Standard of Care Expert Witnesses: 124

Thomas J. Zaydon, MD, FACS,  is a Board Certified Plastic Surgeon with over 30 years of experience.. Dr. Zaydon is the founder of The Plastic Surgery Institute of Miami and is a recognized authority on Plastic and Reconstructive Surgery. During his tenure, he continues to work in the emergency room, providing surgical evaluations and performing procedures on patients who need traumatic care.

Dr. Zaydon is certified by the American Board of Plastic Surgery, is a member of the American Society of Plastic Surgeons, and a Fellow of the American College of Surgeons. He has authored numerous articles and chapters on various aspects of plastic surgery. 

Litigation Support - Dr. Zaydon serves as a plastic surgery expert witness on liability cases around the country. He has had the opportunity to work both with defense and plaintiff attorneys. He is a certified expert witness in the field of plastic surgery for the State of Florida. He works for both plaintiff and defense attorneys.

Dr. Zaydon can provide factual synthesis regarding plastic surgery management. As part of his expertise, he navigates medical records and understands procedural terminology. On request, he has prepared numerous comprehensive plastic surgery examinations in conjunction with depositions, trial testimony, and legal documents.

Video: Plastic Surgeon As Expert Witness: How to Choose Your Expert Witness - A Guide for Lawyers

Areas of Expertise:

Plastic Surgery Burn Reconstructive Surgery Breast Augmentation Breast Reduction Facelift Blephroplasty

Nasal Reconstruction Abdominoplasty Body Contouring Burn Patient Workers Compensation Peer Reviews IMEs / EMAs

Marcel O. Ponton, PhD, has over 25 years of experience in the field of Psychology. He specializes in the Neuropsychological Assessment and treatment of Traumatic Brain Injury patients and patients with Psychological Trauma.

Dr. Ponton continues to treat brain injury and trauma survivors in his private practice. He has extensive expertise in the assessment of Spanish-speaking patients. He is a published author, Associate Clinical Professor in the Department of Psychiatry at UCLA, and Adjunct Professor of Pastoral Counseling at Fuller Theological Seminary.

Litigation Support - Over the past 22 years he has served as an expert witness, Dr. Ponton has executed hundreds of evaluations and been retained for his expertise over 300 times. He has testified as an expert in court or before an arbitrator over 40 times. Dr. Ponton's services include neuropsychological assessments, psychological assessments, report writing, medical records review, consulting, and assessment of children and adults.

Areas of Expertise:

Forensic Neuropsychology Traumatic Brain Injury Brain Injury Rehabilitation Spinal Cord Injury Trauma Malingering Personal Injury

Post Traumatic Stress Disorder Psychology Dementia Sanity / Trial Competency Sexual Harassment Sexual Discrimination Handedness

Armond Kotikian, DDS, MD, FACS, is double board certified in Oral and Maxillofacial Surgery. In the clinic setting, Dr. Kotikian routinely performs IV sedations for complex cases including impacted wisdom teeth removal, dental implants, bone grafting and tumor excisions. He specializes in:

• Oral and Maxillofacial Trauma
• Infections
• Oral Pathology Resection and Reconstruction
• Treatment of Obstructive Sleep Apnea Patients (surgical and non-surgical)
• Craniofacial Anomalies (orthognathic surgery / corrective jaw surgery)

Litigation Support - A Fellow of the American College of Surgeons, Dr. Kotikian has extensive experience as an expert witness in the field of Oral and Maxillofacial Surgery and Dentistry. His Dental law and Dentistry services have been requested all over the country. Dr. Kotikian has been an expert witness on over 125 malpractice cases, given depositions on over 65 cases and testified at court over the past six years. His cases have included a wide variety of issues related to the Oral and Maxillofacial region including

• Oral Pathology
• Nerve Injuries
• TMJ Issues
• Oral Trauma
• Oral and Facial Fractures and Lacerations
• Injuries related to Extraction of Teeth
• Injuries related to Dental Implant \ Surgery
• Orthognathic Surgery Complications
• Head and Neck Infections related to Teeth and Salivary Glands

More information at www.oralsurgeryexpertwitness.com

View Dr. Kotikian's Consulting Profile. 

John D. O'Connor has more than 40 years of experience dealing with complex Attorney Fee Disputes. He is a member of the National Association of Legal Fee Analysis (NALFA) and is recognized as one of the top legal fee experts in the country.

