About Us

Our work stems from a deep commitment to patients, driven by a team with unmatched clinical, regulatory, and strategic experience.

Putting extra care in our healthcare advising.

The inspiration behind our name comes from the Rubrum Lily—the flower that our founder, Dr. Lee Fleisher, would often gift his wife as a sign of his love and devotion. To Lee and Matthew, these flowers represent confidence, care, and generosity—three pillars in which Rubrum Advising is strongly rooted.

As a boutique firm, we take pride in building strategies that are tailored to your unique needs. And with our unique clinical background, including a team of actively practicing clinicians, we have firsthand insight into what truly makes a difference for patients.

Illustrated, textured, and pink- and green-colored Rubrum lily.

Meet the Team

At the heart of our firm is a team deeply grounded in clinical practice. Our experts include actively practicing clinicians, MBAs, JDs, PhDs, and more, allowing us to navigate the complexities of the healthcare ecosystem from every angle.

From the bedside to the boardroom, our team’s strength lies in our ability to develop market access, regulatory, and policy strategies that put patients first—while helping companies demonstrate the value of their innovations to both payers and providers using evidence they value. With our strong background in leadership roles at the FDA and CMS, you can feel confident that the highest-quality, patient-focused care will be delivered where it matters most.

Contact Us
  • Headshot of Lee Fleisher on an outdoor background with a tree.

    Lee Fleisher, M.D., M.L.

    Founder & Managing Principal

    • Former Chief Medical Officer & Director, Center for Clinical Standards and Quality, Centers for Medicare & Medicaid Offices (CMS).
    • Practicing senior clinician and emeritus professor at the University of Pennsylvania.

    Lee Fleisher, M.D., M.L.

    Founder & Managing Principal

    • About

      A distinguished national healthcare leader with experience as a director, clinician, scientist, educator, and regulator specializing in market access, regulatory, and policy at Rubrum Advising.

    • Experience

      • Former Chief Medical Officer & Director, Center for Clinical Standards and Quality, Centers for Medicare & Medicaid Offices (CMS). Responsible for executing all national clinical, quality, and safety standards for healthcare facilities and providers, as well as establishing coverage determinations for items and services that improve health outcomes for Medicare beneficiaries.
      • Oversaw a budget of $1.7 billion and 850 individuals at CMS. Utilized novel quality measurement, payment strategies and care paradigms, and worked towards developing the National Quality Strategy and the first universal foundation for quality measurement.
      • Member of the CMS/HHS executive team developing pandemic response including COVID, MPOX, and planning for future pandemic response strategies.
      • Advised the Blue Cross/Blue Shield Association Technology Evaluation Center, pharmaceutical and device companies, and international health systems on the assessing of quality, outcomes, and cost-effectiveness of care.
      • Experienced clinician, actively practicing providing anesthesia at the Hospital of the University of Pennsylvania.
      • Emeritus Professor of Anesthesiology and Critical Care at the University of Pennsylvania Perelman School of Medicine.

    • Awards

      • Modern Healthcare’s 50 Most Influential Clinical Executives. (2023)
      • Lindback Award for Distinguished Teaching from the University of Pennsylvania. (2016)
      • Distinguished Alumni Award from SUNY. (2011)
      • Member of the National Academy of Medicine (formerly Institute of Medicine) of the National Academy of Sciences. (2007-Present)
    • Memberships and Organizations
      • Senior Advisor, Bipartisan Policy Council.
      • Visiting Fellow, Duke-Margolis Center for Health Policy.
      • Senior Advisor, FasterCures at the Milken Institute.
      • Safety Committee Co-Chair and Steering Committee Member, Coalition for Health AI (CHAI).
      • Health IT Advisory Committee (HITAC) Member, Office of the National Coordinator (ONC).
    • Education
      • Masters in Law, University of Pennsylvania Carey Law School.
      • Residency in Anesthesiology, Yale University.
      • Doctor of Medicine (M.D.), State University of New York (SUNY) at Stony Brook.

