecating blond would probably be judged humble or modest.
Posted by Enquiring minds wanna know - 3 months, 3 weeks, 3 days, 14 hours, 50 minutes ago

Wow. What a long note from Sally. You certainly have a lot of time on your hands! How many more posts have you entered here? Are YOU that plaintff? Creating a little publicity for yourself?
Posted by Houston Lawyer - 3 months, 3 weeks, 3 days, 11 hours, 24 minutes ago

I had an experience remarkably similar to that of Sally and Stella. In fact, my assistant, who was female, flat out told me that she preferred to work for men, and that was why she didn’t do my work and only did the work of a male partner who was only 1 year senior to me at the firm. She literally allowed my filing to pile up to the point that it filled an entire associates office, while his work was done immediately. It made it very difficult for me to do my job. I was never particularly “sweet” nor was I particularly abrasive to this woman. She simply decided that my work wasn’t as important as the male partner’s work. Gender stereotypes and discrimination thrive in large law firms. I’m glad I’m now in-house at a company whose law department actually values diversity and treats women with respect at all levels of the organization.
Posted by Enquiring minds wanna know - 3 months, 3 weeks, 3 days, 8 hours, 19 minutes ago

Houston Lawyer: With all of your work not getting done by your secretary, how come no one noticed and fired you for not getting your work done? Filled a whole room ... sounds like Newman on Seinfeld who brought all of his mail home rather than delivering it. Did you work for the Post Office too? Certainly no law firm would tolerate such activities.
Posted by mrs jd - 3 months, 2 weeks, 6 days, 13 hours, 30 minutes ago

As a female associate, I find I have to spend a lot of time building rapport with the support staff to get my stuff done. I always bring out the birthday gifts and christmas gifts with flourish, and the guys can get off on being callous and “forgetting”, but the investment it well worth it. Spend $400 on godiva and itunes giftcards for the mailroom and support staff that isn’t your secretary each year, and you’ll see the investment is well worth it.
Posted by Former Jr Associate - 3 months, 2 weeks, 3 days, 11 hours, 50 minutes ago

To Mrs JD: When I was a junior associate, neither secretaries nor support staff would do my work if anyone more senior had given them work. Even if one gets more senior, there is usually someone more senior who the secretarries and support staff view as more important, irrespective of what sex you are. Bribes DO help, but x-mas gifting is forgotten by February. A good attitude with reasonable deadlies, coupled with a genuine interest in their life, is better. If you treat people well, usually, they will treat you well.

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