Mr. O’Connor has tried over 70 cases in federal and state venues throughout the country, with highly enviable success in complex, contentious disputes. Retained by R.J. Reynolds Tobacco Company as trial counsel in key cases, he has achieved a pretrial dismissal in each concluded action. He has held the highest Martindale-Hubbell “AV” rating for over 25 years, and has consistently been named a “SuperLawyer” by his Northern California peers.

A former Federal Prosecutor, Mr. O’Connor was chosen lead outside counsel in certain S&L crisis litigation, defended a California Attorney General in campaign-related litigation, and successfully represented Golden State Warriors basketball Coach Don Nelson in significant contract claims.

Litigation Support - Since the advent in the late 1980’s of adversarial legal auditing, Mr. O’Connor has served extensively as an expert, litigator, and JAMS mediator throughout the country, analyzing audit criticisms, applying community standards, and construing applicable case law. Through written Declaration and oral testimony, he has consulted on hundreds of adversarial legal fee disputes over three decades. Mr. O'Connor's work has been widely lauded by clients, lawyers, courts, and arbitrators.

Areas of Attorney Fee Dispute Expertise:

• Billing Rates / Overbilling
• Litigation Efficiency
• Task Assignment and Staffing
• Prevailing Party Determination
• Litigation Skill

Craig A. Nachbauer, MD, RPVI, is certified by the American Board of Thoracic Surgery and has practiced thoracic and vascular surgery since 1991. He also serves as the Medical Director of the University of Vermont Health Network-Champlain Valley Physicians Hospital Wound Center.

Dr. Nachbauer completed his thoracic surgery residency at the Ohio State University Hospitals. After a fellowship in pediatric cardiothoracic surgery at Emory University, he served as Clinical Associate in Cardiothoracic Surgery at The Cleveland Clinic.

He is a diplomate of the American Board of Thoracic Surgery, Fellow of the American College of Surgeons, a member of the Society of Thoracic Surgeons, the Southern Thoracic Surgical Association, and the Society for Vascular Ultrasound.

Litigation Support - Dr. Nachbauer has over 10 years of experience in medical record review, determinations of standard of care, and deposition and testimony in medical malpractice cases.

Areas of Expertise:

• Thoracic Surgery
• Vascular, Endovascular surgery and Phlebology
• Non-invasive Vascular Testing
• Wound Care

New York Address 12 Haeley Avenue Plattsburgh, NY

Vermont Address 54 West Twin Oaks Terrace, Suite 14 South Burlington, VT

View Dr. Nachbauer's Consulting Profile.

Arnold J. Weil, MD has over 29 years of experience specializing in Non-Surgical Orthopaedics and Pain Management. A Diplomat of the American Board of Physical Medicine and Rehabilitation and Chief Executive Officer of Non-Surgical Orthopaedics, P.C., one of the premier orthopaedic practices in the metro Atlanta area. 

Dr. Weil's practice focuses on conservative, non-surgical care of orthopaedic injuries, including the spine and extremities, with emphasis on spine rehabilitation, functional restoration, pain management, and ergonomic modifications. He treats patients with back and neck pain and a variety of other orthopaedic conditions. Managing acute and chronic pain through an advanced Non-Surgical approach, Dr. Weil has become one of the leading experts on Spine Care and Disability Management.

 

Video: Non-Surgical Orthopaedics, P.C. | The Overview

Litigation Support - Arnold Weil provides litigation support services to attorneys representing plaintiffs and defendants. He has maintained an unbiased reputation in the medical and legal community. Dr. Weil's experience includes over 300 depositions, medical-legal reviews, peer reviews, and trial appearances. 

Areas of Expertise:

Back, Neck, Spine Injuries Disability Management Pain Management Physical Medicine Workers' Compensation Injuries

Disc Herniation, Bulge, Rupture Independent Medical Evaluations Peer Review Physical Rehabilitation Sports Injuries

View Dr. Weil's Consulting Profile.

Kent C. Sasse, MD, MPH, FACS, FASCRS, FASMBS, is a Bariatric surgery thought leader.  Performed over 5,000 primary bariatric surgical procedures and 500 revisional bariatric procedures. Medical Director of nationally accredited bariatric surgery center. Award-winning teacher. Widely published scientist. Author of the nine books. Inventor and patent holder of bariatric surgical device. 

