Your Roundup Claim Didn’t Disappear — Bayer’s Settlement Delay Is Procedural, Not Final
You saw the headline. Bayer wants a short delay of the hearing on its $7.25 billion Roundup settlement. Your stomach dropped. You thought: Is the settlement falling apart? Did I miss my chance? Is my claim gone?
Take a breath. None of that is true.
A hearing delay in a mass tort settlement this large is a procedural step, not a rejection. The federal Roundup litigation — formally known as Multidistrict Litigation No. 2741 — sits in the United States District Court for the Northern District of California, in San Francisco. When a company like Bayer asks the court to postpone a settlement hearing, it usually means one of several things: the paperwork on a multi-billion-dollar agreement is not yet complete, the parties need more time to finalize claim-registration mechanics, or the court and the parties are working through objections from claimants who feel the framework does not adequately compensate them. None of those reasons closes the courthouse door. None of them erase your claim. None of them stop the clock that is already running on your rights.
We are writing this for one person: someone who used Roundup, developed non-Hodgkin lymphoma or another hematological cancer, and is now trying to figure out whether this delay changes anything. It does not change your legal rights. It may actually give you a narrow window — a breath of time — to get your evidence in order and your claim documented before any participation deadline closes. But that window is not unlimited, and the statute of limitations does not pause because Bayer asked for more time.
Here is what we know, what the delay means, what your claim is worth, what evidence is dying while you wait, and what to do about all of it — straight, from a trial team that has spent decades fighting companies exactly like this one.
What Bayer’s Delay Actually Means for Your Roundup Case
A settlement hearing in a mass tort of this scale is not like a closing on a house. It is a court-supervised process where a federal judge reviews the terms of a proposed settlement to determine whether it is fair, reasonable, and adequate for the thousands of claimants it is designed to compensate. The judge does not simply rubber-stamp a $7.25 billion agreement. The court examines the allocation formula, the claims-administration procedures, the timeline for payment, the treatment of future claimants who have not yet been diagnosed, and the rights of claimants who object to the terms or choose to opt out.
When Bayer asks for a short postponement of that hearing, the most likely explanation is practical: finalizing the settlement structure across thousands of claims filed in federal court and state courts in Missouri — where Monsanto was historically headquartered in St. Louis — requires coordination that does not happen overnight. The dual-track geography of this litigation, with the federal MDL in San Francisco and a substantial state-court docket in Missouri, means any settlement framework must address claims in multiple forums simultaneously. That is logistically demanding, and delays are routine in settlements of this magnitude.
What the delay does NOT mean:
It does not mean the settlement is cancelled. It does not mean Bayer is backing out. It does not mean your claim is invalid. It does not mean the statute of limitations has been extended — it has not. It does not mean you have more time to gather evidence than you did before the headline appeared. And it does not mean you should wait to talk to a lawyer.
What the delay MAY mean for you:
If you have not yet filed a claim, this postponement could represent a narrow window to get your documentation in order and register your claim before a participation deadline closes. Settlement frameworks in mass torts typically include a cutoff date — a date after which new claimants cannot join the settlement structure. If that deadline has not yet passed, the delay may buy you time. But if it has already passed, or if the court sets a new deadline at the rescheduled hearing, you could be shut out. The only way to know where you stand is to have your specific situation evaluated now, not after the rescheduled hearing date is announced.
If you have already filed a claim through a lawyer, the delay likely does not affect your case in any material way — your claim is in the system, your lawyer is tracking the deadlines, and the settlement administration will process your claim whenever the hearing goes forward. But if you filed on your own, or if you have been waiting to see what happens before contacting an attorney, the delay is your warning, not your comfort.
The $7.25 Billion Framework: How a Mass Tort Settlement Actually Works
The $7.25 billion figure is not a per-person payout. It is an aggregate — a pool of money designed to resolve thousands of claims at once. Understanding how that pool gets divided is the single most important thing you can learn about your individual case value.
Mass tort settlements of this scale typically operate through a matrix allocation system. Instead of evaluating each claim individually through negotiation or trial, the settlement establishes a point-based formula that assigns compensation based on specific factors. The matrix approach is designed for efficiency — it allows thousands of claims to be processed without thousands of separate trials — but it also means your individual recovery depends on where you land in the formula.
The factors that drive your matrix allocation:
Your disease subtype is the first and most powerful factor. Non-Hodgkin lymphoma is not a single disease — it is a family of cancers, and the subtypes vary dramatically in severity, prognosis, and treatment intensity. Diffuse large B-cell lymphoma, the most common aggressive subtype, typically commands higher compensation than more indolent forms like follicular lymphoma. Chronic lymphocytic leukemia, which is related to the lymphoma family, may be evaluated differently depending on the specific settlement terms. Your pathology report — the document where a pathologist identified your exact subtype under a microscope — is the single most important medical record in your case. Without it, your claim cannot be precisely valued.
Your age at diagnosis matters. Younger patients who are diagnosed with an aggressive cancer face decades of lost earning capacity, ongoing surveillance, and the psychological weight of living with a cancer diagnosis through what should have been their peak years. The matrix accounts for this.
Your exposure duration and intensity are the causation backbone of your claim. A farm worker who mixed and sprayed Roundup five days a week for fifteen years has a fundamentally different exposure profile than a homeowner who used a ready-to-use spray bottle on driveway weeds twice a year. The matrix weighs this heavily. Occupational exposure — agricultural workers, commercial landscapers, groundskeepers, golf course maintenance crews — generally produces higher point values because the dose and duration are greater and easier to document. Residential exposure can still produce a valid claim, but the documentation burden is different.
The strength of your specific causation evidence is the final factor. General causation — whether Roundup can cause non-Hodgkin lymphoma at all — is a battleground the MDL has already fought through expert testimony and bellwether trials. Specific causation — whether Roundup caused YOUR non-Hodgkin lymphoma — is where your individual evidence either rises or falls. The matrix rewards claimants who can produce purchase receipts, employment records, witness statements, and medical records that tie their specific exposure to their specific diagnosis.
Retrospective and prospective components:
The settlement framework reportedly includes both a retrospective component — compensation for claimants who have already been diagnosed and filed — and a prospective component for future claimants who develop non-Hodgkin lymphoma after exposure but have not yet been diagnosed. The prospective piece is critical because it determines whether someone who used Roundup for years but has not yet developed cancer will have a path to compensation if they are diagnosed in the future. The terms of that prospective component — how long it remains open, what proof is required, and whether it adequately protects future claimants — are among the issues a court examines at a settlement hearing. That is one reason the hearing matters, and one reason a delay to get those terms right is not necessarily bad for claimants.