    • Outside of work

      • Action movie lover
      • Jazz aficionado
      • Yogi
      • World traveler
  • Headshot of Matthew Fleisher on an outdoor background with a bush behind him.

    Matthew Fleisher, J.D., M.P.H.

    Founder & Managing Director

    • Expert in healthcare regulation, particularly pertaining to CMS, the ONC/ASTP, and the FDA.
    • Former Associate at Leavitt Partners, with a focus on Medicare and Medicaid policy.

    Matthew Fleisher, J.D., M.P.H.

    Founder & Managing Director

    • About

      As an enthusiastic, experienced professional, Matthew leverages his experiences at CMS and in consulting to craft novel strategic counsel with a focus on operational excellence. He leads critical initiatives and specializes in market access, regulatory, and policy at Rubrum Advising.

    • Experience

      • Former Associate at Leavitt Partners, advising and managing healthcare alliances built on issues related to Medicare and Medicaid enrollment and regulation, quality measurement, healthcare data interoperability, and more.
      • Consulting experience related to healthcare law including Medicare, FDA, legal ethics, and patient advocacy regulation.
      • Graduate fellow at the CMS STARS program, supporting Medicaid quality policy for the CHIP Quality Rating system.
    • Education
      • Master of Public Health (M.P.H), Johns Hopkins Bloomberg School of Public Health..
      • Doctor of Law (J.D.), with a Certificate in Health Law, University of Maryland Francis Carey School of Law.

    • Outside of work

        • Professionally trained opera singer and music teacher
        • Woodworker
  • Headshot of Tamara Rook on a blurred-out outdoor background.

    Tamara Rook, M.B.A.

    Principal

    • Expert in global market access and reimbursement strategy, with a focus on enhancing patient access to life-changing medical technologies.
    • Former Vice President of Global Market Access, Health Economics, and Reimbursement at Zimmer Biomet.

    Tamara Rook, M.B.A.

    Principal

    • About

      A distinguished healthcare leader in the medical device industry, known for her expertise in market access, health economics, and reimbursement policy. Tamara specializes in developing payer-focused strategies to successfully commercialize new technologies at Rubrum Advising.

    • Experience

      • Former Vice President of Global Market Access, Health Economics, and Reimbursement at Zimmer Biomet.
      • Key leadership positions in medical device organizations, including serving as the Vice President of Reimbursement and Health Economics at Nevro and Senior Director of Global Neuromodulation Reimbursement at Abbott.
      • Extensive experience in developing effective reimbursement and payer education strategies, leading to favorable coverage and reimbursement policies for new technologies including implantable devices.
      • Experience successfully recruiting top talent to build high-performing Market Access teams focused on strategic and tactical efforts.

    • Memberships and Organizations

      • Committee Chair for the industry leadership group focused on advancing Health Economics and Patient Value (HEPV) with the Medical Device Innovation Consortium (MDIC).
      • Foundation Board Member, Junior League of Denver.

    • Education

      • Masters of Business Administration (M.B.A.), University of Houston.

    • Outside of work

      • Tennis
      • Snow skiing
      • Cheering for the Denver Nuggets!
  • Headshot of Steve Hahn on a white background.

    Steve Hahn, M.D.

    Principal

    • Former Commissioner of Food and Drugs at the U.S. Food and Drug Administration (FDA).
    • Executive leadership experience at Harbinger Health and the world-renowned MD Anderson Cancer Center.

    Steve Hahn, M.D.

    Principal

    • About

      A distinguished clinician and healthcare leader with two decades of experience in healthcare strategy, oncology medical practice, translational/clinical research, and product development. Steve specializes in market access, regulation, and policy at Rubrum Advising.