Clinical Experience includes: bariatric surgery and endoscopy, sleeve gastrectomy, gastric bypass, duodenal switch, reoperative surgery, revisional surgery, hiatal hernia, wound care, Barrett's esophagus, hernia mesh, hernia mesh explantation, endoscopic stenting, leaks, Ambulatory Surgery Centers, and solving complications. Prolific public speaker. University of Nevada School of Medicine faculty. Experienced expert witness at both deposition and trial. www.SasseSurgical.com/books. 

Litigation Support - Dr. Sasse has served as a medico-legal consultant to attorneys involved in complex litigation. He has provided extensive expert reviews of complex cases for the State of Nevada, for independent insurance and disability carriers, and for the United States Air Force. He brings to each and every case a level of experience and unparalleled dedication to preparation, excellent service, and insightful review. His expert testimony has proven highly valuable , serving both defense and plaintiff to reach the truth. 

Dr. Sasse is a sought after speaker and an experienced trial witness, having logged many hours on the witness stand in highly charged cases. He brings a commitment to objectivity and thoroughness to each and every case. 

Areas of Expertise:

Bariatric Surgery Weight Loss Surgery Obesity Gastric Leaks Surgical Complications Weight Loss Medications

Hernia Repair Hernia Mesh Sleeve Gastrectomy Endoscopy Sepsis Gastric Bypass

View Dr. Sasse's Consulting Profile.

Dr. Farr Ajir, MD, MBA, FACS, CIME, is a Board Certified Neurosurgeon with more than 35 years of experience in the treatment of disorders of the Brain and Spine. He is also Certified by the American Board of Independent Medical Examiners (CIME).

Dr. Ajir has been staff neurosurgeon at Mayo Clinic and Kaiser Permanente Healthcare Systems.

He is a Fellow of the American College of Surgeons (FACS),  Congress of Neurological Surgeons, and California Association of Neurological Surgeons. He is a Certified Physician Executive (CPE) with many years of leadership and administrative experience in healthcare delivery.

Litigation Support - As an expert neurosurgeon with decades of experience, Dr. Ajir offers services to attorneys representing plaintiff and defendant. He performs Independent Medical Exammination, and provides expert reviews and medical-legal opinions. Dr. Ajir holds medical licenses in California, Montana, New York, Pennsylvania, Washington, Wisconsin, and Utah. 

Areas of Expertise: 

Brain

Brain Abscesses & Infections Brain Concussions Brain Contusions Brain Edema Brain Hemorrhages Brain Injuries Brain Tumors Cerebral Aneurysms Cerebral Vascular Diseases Cranioplasty

Craniotomy Head Traumas Hydrocephalus Microneurosurgery Pituitary Tumors Skull Fractures Stereotactic Neurosurgery Vascular Malformations Ventriculoperitoneal Shunts

Spine

Back Pain & Injuries Back Pain & Injuries Cervical Disc Diseases Cervical & Lumbar Disc Surgeries Cervical & Lumbar Laminectomy Lumbar Disc Diseases Microdiscectomy

Neck Pain & Injuries Spinal Abscesses & Infections Spinal Cord Injuries Spinal Cord Tumors Spinal Stenosis & Spondylosis Spine Fractures Spine Injuries

             

Dr. Tony Nettleman is a Land Surveying Engineer and Attorney who has been practicing for over 20 years. He holds a BS, MS and PhD in geomatics as well as a law degree. He is licensed in multiple states as a Professional Surveyor and is also a licensed attorney. 

Litigation Support - Tony has helped over 100 clients understand their land surveying and/or property dispute issues. He has testified in depositions and trials over a dozen times throughout that period to help judges and juries better understand what's expected of a Professional Land Surveyor. Whether your dispute is in Florida or Texas, New York or California, Tony travels across the country to conduct surveys, help the clients understand the substantive surveying issues, and resolve the surveying matter at hand.