What bellwether verdicts tell us — and what they do not:
Before the settlement framework was proposed, several Roundup cases went to trial as bellwethers — test cases designed to show both sides what a jury might do. Those jury verdicts ranged from approximately $80 million to over $2 billion at the jury stage. But those numbers are not your case value. Several of those verdicts were reduced on post-trial motions or appeal, bringing them into the $25 million to $87 million range. And even those reduced figures represent outlier trial outcomes — the results of individual cases with specific fact patterns, specific plaintiffs, and specific courtroom dynamics — not the matrix values that most claimants will receive under a settlement framework. Your case value under the settlement matrix is almost certainly lower than a trial verdict, but it comes without the risk, delay, and uncertainty of trial. The trade-off is the whole point of the settlement.
Who You Are Really Up Against: Bayer, Monsanto, and the Corporate Structure
Understanding who you are suing changes how your case is built. The defendant in a Roundup case is not a single company — it is a corporate structure, and that structure has implications for how claims are valued, negotiated, and paid.
Monsanto Company developed, manufactured, and marketed Roundup herbicide starting in 1974. Monsanto designed the glyphosate formulation at issue. Monsanto controlled the safety testing, the regulatory submissions, and the marketing claims that plaintiffs allege misrepresented the carcinogenic risk. Monsanto was historically headquartered in St. Louis, Missouri, which is why a substantial portion of individual Roundup claims were filed in Missouri state courts. Monsanto’s own scientists conducted the toxicological research. Monsanto’s own regulatory team handled the submissions to the Environmental Protection Agency. Monsanto’s own marketing department created the advertising that plaintiffs say described Roundup as safe enough that you could “spray it and walk away.” Every decision about what warnings to put on the label, what studies to conduct, and what studies to suppress or challenge — those were Monsanto’s decisions.
Bayer AG is a German pharmaceutical and agricultural conglomerate that acquired Monsanto in 2018 for approximately $63 billion. With that acquisition, Bayer assumed the Roundup litigation exposure — tens of thousands of personal injury and wrongful death claims that had already been filed or would be filed in the future. Bayer is the entity funding the $7.25 billion settlement. Bayer is the entity whose corporate resources stand behind the settlement payments. And Bayer is the entity whose board of directors and shareholders are watching the litigation’s resolution affect the company’s financial position and public reputation.
What this means for your case is simple: the defendant has extraordinary resources. Bayer is not a small company that might be unable to pay a judgment. It is one of the largest pharmaceutical and agricultural companies in the world. The settlement is funded by a corporation with deep pockets, which means the money is there. The question is not whether the defendant can pay — it is whether your claim is documented strongly enough to command the compensation you deserve from the matrix.
The corporate structure also matters for liability theory. Monsanto made the product. Bayer bought the company that made the product. Under principles of successor liability — the legal doctrine that determines whether a acquiring company inherits the liabilities of the company it acquires — Bayer stands behind Monsanto’s conduct. This is why Bayer, not Monsanto, is the primary settlement proponent. The corporate restructuring does not let the manufacturer walk away from the consequences of what it made.
The Regulatory War: EPA Says Safe, IARC Says Probably Carcinogenic
If there is one thing that makes the Roundup litigation different from almost any other mass tort, it is the regulatory conflict at the center of the causation fight. Two reputable agencies looked at the same chemical and reached opposite conclusions. That conflict is not a footnote — it is the battleground.
The Environmental Protection Agency regulates glyphosate under the Federal Insecticide, Fungicide, and Rodenticide Act, codified at 7 U.S.C. § 136a. Under FIFRA, no person in any state may distribute or sell any pesticide that is not registered by the EPA. The EPA has conducted registration review of glyphosate and has historically classified it as “not likely to be carcinogenic to humans.” Bayer and Monsanto cite this position heavily in litigation. Their argument is straightforward: if the federal agency charged with regulating pesticides says glyphosate is not likely to cause cancer, how can they be liable for failing to warn that it does?
The International Agency for Research on Cancer, a branch of the World Health Organization, reached a different conclusion. In 2015, IARC classified glyphosate as “probably carcinogenic to humans” — Group 2A in its classification system. IARC’s classification was based on a review of scientific evidence, including studies showing DNA damage and oxidative stress from glyphosate exposure — mechanisms that are biologically plausible contributors to non-Hodgkin lymphoma.
This regulatory-scientific conflict is central to the causation battleground in Roundup cases. Plaintiffs argue that IARC’s classification, combined with internal Monsanto documents produced in discovery, shows that Monsanto knew or should have known about the carcinogenic potential of its product and failed to warn consumers. Defendants argue that the EPA’s position, combined with the absence of a definitive epidemiological consensus, means the cancer risk was not established and warnings were not required.
The Federal Food, Drug, and Cosmetic Act governs pesticide residue tolerances on food crops treated with glyphosate, codified at 21 U.S.C. § 346a, with glyphosate tolerances specifically codified at 40 CFR § 180.364. The EPA’s interim registration review decision has been the subject of litigation by environmental groups challenging the adequacy of the agency’s cancer risk assessment. That ongoing regulatory uncertainty adds another dimension to settlement negotiations — because if the EPA’s position changes, or if a court overturns the current classification, the litigation landscape shifts.
What this means for your claim:
The regulatory conflict does not prevent you from pursuing a claim. Juries in Roundup bellwether trials heard evidence of both the EPA and IARC positions and still returned verdicts for plaintiffs. The EPA’s position is not a shield that automatically defeats your case — it is evidence the defense uses, and your case must be prepared to meet it. This is where the MDL’s common evidence database becomes powerful: internal Monsanto corporate documents produced in discovery — including alleged ghostwriting of scientific literature, regulatory influence campaigns, and internal debates over IARC’s classification — provide the counter-narrative that the company’s public safety claims were not as settled as the EPA’s position might suggest. That evidence supports both the failure-to-warn theory and the punitive damages argument that Monsanto’s conduct was knowing and deliberate.