    • Experience

      • Served as the 24th Commissioner of Food and Drugs at the U.S. Food and Drug Administration (FDA). Oversaw both COVID and non-COVID regulatory affairs, including therapeutics and vaccine development, devices, diagnostics, and clinical trials.
      • Experience in medical product development and clinical trials spanning drugs, biologics, medical devices, and diagnostics.
      • CEO of Harbinger Health and CEO-Partner at Flagship Pioneering, leading strategy around preemptive care and early cancer detection.
      • Former Chief Medical Executive, Deputy President, and Chief Operating Officer (COO) at MD Anderson Cancer Center in Houston, TX. Steve provided executive leadership across research development, clinical trials, patient care, and health system management, as well as day-to-day management of business, clinical, and faculty matters.
      • Former Chair of Radiation Oncology at the University of Pennsylvania’s Perelman School of Medicine.
      • Extensive research experience focusing on the evaluation of the tumor microenvironment and signal transduction pathways involved in tumor response to proton therapy.

    • Education

      • Fellowship and residency in Oncology at the National Cancer Institute.
      • Residency in Internal Medicine at the University of California, San Francisco.
      • Doctor of Medicine (M.D.), Temple University.

    • Outside of work

      • CrossFit
      • Studying Italian
  • Headshot of Nancy Stade on an outdoor background with tree branches behind her.

    Nancy Stade, J.D.

    Principal

    • Former Deputy Director for Policy, Center for Devices and Radiological Health at the US Food and Drug Administration (FDA).
    • Accomplished attorney and consultant, representing manufacturers of medical devices and consumer health products.

    Nancy Stade, J.D.

    Principal

    • About

      An accomplished attorney, consultant, and policy expert with extensive experience in FDA regulation and novel healthcare technology, specializing in regulation and policy at Rubrum Advising.

    • Experience

      • Former Deputy Director for Policy, Center for Devices and Radiological Health at the US Food and Drug Administration (FDA). Nancy led the development and implementation of the FDA’s device regulatory policy for novel technologies such as digital health products, mobile medical apps, direct-to-consumer genetic tests, and more.
      • Initiated and championed a pilot program to allow parallel review by FDA and CMS of innovative technologies, and led policies for pre-submissions, the 510(k) program, and de novo review of novel technologies.
      • Partner, Food, Drug, and Medical Device Regulatory practice at Sidley Austin and Foley Hoag. Nancy’s practice focused on advising clients on all aspects of FDA oversight in the medical device, combination product, and digital health and life sciences arenas.
      • Private attorney and consultant, counseling major health clinics, private equity firms, laboratories, traditional medical device manufacturers, makers of consumer electronic and digital health products, and start-up developers of innovative AI-based devices.

    • Awards

      • Award of Merit and Commissioner’s Award for Distinguished Service, US Food and Drug Administration (FDA).
      • Vincent F. Prada Award for pro bono service.

    • Education

      • Doctor of Law (J.D.), Columbia Law School.

    • Outside of work

      • Self-taught portrait artist
      • Avid gardener and knitter
      • Outdoors enthusiast
  • Headshot of Kurt Herzer on an outdoor background with a tree and a bush behind him.

    Kurt Herzer, M.D., Ph.D., M.Sc.

    Principal

    • Former Senior Advisor of Data and Analytics at the Centers for Medicare and Medicaid Services (CMS).
    • Expert in product/industrial design, health economics and health services research, and the application of technology in complex sociotechnical organizations.

    Kurt Herzer, M.D., Ph.D., M.Sc.

    Principal

    • About

      An accomplished healthcare leader with experience spanning academia and the public and private sectors, including Johns Hopkins Medicine, the World Health Organization, and the U.S. Department of Health and Human Services. Kurt specializes in clinical, data, and health economic evaluation for market access at Rubrum Advising.

    • Experience

      • Former Senior Advisor of Data and Analytics, Centers for Medicare & Medicaid Offices (CMS). Responsible for setting the vision and strategy related to enterprise-wide use of data and analytics to improve quality of care for 150 million Americans.
      • Worked to modernize technology and data infrastructure and develop new platforms and applications for advanced analytics, machine learning, and artificial intelligence across the world’s largest collections of healthcare data at CMS.
      • Former Head of Population Health at Oscar Health, building and leading a team working on innovative approaches to acute care, chronic disease, medication management, virtual care, and value-based insurance design.
      • Adjunct Faculty in Anesthesiology & Critical Care Medicine at The Johns Hopkins School of Medicine.
      • Extensive research experience supporting global interventions to improve healthcare quality and reduce childhood mortality and morbidity, including living and working abroad in both London and Geneva.