Areas of Expertise:

Easements Land / Water Boundaries Land Title / Deeds Real Property Attorney Standard of Care

Surveyor Negligence Riparian Allocations of Ownership and Use Dock Surveys Unmanned Aerial Systems

Tony Nettleman on Land Surveyor Negligence

Dr. Nettleman has held distinguished professorships at Texas A&M Corpus Christi, University of Florida, Florida Atlantic University, and Troy University. He is currently the Director of the Nettleman Institute of Surveying Engineering Technology, the President of Nettleman Land Consultants, and the President of NLC Test Prep. He is the author of Clark on Surveying, a co-author of Brown’s Boundary Control and Evidence & Procedures for Boundary Location, teaches college courses, and helps hundreds of land surveyors become licensed each year.

Dr. Robert Evans, PhD,  is a Licensed School Psychologist with over 30 years of experience in the behavioral sciences, including completing over 100 Child Custody Evaluations. Dr. Evans serves as a consultant to the medical, legal, and law enforcement community in Florida on Psychological and Educational matters. He consulted with Orange County Public Defender with cases involving arrest and incarceration of children, including Competency Assessments and Insanity Determinations. He has also provided Critical Incident Stress Debriefings to victims of crime in the Central Florida area. 

Litigation Support - Dr. Evans specializes in Parental Alienation cases which are commonly among those classified as High Conflict Divorce cases and he has written a book on Parental Alienation. He provides litigation support to counsel for both Plaintiff and Defense. His services include support with hearing / trial preparations, review of current evaluations, and support during and after the litigation process. 

Dr. Evans has given sworn testimony as a Forensic Psychology expert witness in NY, IL, PA, GA, FL, IA, ID, CO, OH, TX, TN, LA, MA, MD, MO, NC, SC, WA, and OR. 

Areas of Expertise:

• Parental Alienation
• Child Custody Evaluations
• False Allegations of Abuse
• Treatment Considerations for Alienated Children

William A. Muñoz, Esq., is a Civil Trial Attorney, Legal Ethics Expert, and Third-Party Neutral with over 20 years of experience defending attorneys, and other professionals such as architects and engineers, real estate agents/brokers, real estate appraisers, and insurance brokers, as well as defending personal injury, toxic torts, products liability, defamation, wrongful termination / harassment, wage and hour and discrimination claims.

 Mr. Muñoz is currently a member of the California State Bar Committee on Professional Responsibility and Conduct (“COPRAC”) where the Committee interprets and issues opinions regarding legal ethics and the California Rules of Professional Conduct. Mr. Muñoz also serves as an arbitrator for the State Bar’s Mandatory Fee Arbitration program.

Mr. Muñoz previously served as the Chair for the Legal Malpractice Law Advisory Commission for the State Bar of California Board of Legal Specialization responsible for preparing and grading the legal malpractice law legal specialization examination as well as assessing the qualifications of potential applicants seeking the legal malpractice specialization designation and recertification.

Legal Malpractice Litigation Support - As a Subject Matter Expert, and with his wealth of experience, Mr. Muñoz is prepared to address the nuances of each case. His services are available to attorneys representing injured parties in the following areas:

Standard of Care Conflicts of Interests

Legal Ethics Reasonableness of Attorney’s Fees

Mr. Muñoz also serves as a Dispute Resolution Conference judge for El Dorado County Superior Court, a judge pro tem for Sacramento County Superior Court’s Settlement Conference Department, and more recently, a mediator for the Third District Court of Appeals Mediation Program. His approach is further informed by the renowned Straus Institute for Dispute Resolution at Pepperdine University Caruso School of Law mediation training program and the National Conflict Resolution Center mediation training program.

An expert in his field, Mr. Muñoz has presented locally and nationally on issues of legal malpractice, conflicts of interests and legal ethics and regularly contributes a column in the Association of Defense Counsel for Northern California and Nevada’s Defense Comment entitled “The Lawyer’s Lawyer” addressing issues of legal malpractice avoidance and legal ethics.

View Muñoz Dispute Resolution's Consulting Profile.

Brent Moelleken, MD, FACS is a Plastic and Reconstructive Surgeon practicing in Beverly Hills and Santa Barbara. Double board certified, he received his training at Harvard University, Yale University, UCSF, and UCLA. Dr. Moelleken is one of three specialty-trained surgeons in the world to complete the year-long Aesthetic Surgery Fellowship at UCLA. He is an Attending Surgeon and Associate Clinical Professor in the Division of Plastic Surgery at UCLA, where he often performs surgeries and teaches residents. Here, he specializes in patients diagnosed with skin cancers in the facial area who require complex, artful reconstructions. 