California Law and Your Roundup Claim: The Rules That Decide Your Case
The Roundup MDL is in the Northern District of California. The transferee court applies choice-of-law analysis to determine which state’s substantive law governs each individual plaintiff’s claims — meaning the court looks at where you live, where you were exposed, and where you were diagnosed to decide whether California law, Missouri law, or another state’s law applies to your specific case. If you are a California resident who used Roundup in California and was diagnosed in California, California law will likely govern your claim. If you were exposed in Missouri or another state, the analysis may point to a different state’s law. This is not a detail — it changes your deadline, your damages, and your causation standard.
The statute of limitations — the clock that does not pause for a settlement delay:
California has a specific statute for toxic exposure claims. Under California Code of Civil Procedure § 340.8(a), a civil action for injury or illness based upon exposure to a hazardous material or toxic substance must be commenced no later than two years from the date of injury, or two years after the plaintiff becomes aware of, or reasonably should have become aware of, (1) an injury, (2) the physical cause of the injury, and (3) sufficient facts to put a reasonable person on inquiry notice that the injury was caused or contributed to by the wrongful act of another, whichever occurs later.
The time for commencement of the action shall be no later than either two years from the date of injury, or two years after the plaintiff becomes aware of, or reasonably should have become aware of, (1) an injury, (2) the physical cause of the injury, and (3) sufficient facts to put a reasonable person on inquiry notice that the injury was caused or contributed to by the wrongful act of another, whichever occurs later.
For wrongful death actions based on toxic exposure, § 340.8(b) imposes the same two-year period measured from the date of death or the date the plaintiff knew or should have known of the physical cause of death and facts sufficient for inquiry notice, whichever is later.
This is the discovery rule as applied to toxic exposure in California. The clock does not start when you were exposed to Roundup — it starts when you knew or should have known that your cancer was caused by Roundup. For many claimants, that date is the date they first heard about the Roundup litigation or the IARC classification and connected it to their own diagnosis. But the “should have known” standard is objective — the court asks what a reasonable person in your position would have known, not what you actually knew. If you were diagnosed with non-Hodgkin lymphoma in 2019 and the Roundup litigation was national news by 2018, the court may find that you should have known earlier than you claim.
This is why the settlement delay is not your friend on the statute of limitations. The clock is running. Bayer’s postponement does not toll it. The court’s rescheduled hearing does not extend it. If your two-year window is closing, you need to file before it does — whether or not the settlement hearing has happened.
The causation standard — substantial factor, not sole cause:
California has adopted the substantial-factor test for cause-in-fact determinations. Under the California Supreme Court’s decision in Rutherford v. Owens-Illinois, Inc. (1997) 16 Cal.4th 953, 968–969, 976–977, in toxic exposure cancer cases, a plaintiff proves causation by showing that exposure to the defendant’s product was in reasonable medical probability a substantial factor contributing to the plaintiff’s risk of developing cancer. You do not have to prove that Roundup was the only cause of your non-Hodgkin lymphoma. You do not have to exclude every other possible risk factor. You have to prove that your Roundup exposure was a substantial factor — that it meaningfully contributed to your cancer in reasonable medical probability.
This standard is plaintiff-favorable compared to standards that require proof of sole causation, but it still requires expert testimony. A board-certified hematologist-oncologist must review your medical records, your exposure history, and the scientific literature, and offer the opinion that your Roundup exposure was a substantial factor in causing your specific cancer. This is not something you can establish with your own testimony. It requires a qualified expert, and the defense will have their own experts arguing the opposite.
The duty of care — what Monsanto owed you:
Under California Civil Code § 1714(a), everyone is responsible not only for the result of their willful acts, but also for an injury occasioned to another by their want of ordinary care or skill in the management of their property or person. California products liability precedent defines a manufacturer’s duty under § 1714 as the duty to design, manufacture, and market products free from defects, and manufacturers remain liable for negligent design and failure to warn of known or reasonably knowable risks. Monsanto owed you a duty of ordinary care in product testing, safety evaluation, post-market surveillance, and consumer warning. Plaintiffs allege Monsanto breached that duty by failing to conduct adequate long-term carcinogenicity studies and disregarding warning signs in its own toxicological data.
Consumer protection statutes:
California’s consumer protection framework provides additional legal theories. The Consumers Legal Remedies Act, codified at Civil Code § 1750 et seq., and the Unfair Competition Law, codified at Business and Professions Code § 17200 — which defines unfair competition to include any unlawful, unfair, or fraudulent business act or practice — give plaintiffs additional avenues for relief beyond traditional product liability claims. These statutes are part of what makes California a plaintiff-favorable forum for Roundup cases.
Damages — no MICRA cap on toxic tort claims:
One of the most important things to understand about California law in a Roundup case is what does NOT apply. The Medical Injury Compensation Reform Act — MICRA — imposes a cap on non-economic damages in actions against health care providers based on professional negligence. Under Civil Code § 3333.2(a), that cap applies only to actions for injury against a health care provider or health care institution based on professional negligence. It does not apply to toxic tort claims. Roundup is a product liability case against a chemical manufacturer, not a medical malpractice case against a doctor. There is no statutory cap on non-economic damages in product liability cases in California. The full range of pain and suffering, emotional distress, and loss of quality of life damages is available.
Punitive damages are available in California upon a showing of malice, oppression, or fraudulent conduct. The internal Monsanto documents in the MDL record — the alleged ghostwriting, the regulatory influence campaigns, the internal debates over IARC’s classification — are the evidence that drives the punitive damages argument. In bellwether trials, juries returned substantial punitive awards based on exactly this evidence, though several were reduced on post-trial motions or appeal.
Missouri law — the other track:
For claims filed in Monsanto’s home-state courts, Missouri law applies. Missouri adopted strict product liability in Keener v. Dayton Electric Manufacturing Co., 445 S.W.2d 362, 364 (Mo. 1969), and applies pure comparative fault to products liability claims under RSMo §§ 537.765.1–.2. Under Missouri’s pure comparative fault framework, a plaintiff’s own fault diminishes proportionately the amount awarded as compensatory damages but does not bar recovery entirely — meaning even if a plaintiff is partially at fault, they can still recover, with their recovery reduced by their percentage of fault. Missouri also permits punitive damages upon the requisite showing. If your claim is governed by Missouri law rather than California law, the analysis shifts — which is why choice of law is not an academic question but a practical one that affects your case value, your deadline, and your strategy. Our toxic tort claim practice handles these choice-of-law questions across state lines.
What Your Roundup Case Is Actually Worth
We are going to be honest with you about money, because honesty about money is the foundation of trust in a lawyer-client relationship.