    • Awards

      • Marshall Scholar, Marshall Aid Commemoration Commission.
      • Truman Scholar, the Harry S. Truman Scholarship Foundation.
      • National Quality Scholar, American College of Medical Quality.
      • Mary P. Oenslager National Achievement Award, Learning Ally.
      • Graduate Scholar, Golden Key International Society.
      • John T. McGraw Scholar, National Federation of the Blind.

    • Memberships and Organizations

      • Member, Industrial Design Society of America

    • Education

      • Doctor of Medicine (M.D.), The Johns Hopkins University School of Medicine.
      • Doctor of Philosophy (Ph.D.) in Health Policy and Economics, The Johns Hopkins Bloomberg School of Public Health.
      • M.Sc (Master of Science) in Social Policy and Intervention and Marshall Scholar, University of Oxford.
      • M.I.D. (Master of Industrial Design), Pratt Institute.

    • Outside of work

      • Cyclist and skier
      • Modern art enthusiast
      • Photographer
      • Avid reader of foreign fiction
      • Machinist
      • DIY biohacker
  • Headshot of Neha Presad on an outdoor background with a tree and a fence behind her.

    Neha Prasad, Ph.D.

    Senior Manager

    • A translational market access strategist bridging the bench-to-bedside gap for innovative therapeutics and medical devices.
    • A specialist in antimicrobial resistance (AMR) market shaping initiatives and a former portfolio strategy analyst at BARDA, a major global funder of antimicrobial product development.

    Neha Prasad, Ph.D.

    Senior Manager

    • About

      A science-oriented strategist with over a decade of experience spanning chemistry and molecular microbiology research, go-to-market strategy, funding/investment portfolio strategy, and clinical evidence/regulatory strategy. Neha focuses on market access and regulatory strategy at Rubrum Advising.

    • Experience

      • Former ORISE fellow at the Biomedical Advanced Research and Development Authority (BARDA), supporting the Antimicrobials Branch as well as the Division of Research, Innovation, and Ventures (DRIVe). Neha developed funding decision-making tools, evaluated funding strategies, and sourced investment opportunities based on gap analyses.
      • Former fellow at the Cystic Fibrosis Foundation, working on due diligence for equity investments around phage therapies and genetic technology.
      • Business development experience at Felix Biotechnology, conducting market evaluations and revenue projections toward new product ideation.
      • Authored multiple peer-reviewed research publications and delivered oral and poster presentations at several conferences.

    • Education

      • Ph.D. in Chemistry and Chemical Biology from the University of California, San Francisco (UCSF) as a National Science Foundation Graduate Research Fellow and a Moritz-Heyman Discovery Fellow.

    • Outside of work

      • Board games
      • Mario Kart
      • Bollywood, Jazz, and Carnatic music
      • Poetry writing, yoga, and meditation
  • Headshot of Samuel Yates on an outdoor background with a terrace and a plant behind him.

    Samuel Yates, M.H.A

    Manager

    • Former Research Director and Product Quality Lead at Darwin Research Group, analyzing the growing national shift from volume to value-based care.
    • Clinical experience in neurosurgery, physical therapy and rehabilitation, optometry, orthopedics, and long-term care.

    Samuel Yates, M.H.A

    Manager

    • About

      An enthusiastic healthcare leader, bringing a unique blend of clinical and consultative experience to Rubrum Advising’s regulatory and policy strategies. At Rubrum, Sam focuses on understanding the changing healthcare policy landscape and its impacts on both clinical and operational sectors of the industry.