Dr. Moelleken has innovated various procedures including LiveFill®, autologous fat-fascial grafts; the USIC® & LUSIC® cheeklifts, short incision cheeklifts; the 360 Facelift®, a comprehensive natural appearing facelift procedure; and the Hybrid Tummy Tuck®, a short incision tummy tuck for fit moms. He believes in publishing the results of his innovations in peer-reviewed journals. Results of Dr. Moelleken’s studies have been published in books, articles, and the Plastic and Reconstructive Surgery journal. Dr. Moelleken provides free surgical services to Veterans at the West Los Angeles Veteran's Hospital through his UCLA affiliation, and has his own charity, the About Face Foundation ™, helping children and victims of violence or crime who might otherwise be unable to afford reconstructive services. Several of his charity patients have been featured in local and national television and print segments.

Litigation Support - Dr. Brent Moelleken provides expert witness support for insurance companies and counsel representing both plaintiff and defendant. His services include medical case review, depositions, and trial testimony when necessary. Dr. Moelleken has trial experience with the following issues:

Cosmetic Surgery Reconstructive Surgery Medical Malpractice

Burns & Wounds Scar Revision Lien Work

View Dr. Moelleken's Consulting Profile.

Dr. Ronnie I. Mimran, a Board-Certified Neurosurgeon, and former Oakland Raiders NFL Team Neurosurgeon, specializes in Spinal Cord Injuries, Traumatic Brain Injury, and Complex Spinal Surgeries. He is the Medical Director of Neurosurgery and the Neuroscience Department Chair at Sutter Medical Center where he maintains an active clinical practice. 

Litigation Support - As an award-winning teacher, Dr. Mimran brings the capacity to effectively and succinctly communicate complex neurological concepts to his medical-legal practice. He provides Forensic Neurosurgery, Neurosurgery Malpractice / Standard of Care services to attorneys for plaintiff and defendant, including medical record review, thorough reporting, depositons, and trial testimony as needed.

Areas of Expertise:

Traumatic Brain Injury / TBI Brain Surgery Brain Tumors Concussion Emergency Medical Services Independent Medical Examinations Medical Devices

Neurology Neurosurgery Personal Injury Spine Cord Injury Trauma Surgery / Trauma Medicine Thoracic Surgery Back Pain

Selected Background Experience

• Neurosurgeon Sutter West Bay Medical Group, San Francisco, CA December 2020 – present
• Chairman, Department of Neuroscience Sutter Eden Medical Center, Castro Valley, CA December 2021 – present
• Medical Director, Neurosurgery Sutter Eden Medical Center, Castro Valley, CA 2015 -- present
• Adjunct Clinical Professor UCSF Department of Neurosurgery 2006 – present
• Vice Chairman, Department of Neuroscience Sutter Eden Medical Center, Castro Valley, CA December 2019 – December 2021
• Neurosurgeon Pacific Brain and Spine, Danville, CA July 2005 – December 2020
• NFL Team Neurosurgeon Oakland Raiders, Alameda, CA 2009 – 2020

Dr. Mimran completed medical school at the University of Southern California. He subsequently completed a General Surgery Internship, Residency in Neurological Surgery, and Fellowship in Minimally Invasive Spine Surgery, at the University of Florida. During residency and fellowship, Dr. Mimran received the Charles Shank Award for Excellence in Neurosurgery, was a Delegate Fellow for the Council of Neurosurgical Societies, and was honored as the Outstanding Resident Educator in 2002. 

Between 2016-2018, Dr. Mimran completed an MBA at Cornell University. Dr. Mimran has published chapters and peer-reviewed articles in the Journal of Neurosurgery, Journal of Spinal Disorders and Techniques, Clinical Intervention Aging and the Journal of Stroke and Cerebrovascular Diseases. He has successfully patented two neurosurgical devices.

Paul J. Michaels, MD, is a nationally renowned Anatomical and Clinical Pathologist with over 20 years of experience in his field. Dr. Michaels completed his medical residency and earned a Fellowship in Cytopathology from Massachusetts General Hospital / Harvard Medical School.

Litigation Support - Dr. Michaels offers expert witness services to attorneys representing plaintiff and defense. He has written over 100 general causation reports focusing on pathology and providing an extensive differential diagnosis in order to provide an opinion with a reasonable degree of medical certainty. Dr. Michaels has participated in numerous MDLs, been deposed over 60 times, and testified in court 6 times.