The $7.25 billion settlement figure is an aggregate portfolio resolution. It is not divided equally among claimants. It is divided according to the matrix allocation formula, which assigns points based on the factors we discussed — disease subtype, age at diagnosis, exposure duration and intensity, and specific causation evidence strength.
Individual recoveries under the settlement matrix are expected to range from approximately $25,000 at the low end to $1,500,000 or more at the high end. Where you fall in that range depends entirely on the specifics of your case.
Claims at the lower end typically involve less severe disease presentations, weaker exposure documentation, shorter exposure duration, or residential rather than occupational use. If you used Roundup occasionally around your home for a few years and were diagnosed with an indolent subtype of non-Hodgkin lymphoma with a favorable prognosis, your matrix value will be at the lower end. That is not a judgment on your suffering — it is the arithmetic of the formula.
Claims at the upper end involve wrongful death, severe or aggressive disease subtypes, prolonged heavy occupational exposure, and strong specific causation evidence. A farm worker who handled Roundup daily for twenty years and died from diffuse large B-cell lymphoma has a claim that occupies the upper range. A commercial landscaper with fifteen years of Roundup exposure and a stem-cell transplant has a claim that occupies the upper range. The matrix rewards documentation — the more precisely you can prove your exposure, the higher your point value.
What bellwether trial verdicts tell us about ceiling value — and why your settlement is lower:
Roundup bellwether trials before the settlement produced jury verdicts ranging from approximately $80 million to over $2 billion. Those are staggering numbers, and they tell you something important: when a jury hears the full story — the exposure, the cancer, the internal corporate documents — they react with enormous verdicts. But those numbers are not your settlement value. Several of those verdicts were reduced on post-trial motions or appeal, bringing them into the $25 million to $87 million range. And even those reduced figures represent individual trial outcomes, not matrix allocations. The settlement trades the possibility of a massive verdict for the certainty of a structured payment, without the risk of losing at trial or waiting years for an appeal to resolve.
We will not promise you a specific dollar amount, because any lawyer who does that before reviewing your medical records, your exposure history, and the settlement’s specific matrix formula is not being honest with you. What we can tell you is that the quality of your evidence — the pathology report that identifies your exact subtype, the purchase records that prove how much Roundup you bought and how often, the employment records that document your occupational exposure, the witness statements that corroborate your use — directly determines where you land in the matrix. Strong evidence produces strong offers. Weak evidence produces the bottom of the range.
The damages categories the matrix is designed to compensate:
Economic losses include past and future medical expenses for cancer treatment — chemotherapy regimens, radiation therapy, stem cell transplants, immunotherapy, and ongoing surveillance for recurrence. Non-Hodgkin lymphoma treatment can cost hundreds of thousands of dollars, and some therapies — CAR-T cell therapy, for example — can cost hundreds of thousands per treatment course. Lost wages and diminished earning capacity account for the time you missed from work during treatment and the long-term impact on your ability to earn. For wrongful death claims — which we handle separately — the damages include the financial support your loved one would have provided, the loss of guidance and companionship, and funeral and burial expenses.
Non-economic damages cover the human cost: pain and suffering, emotional distress, the loss of quality of life, and the psychological impact of a cancer diagnosis you believe was caused by a product you trusted. In California, there is no statutory cap on these damages in a product liability case. The full scope of your suffering is compensable.
Punitive damages — designed to punish and deter particularly egregious conduct — were a hallmark of the bellwether verdicts and remain available under both California and Missouri law upon a showing of malice, oppression, or fraud. Whether the settlement framework preserves or releases punitive damages claims is a critical question your lawyer must examine before you agree to participate.
The Medicine: Non-Hodgkin Lymphoma, Glyphosate, and the Causation Fight
If you are going to understand your Roundup claim, you need to understand the medicine — not at the level of a doctor, but at the level of a patient who knows what the evidence in their case actually says.
What non-Hodgkin lymphoma is:
Non-Hodgkin lymphoma is a cancer of the lymphatic system, which is part of the body’s immune defense. It begins in white blood cells called lymphocytes — specifically B cells or T cells — when those cells develop genetic mutations that cause them to grow abnormally and fail to die at the end of their normal lifecycle. The abnormal cells accumulate in lymph nodes, spleen, bone marrow, or other lymphoid tissue, forming tumors and disrupting the immune system’s ability to fight infection.
Non-Hodgkin lymphoma is not one disease. It is a category that includes more than seventy subtypes, each with its own behavior, prognosis, and treatment protocol. The broad division is between aggressive (fast-growing) and indolent (slow-growing) subtypes. Diffuse large B-cell lymphoma is the most common aggressive subtype — it grows quickly, requires immediate treatment, but is often curable with standard chemotherapy. Follicular lymphoma is the most common indolent subtype — it grows slowly, may not require immediate treatment, but is generally considered incurable and manageable as a chronic condition. Chronic lymphocytic leukemia, related to the lymphoma family, involves abnormal lymphocytes in the blood and bone marrow. Mantle cell lymphoma, Burkitt lymphoma, marginal zone lymphoma — each is a different disease with a different course.
Your pathology report — the document where a pathologist examined your biopsy under a microscope and used immunohistochemistry and flow cytometry to identify your exact subtype — is the foundation of your medical evidence. Without a confirmed tissue diagnosis with subtype identification, your claim cannot proceed. If you have not obtained a complete copy of your pathology report, that is the first piece of evidence you need.
The treatment and its costs:
Treatment depends on the subtype, stage, and your overall health. The most common regimen for aggressive B-cell lymphomas is R-CHOP — a combination of rituximab, cyclophosphamide, doxorubicin, vincristine, and prednisone — typically delivered in six cycles over several months. Radiation therapy may follow or replace chemotherapy for localized disease. For relapsed or refractory disease, the treatment escalates: stem cell transplants (autologous, using your own cells, or allogeneic, using a donor’s), immunotherapy drugs, and CAR-T cell therapy — a treatment in which your own T cells are genetically engineered to attack your cancer cells. Each of these treatments carries its own risks, its own recovery timeline, and its own cost. Stem cell transplants can require weeks of hospitalization. CAR-T therapy can cost hundreds of thousands of dollars per treatment. Surveillance continues for years — scans, blood tests, oncologist visits — because recurrence is always a possibility.
The causation theory:
Plaintiffs allege that glyphosate causes non-Hodgkin lymphoma through two primary mechanisms. First, DNA damage — glyphosate is alleged to cause genotoxicity, damaging the genetic material in lymphocytes and creating the mutations that lead to malignant transformation. Second, oxidative stress — glyphosate is alleged to disrupt cellular oxidative balance, generating reactive oxygen species that damage cells and contribute to cancer development. The scientific support for these mechanisms includes the IARC classification, which cited limited evidence of carcinogenicity in humans and sufficient evidence in experimental animals, as well as epidemiological studies reporting elevated non-Hodgkin lymphoma risk in highly exposed populations.
The proof problem — and how it is solved:
The defense exploits the fact that non-Hodgkin lymphoma has many known risk factors. Age, immune suppression, certain viral infections (including Epstein-Barr and HTLV-1), certain bacterial infections (including H. pylori), family history, and exposure to other chemicals have all been associated with increased lymphoma risk. The defense argument is that your cancer could have been caused by any of these factors — that Roundup is just one of many possible explanations, and you cannot prove it was THE cause.
The answer is the substantial-factor standard. You do not have to prove Roundup was the sole cause. Under California’s Rutherford standard, you prove that your Roundup exposure was in reasonable medical probability a substantial factor contributing to your cancer risk. A board-certified hematologist-oncologist reviews your exposure history, your medical history, your pathology, and the scientific literature, and offers the opinion that your significant Roundup exposure was a substantial contributor. The defense presents their own experts. The jury — or the settlement matrix — weighs the evidence.
This is why exposure documentation is so critical. The stronger your evidence of significant, prolonged Roundup exposure, the stronger the causal inference. A person who sprayed Roundup professionally for fifteen years and has no other significant lymphoma risk factors has a stronger specific causation case than a person who used it occasionally and has multiple other risk factors. The medicine and the evidence work together — your expert needs the exposure data to support the opinion.
The long arc:
Non-Hodgkin lymphoma is not always a one-time event. Even after successful treatment, surveillance continues for years. Recurrence is possible. Late effects of treatment — cardiac damage from anthracycline chemotherapy, secondary cancers from radiation or chemotherapy, chronic effects of stem cell transplant — can emerge decades later. Your case must account for the full arc, not just the acute treatment phase. A life-care planner builds the cost stream of future medical needs, and a forensic economist reduces it to present value. These are the numbers that should drive your settlement valuation, not just the medical bills you have already accumulated.
The Evidence You Need to Preserve — and How Fast It Dies
Evidence in a Roundup case is not like evidence in a car crash. There is no skid mark to photograph, no vehicle to inspect, no police report to pull. The evidence is scattered across years of your life — in medical files, in purchase records, in employment archives, in the memories of people who watched you use the product. And it is dying on a clock that does not wait for the settlement hearing.
Medical records — the foundation:
Your medical records establish three things: your specific diagnosis (the pathology report identifying your exact non-Hodgkin lymphoma subtype), the temporal relationship between your exposure and your diagnosis, and the damages baseline (treatment history, costs, prognosis). Under California law, physicians must maintain patient records for at least seven years after the last date of service, under Business and Professions Code § 2266. Hospitals must preserve records for a minimum of seven years following discharge, under California Code of Regulations, title 22, § 70751(c). After those retention periods, records may be archived, made difficult to access, or destroyed.
Here is what most people do not think about: the seven-year clock starts from the last date of service, not from diagnosis. If you were diagnosed five years ago but have been seeing your oncologist regularly since then, the clock is still running. But if your last oncology visit was eight years ago and you have not been back, those records may already be gone. Obtain complete copies of your medical records now — pathology reports, treatment summaries, oncologist correspondence, imaging reports, medication records — not later, not after the settlement hearing, now.
Purchase records — the exposure backbone:
Roundup purchase receipts, product containers with labels, store loyalty program records, and credit card statements document the frequency, duration, and product-specific identification of your exposure. This is essential for causation. But retail purchase data degrades rapidly. Store loyalty programs may not retain purchase histories beyond a few years. Credit card statements are typically available for seven years from your bank, but older transactions may be archived. Product containers with their original labels — which identify the specific Roundup formulation you used — may have been discarded years ago.
If you still have any Roundup containers, product packaging, or old receipts, photograph them immediately and store the physical items safely. If you used Roundup through your employment, your employer’s purchasing records may document bulk purchases that establish your occupational exposure. If you used it at home, your local hardware store or garden center may have loyalty program records that can be subpoenaed. The longer you wait, the more of this evidence disappears.
Employment records — for occupational exposure:
If you were an agricultural worker, commercial landscaper, groundskeeper, golf course maintenance worker, or any other professional who used Roundup as part of your job, your employment and payroll records establish the duration and intensity of your occupational exposure. This is the evidence that drives the higher end of the matrix range.
Employers must retain Cal/OSHA injury and illness records for five years after the end of the calendar year covered, under California Code of Regulations, title 8, § 14300.33(a). Payroll records must be preserved for at least three years under federal regulation, 29 CFR § 516.5. But former employers may have dissolved, been acquired, or purged old records. If your employer went out of business or was bought by another company, the records may be in a storage facility, an acquiring company’s archive, or nowhere at all. The time to request these records is now — not after the settlement hearing, not after the delay is resolved, now.
Witness statements — the corroboration that fills the gaps:
Sworn statements from family members, coworkers, or neighbors who can testify to your Roundup use are the evidence that fills the gaps when purchase documentation is incomplete. A spouse who watched you mix Roundup every Saturday morning for ten years. A coworker who sprayed alongside you on the crew. A neighbor who saw the yellow jugs in your garage. These statements corroborate your exposure history and support the frequency and duration estimates that drive your matrix value.
Witness memories fade. Witnesses relocate. Witnesses pass away. Memorialize these statements within months, not years. A written statement taken while the memory is fresh is worth more than a statement taken three years later when the details have blurred.
The MDL common evidence database — already preserved, but access may change:
The MDL’s common evidence database contains internal Monsanto corporate documents produced in discovery — documents showing alleged knowledge of glyphosate carcinogenicity, ghostwritten research, regulatory influence campaigns, and internal debates over IARC’s classification. This evidence supports the failure-to-warn and punitive damages theories. It is already preserved in the MDL record and is accessible through coordinating counsel. But access protocols may change after the settlement is approved — the database may be restricted, closed, or transferred to a claims administrator. If your case depends on access to these documents, that access should be secured before the settlement closes the MDL infrastructure.