Areas of Expertise:

Anatomic Pathology Clinical Pathology Cytopathology Cancer Pathology Oncologic Pathology General Surgical Pathology

Breast Cancer / PremPro Vaginal Mesh Talc / Ovarian Cancer Zantac / Cancer Hair Relaxer / Uterine and Ovarian Cancer Smoking-related Cancer

Background Experience - Dr. Michaels is currently a member of a 10-pathologist group that operates the largest and most comprehensive anatomic pathology services laboratory within Central and Coastal Oregon. He is one of two pathologists responsible for covering Bay Area Hospital, the largest hospital on the Oregon Coast, which serves as a regional referral center.

Dr. Michaels' roles at Bay Area Hospital include: Chairman of Pathology; Member of the Hospital Medical Executive Committee; Medical Director for Transfusion Medicine, Hematology, and Cytopathology; Member of the Cancer Committee; and Member of the Trauma Committee.

At Southern Coos Hospital and Medical Center, Dr. Michaels serves as Laboratory Medical Director where his Anatomic Pathology responsibilities include frozen sections, gross evaluation and sign-out of complex surgical specimens, review of numerous outpatient biopsies, GYN and NON-GYN cytology, presentation at tumor board conferences, and performing hospital autopsies. Clinical pathology responsibilities include peripheral blood smear and body fluid review, crystal identification, and evaluation of blood transfusion reactions.

Speaking Engagements and Presentations - Dr. Michaels has delivered seminars and presentations in Canada, Japan, and throughout the United States. Topics have included cytopathology, breast cancer, acute cellular rejection, and many more. 

Dr. Nicholas Ladikos is a Clinical Pharmacist and Drug Regimen Error expert. He started and operationalized system-level programs at the Johns Hopkins Hospital and the National Institutes of Health (NIH), and is also the founder of MedOp Advisors, a concierge medication, nutrition, and health & wellness advisory company.

Dr. Ladikos also serves as a Medical Director for Optum Serve and is a Professor at both Texas Tech University and Arizona College of Nursing. He co-authored numerous papers in the areas of infectious diseases and antimicrobial stewardship, pharmacoeconomics, pharmacogenomics, geriatrics, and therapies in the lung transplant population. He conducts physician training and clinical staff education regarding medication trends and utilization, identification and mitigation for potential medication fraud, waste and abuse, and collaborates in disease management and population health programs.

Litigation Support - Dr. Ladikos is a subject matter expert in several pharmacy-related areas and serves as an expert witness on a number of Pharmaceutical litigation matters. Numerous hospitals have used his skillset and expertise in medical chart reviews to identify errors in medication preparation and prescribing, drug side effect management, standard of care compliance, continuing education delivery, and personnel assessments.

Areas of Expertise:

Drug Dispensing Errors Drug Interactions and Drug Contraindications Drug Dose Calculations and Verification Drug Monitoring and Levels (e.g. Gentamicin, Vancomycin) Drug Preparation Drug Infusions and Intravenous Medications Total Parenteral Nutrition (TPN) Compounding Anticoagulation (e.g. Heparin, Lovenox, Coumadin)  Acid Reflux / (GERD) Anti-Psychotics Dietary Supplements Drug-induced Lung Disease Drug Labeling and Warnings Drug Safety Geriatrics

Medicare / Medicaid Fraud & Abuse Over The Counter Medications (OTC) Pain Management Prescriptions Psychotropic Pharmaceuticals Pulmonary Medicine Respiratory Therapy Retail Pharmacy Medical Accounting and Valuation Future Medical Costs Insurance Claims Analysis Claim Reviews Health Insurance Life / Health Claims Medical Cost Validation / Negotiation Professional Liability Medical Insurance

Dr. Ladikos currently develops and leads clinical programs that help stakeholders use and advance medication management tools (e.g., formularies, pharmacy, therapeutics committees and medication therapy management), quality metrics, research methodologies, and health information technology. He has experience in medication utilization statistical analyses to demonstrate adherence to evidence-based practice guidelines and inform health program policies.

Dr. Ladikos examines pharmacoeconomic trends to ensure that a cost-effective pharmacy benefit is administered to members, and consults with care management team to provide guidance regarding member goals.