The preservation letter — freezing what can still be frozen:
The preservation demand is the legal instrument that freezes evidence before it can be destroyed. When we take a case, the preservation letter goes out immediately — to the employer whose records document your exposure, to the store whose loyalty program tracks your purchases, to any entity whose records matter and whose retention clock is about to expire. The letter puts the recipient on notice that the evidence is relevant to litigation and that destruction after notice carries legal consequences. In California, when a defendant lets required evidence die after notice, the law answers with an adverse-inference instruction — the jury may assume the lost record was as bad as the plaintiff says — and potential sanctions. The leverage begins the moment the letter is on file.
The Defense Playbook: What Bayer’s Lawyers Do — and How We Counter Each Move
Bayer and Monsanto did not become the defendants in one of the largest mass torts in United States history by being bad at defending themselves. They have teams of lawyers, claims administrators, and corporate strategists whose job is to resolve this litigation for the lowest possible aggregate cost. Understanding their playbook is not paranoia — it is preparation.
Play 1: “The settlement covers everyone — you don’t need your own lawyer.”
This is the most insidious play in the mass tort playbook. The message, sometimes stated directly and sometimes implied, is that the settlement is designed to take care of you and that hiring a lawyer just reduces your recovery by the fee percentage. The reality is the opposite. Matrix allocation systems have discretionary tiers, documentation requirements, and procedural hurdles that unrepresented claimants routinely fail to meet. A claimant who submits without legal review may land in a lower compensation tier because they did not understand what evidence the matrix rewards. A claimant who signs a release without understanding its scope may waive future claims they did not know they had. The settlement is not a gift — it is a transaction, and you need someone who has read the fine print on your side of the table. The counter: have your claim evaluated by a mass tort attorney before you submit anything, sign anything, or accept any offer.
Play 2: Exposure minimization — “Your Roundup use was minimal.”
The defense will attempt to characterize your exposure as infrequent, low-dose, and insufficient to be a substantial factor in causing your cancer. This is the matrix version of the comparative-fault argument — they are trying to push you into a lower point category by minimizing your exposure history. The counter: robust exposure documentation. Purchase records, employment records, witness statements, and product containers are the evidence that defeats the minimization argument. The more precisely you can quantify your exposure — years of use, frequency of application, volume of product — the harder it is for the defense to minimize it. This is why evidence preservation is not a formality but the core of your case.
Play 3: Alternative causation — “Your cancer could have many causes.”
The defense will point to every other risk factor for non-Hodgkin lymphoma — age, immune status, family history, other chemical exposures, viral infections — and argue that your cancer was not caused by Roundup. The counter: a board-certified hematologist-oncologist who reviews your full medical and exposure history and offers the specific causation opinion that your Roundup exposure was a substantial factor under California’s Rutherford standard. The substantial-factor test does not require Roundup to be the sole cause — it requires it to be a meaningful contributor. An expert who can articulate why your significant exposure history makes Roundup a substantial factor in YOUR cancer, despite other possible risk factors, is the difference between a compensated claim and a denied one.
Play 4: The regulatory compliance shield — “EPA says glyphosate is safe.”
Bayer and Monsanto cite the EPA’s classification of glyphosate as “not likely to be carcinogenic to humans” as evidence that they had no duty to warn. The counter: IARC’s 2015 classification of glyphosate as “probably carcinogenic to humans” created a scientific dispute that a jury is entitled to weigh. The EPA’s position is not conclusive — it is evidence, and it is contradicted by another reputable international agency. Moreover, regulatory compliance does not automatically eliminate failure-to-warn liability. A manufacturer’s duty to warn is not limited to what the regulator requires — it extends to what the manufacturer knew or should have known about the risks of its product. The internal Monsanto documents showing alleged knowledge of carcinogenic potential, ghostwritten research, and regulatory influence campaigns are the evidence that the company’s public safety claims were not as settled as the EPA’s position suggests.
Play 5: Delay and degrade — the slow clock.
Every month the process takes, evidence degrades. Witnesses relocate. Records are purged. Memories fade. The defense does not need to win on the merits if they can outlast the evidence. The counter: aggressive, immediate evidence preservation. Preservation letters go out the day you call. Record requests go out the same week. Witness statements are memorialized while memories are fresh. The firm that waits for the settlement hearing to resolve before gathering evidence has already lost the case — the evidence is gone by then.
Play 6: The future-claims waiver — releasing more than you know.
Settlement documents may include language that releases not just your current claim but future claims — claims for family members, claims for conditions that have not yet developed, claims for recurrence of your current cancer. If you sign a release without understanding its scope, you may be giving up rights you do not know you have. The counter: every release is reviewed by a lawyer before it is signed. Every word. The difference between “I release all claims arising from my Roundup exposure” and “I release all claims for non-Hodgkin lymphoma diagnosed as of the date of this release” is the difference between preserving your future rights and extinguishing them.
How a Roundup Case Is Actually Built: From First Call to Resolution
Here is what the process looks like when a Roundup case is handled the way it should be — not a summary, but the actual walk through the work.
Week one — the intake and the evidence freeze. You call. We listen. We take down your exposure history, your diagnosis, your treatment, your work background. We identify the records that matter and the records that are dying. The preservation letter goes out — to your employer, to your oncologist’s office confirming record retention, to any retailer whose loyalty program tracks your purchases. We begin gathering your medical records, starting with the pathology report. We ask you to photograph any Roundup containers or packaging you still have. We ask you to list every person who can corroborate your Roundup use — family, friends, coworkers, neighbors.
Weeks two through four — the record build. Medical records arrive. We review them for subtype identification, diagnosis date, treatment history, and prognosis. Employment records are requested. Witness statements are taken — not just names and phone numbers, but sworn written statements that memorialize what the witness saw, how often, and for how long. Purchase records are subpoenaed where possible. Every piece of evidence is organized, cataloged, and evaluated against the matrix factors.
Weeks four through eight — the expert evaluation. If your case is heading toward individual litigation rather than settlement participation — or if we need to strengthen your settlement position — we retain a board-certified hematologist-oncologist to review your records and provide a specific causation opinion. The expert reviews your exposure history, your pathology, your medical records, and the scientific literature. The expert’s opinion is the bridge between your exposure and your cancer — the opinion that says, in reasonable medical probability, your Roundup exposure was a substantial factor in causing your non-Hodgkin lymphoma.
Months two through six — the MDL and state court coordination. If your claim is part of the MDL, we coordinate with the MDL structure — filing the necessary pleadings, participating in the discovery that is already underway, accessing the common evidence database of internal Monsanto documents. If your claim is in state court, we handle the state-court procedures. If the settlement framework is available and appropriate for your case, we evaluate the matrix allocation, project your point value, and advise whether participation or opt-out is the better path.
The decision — settlement or trial. This is the fork. If the settlement matrix offers fair compensation for your specific case — fair based on your subtype, your exposure, your damages, and the strength of your causation evidence — we recommend participation and handle the submission. If the matrix undervalues your case — because your exposure was extraordinary, your damages are catastrophic, or your punitive damages argument is strong — we may recommend opting out and pursuing individual litigation. That decision is yours, made with full information about the risks and rewards of each path.
Resolution — the payment. Under the settlement framework, payment comes through the claims administrator after your claim is reviewed and approved. The timeline depends on the settlement’s specific procedures, the volume of claims being processed, and any appeals or objections. Individual litigation resolves through trial, settlement during litigation, or alternative dispute resolution. In every path, the number at the end is built from the evidence we gathered in week one — the records we froze, the witnesses we memorialized, the experts we retained, and the documents we pulled from the MDL’s common evidence database.
What to Do Right Now: Your Evidence and Deadline Roadmap
The settlement hearing delay is not a reason to wait. It is a reason to move. Here is what to do — today, this week, this month.
Today:
Get a complete copy of your medical records. Start with your oncologist’s office. Request your pathology report, treatment summaries, imaging reports, medication records, and any correspondence between your providers. Under California law, you have the right to your own medical records. Do not accept a summary — request the complete file. If you have been treated at multiple facilities, request from each one.
Photograph any Roundup containers, packaging, or receipts you still have. Do not throw anything away. The label on the container identifies the specific formulation — the concentration of glyphosate, the brand name, the manufacturer — and that information matters for your exposure documentation.
Write down your exposure history while your memory is fresh. When did you first use Roundup? How often? For how many years? What size containers did you buy? Where did you buy them? Did you use it for work, at home, or both? Who saw you use it? This written timeline is the foundation of your exposure evidence, and it is more accurate now than it will ever be again.
This week:
Request your employment records if you used Roundup occupationally. Contact former employers’ HR departments and request personnel files, payroll records, and any documentation of your job duties. If your employer has dissolved or been acquired, identify the successor entity and request from them.
Begin identifying and contacting witnesses. Family members, coworkers, neighbors who can confirm your Roundup use. Ask them to write down what they remember — when they saw you use it, how often, what they saw you spraying — while their memories are current.
Check your statute of limitations. If you are in California, the two-year clock under Code of Civil Procedure § 340.8 started when you knew or should have known that your cancer was caused by Roundup exposure. If that date is approaching, you need to file before it passes. The settlement hearing delay does not extend this deadline.
This month:
Have your case evaluated by a mass tort attorney — not a firm that signs up clients and does nothing, but a firm that actually understands the Roundup litigation, the matrix allocation, the causation evidence, and the choice-of-law analysis. Ask hard questions: How many Roundup claims have they handled? What is their assessment of your matrix value? What evidence do they need from you? What is their plan for your case — settlement participation or individual litigation? Do they have access to the MDL common evidence database?
Do not sign anything from a claims administrator without legal review. Do not accept any offer without understanding what you are releasing. Do not assume the settlement will automatically take care of you. It will not. The matrix is a formula, and formulas reward the claimants who show up with the strongest evidence.
Why Our Firm
Ralph Manginello has spent 27+ years in courtrooms, including federal court. He was a journalist before he was a lawyer — a background that means he knows how to dig for the document the other side does not want found. He does not lose well, and he does not settle for less than a case is worth. He has recovered $50 million in aggregate for clients, including a $5 million brain-injury settlement, a $3.8 million amputation settlement, and $2.5 million in a truck-crash recovery. Those are not Roundup numbers — they are the numbers of a firm that knows how to build a catastrophic-injury case, how to document damages, and how to face a corporate defendant with deep pockets and fight for what the client deserves. The skill set transfers. The work is the same.
Lupe Peña spent years inside a national insurance-defense firm — the rooms where claims like yours are priced, where administrators decide which tier you land in, where the decision to delay, deny, or devalue is made over coffee and a spreadsheet. He knows how the other side values a claim because he was the other side. He knows the tactics — the minimization, the alternative-causation argument, the delay strategy — because he used them. Now he uses that knowledge for injured people, in English or in fluent Spanish. Lupe conducts full client consultations in Spanish without an interpreter, because a family in crisis should not have to translate their suffering to receive justice.
We work on contingency. That means we do not get paid unless we win your case. The fee is 33.33% if the case resolves before trial and 40% if it goes to trial. The consultation is free. The first call costs you nothing and commits you to nothing. We will tell you honestly whether we are the right firm for your case — and if we are not, we will tell you that too.
Past results depend on the facts of each case and do not guarantee future outcomes. We cannot promise you a specific dollar amount. What we can promise is that your case will be evaluated by people who know the law, know the medicine, know the defense playbook, and know how to build the evidence that drives your matrix value toward the top of the range rather than the bottom.
Call 1-888-ATTY-911. That is 1-888-288-9911. We answer 24 hours a day, seven days a week — live staff, not an answering service. Hablamos Español. The consultation is free. The fee is contingency. You do not pay unless we win.
Frequently Asked Questions
Is the Roundup settlement still happening after this delay?
Yes. Bayer’s request for a short postponement of the settlement hearing is a procedural step, not a cancellation. In mass tort settlements of this scale — $7.25 billion across thousands of claims — hearing delays are routine. The parties may need additional time to finalize the settlement structure, complete documentation, or address objections from claimants. The settlement framework remains in place. Your claim rights are not affected by the delay. What is affected is the timeline — the hearing will be rescheduled, and any deadlines tied to the hearing may shift. But the statute of limitations on your individual claim does not pause, so you should not treat the delay as additional time to wait.
How much will I get from the Roundup settlement?
No attorney can tell you a specific dollar amount without reviewing your medical records, your exposure history, and the settlement’s specific matrix formula. Individual recoveries are expected to range from approximately $25,000 at the low end to $1,500,000 or more at the high end, depending on your disease subtype, age at diagnosis, exposure duration and intensity, and the strength of your specific causation evidence. Claims involving wrongful death, aggressive subtypes like diffuse large B-cell lymphoma, and prolonged heavy occupational exposure occupy the upper range. Claims with weaker exposure documentation or less severe presentations fall toward the lower end. The $7.25 billion is an aggregate pool, not a per-person guarantee. Your individual compensation depends on where the matrix formula places you — and that placement depends on the quality of your evidence.
I used Roundup years ago and just got diagnosed with non-Hodgkin lymphoma — is it too late to file?
It depends on when you knew or should have known that your cancer was connected to Roundup exposure. California’s toxic exposure statute of limitations, under Code of Civil Procedure § 340.8(a), gives you two years from the date you became aware of, or reasonably should have become aware of, (1) your injury, (2) the physical cause of your injury, and (3) facts sufficient to put a reasonable person on inquiry notice that the injury was caused by someone else’s wrongful conduct. If you were diagnosed recently and only recently learned that Roundup may have caused your cancer, your two-year clock may have just started. But the “should have known” standard is objective — if the Roundup litigation was widely reported and you had reason to connect your diagnosis to your Roundup use earlier, the clock may have started earlier. This is a fact-specific question that requires legal evaluation of your specific timeline. Do not assume you have plenty of time. Do not assume you are too late. Call and find out.
Does the settlement cover future claims if I haven’t been diagnosed yet?
The settlement framework reportedly includes a prospective component for future claimants who develop non-Hodgkin lymphoma after exposure but have not yet been diagnosed. The terms of that prospective component — how long it remains open, what proof is required, and how compensation is calculated — are among the issues the court examines at the settlement hearing. This is one reason the hearing matters and one reason the delay may actually serve future claimants: getting the prospective terms right is critical for anyone who was exposed to Roundup but has not yet developed cancer. If you have significant Roundup exposure but have not been diagnosed, you should understand your rights under the prospective component and under individual state statutes of limitations, which may give you a path to file if you are diagnosed in the future.
I live in California but used Roundup in another state — which law applies to my claim?
The MDL transferee court applies choice-of-law analysis to determine which state’s substantive law governs each plaintiff’s claims. The analysis considers where you were exposed, where you were diagnosed, where you live, and which state has the most significant relationship to your claim. If you are a California resident who was exposed to Roundup in California and diagnosed in California, California law will likely govern. If you were exposed in another state, the analysis may point to that state’s law — which could mean a different statute of limitations, a different causation standard, and different damages rules. This is not a minor detail. It can change your deadline, your case value, and your strategy. Your attorney must conduct this analysis early in your case.
My family member died from non-Hodgkin lymphoma after using Roundup — can I still file a wrongful death claim?
You may be able to, depending on the timing. Under California Code of Civil Procedure § 340.8(b), a wrongful death action based on toxic exposure must be commenced within two years of the date of death or two years after the plaintiff knew or should have known of the physical cause of death and facts sufficient for inquiry notice, whichever is later. If your family member died within the last two years and you recently learned that Roundup may have caused their cancer, you may still be within the limitations period. If the death occurred more than two years ago, the analysis is more complex and depends on when you should have known about the connection. Wrongful death claims in the Roundup litigation typically occupy the upper end of the matrix range because they involve the most severe outcome. Do not wait to have this evaluated.
Do I need a lawyer if there is already a settlement?
Yes. The existence of a settlement framework does not mean you are automatically compensated. You must register your claim, submit documentation, meet the matrix criteria, and navigate the claims-administration process. The matrix has discretionary tiers, documentation requirements, and procedural hurdles that unrepresented claimants routinely fail to meet. The settlement release may contain language that waives future claims you do not know you have. A lawyer who understands the Roundup settlement structure can evaluate your matrix value, ensure your evidence is properly submitted, review any release before you sign it, and advise whether settlement participation or individual litigation is the better path for your specific case. The settlement is a transaction, not a gift. You need someone on your side of the table.
What if I already signed something from a claims administrator?
Do not assume it is too late, but do not sign anything else without legal review. If you signed a release or a participation agreement, an attorney may be able to review it and advise you on its scope, its effect on your rights, and whether any options remain. Some releases can be challenged if they were obtained through misrepresentation, if they were unclear about what rights were being waived, or if they were presented in a language the signer did not understand. The specific language of the document and the circumstances under which you signed it determine what options are available. If you signed something, bring it to an attorney immediately — before the settlement hearing, before any additional deadlines, and before you take any further action.
How long will the settlement process take?
Mass tort settlement administration is slow. After the court approves the settlement — which happens at the rescheduled hearing — the claims administrator must process thousands of claims, verify documentation, assign matrix values, and issue payments. This can take months to years, depending on the volume of claims, the complexity of the review process, and any objections or appeals. The hearing delay adds time to the front end of this process. If you are considering individual litigation instead of settlement participation, that timeline is different — typically one to three years from filing to resolution, depending on the court’s docket, discovery disputes, and whether the case settles or goes to trial. Neither path is fast. The question is which path produces the best outcome for your specific case.
Can I still file an individual lawsuit instead of joining the settlement?
In many mass tort settlements, claimants have the option to opt out of the settlement and pursue individual litigation. Whether opt-out is available, what the deadline is, and what the procedural requirements are depend on the specific terms of the settlement — which are among the issues the court reviews at the hearing. If you opt out, you retain your right to file an individual lawsuit against Bayer and Monsanto, but you give up the certainty of the settlement payment. Individual litigation can produce higher recoveries — the bellwether verdicts ranged from $80 million to over $2 billion at the jury stage, though several were reduced on appeal — but it also carries the risk of losing at trial, the delay of litigation, and the cost of expert witnesses and discovery. The decision to opt out or participate depends on the strength of your individual case, your risk tolerance, and your timeline. This is a decision that should be made with full information and legal advice — not a decision you make alone.
If you used Roundup and developed non-Hodgkin lymphoma, the news about Bayer’s hearing delay is not the end of your claim. It may be the beginning of the window you need. But that window is closing — the statute of limitations is running, the evidence is aging, and the settlement process will move forward with or without you.
Call us. 1-888-ATTY-911. That is 1-888-288-9911. Free consultation. No fee unless we win. We answer 24/7 — live, not a machine. Hablamos Español.
This page is legal information, not legal advice. Every case is different. Past results depend on the facts of each case and do not guarantee future outcomes. Contacting the firm is free and confidential. If we are not the right fit for your case, we will tell you — and we will point you toward someone who is.