    • Experience

      • Former Research Director and Product Quality Lead at Darwin Research Group, analyzing the growing national shift from volume to value-based care.
      • Clinical experience in neurosurgery, physical therapy and rehabilitation, optometry, orthopedics, and long-term care.
      • Research experience in national and regional healthcare trends, with a focus on helping industry organizations partner with care delivery networks to provide more cost-effective, collaborative patient care.

    • Education

      • Masters in Healthcare Administration (M.H.A), Milken Institute School of Public Health, George Washington University.
      • Co-Chair of Professional Development in the Health eLeaders Student Association, George Washington University.

    • Outside of work

      • Professionally trained flutist
      • Distance runner
      • Amateur electronic music mixer
  • Headshot of Eleanor Wolfe on an outdoor background with tree branches behind her.

    Eleanor Wolfe, M.P.H.

    Senior Associate

    • Accomplished researcher with expertise in healthcare policy, regulation, and public health strategy.
    • Experience in health insurance enrollment and service coordination at the New York City Department of Health and Mental Hygiene in the Office of Health Insurance Services.

    Eleanor Wolfe, M.P.H.

    Senior Associate

    • About

      A natural leader and analytical thinker, Eleanor brings an in-depth knowledge of public health systems to Rubrum Advising’s regulatory and policy strategies. Eleanor conducts robust analyses and develops novel strategies for healthcare challenges to improve outcomes for all.

    • Experience

      • Experience in the Health Research and Training Program (HRTP) at the New York City Department of Health and Mental Hygiene, working to increase Medicaid enrollment and improve access to care for children with disabilities.
      • Former criminal defense paralegal, with a focus on expanding healthcare services and legal representation within the Justice System.
      • Extensive experience in health education and curriculum development with interdisciplinary teams.

    • Education

      • Master of Public Health (M.P.H), Columbia University Mailman School of Public Health in the Health Policy and Management Department with a Certificate in Health and Human Rights.

    • Outside of work

      • Recreational sports lover
      • College football fan
      • Half marathon runner
  • Headshot of Allison Goldring on an outdoor background with tree leaves behind her.

    Allison Goldring, M.P.H.

    Senior Associate

    • Project coordination experience at ADAPT Community Network, bringing accessibility services and care management to intellectually and physically disabled populations.
    • Payer strategy experience at EmblemHealth, supporting the creation of a women’s health strategy and IVF coverage pathway.

    Allison Goldring, M.P.H.

    Senior Associate

    • About

      A passionate public health professional, Allison employs her clinical research and analysis skills in developing Rubrum Advising’s market access strategies.

    • Experience

      • Assisted in the strategy and implementation of a care management program for 600 students with multiple chronic conditions at ADAPT Community Network.
      • Coordinated the implementation of a grant-funded project collecting voice samples from people with speech disorders to improve voice recognition capabilities.
      • Produced materials and resources for patient advocates aiding in the coverage navigation of women’s healthcare services.
      • External communications and strategy at a gun violence prevention organization, focused on safe firearm storage and bipartisan solutions.

    • Education

      • Master of Public Health (M.P.H), Columbia University Mailman School of Public Health in the Health Policy and Management Department with a Certificate in Health Policy Analysis.
      • Cross-registration at Columbia Business School, in courses focused on the intersection of healthcare delivery and technology.

    • Outside of work

      • SEC football fan (go Dawgs!)
      • Pop culture expert
      • Puzzle lover
  • Headshot of Anjali Bhatla on an outdoor background with tree branches behind her.

    Anjali Bhatla, M.D., M.B.A.

    Senior Fellow

    • Resident physician in the Department of Internal Medicine at Johns Hopkins Hospital, pursuing a Cardiology fellowship at Johns Hopkins starting July 2025.
    • M.D. and M.B.A. from the Perelman School of Medicine and The Wharton School at the University of Pennsylvania.

    Anjali Bhatla, M.D., M.B.A.

    Senior Fellow

    • About

      An accomplished physician and strategist, interested in the intersection of cardiology, health policy, and digital health. Anjali focuses on market access at Rubrum Advising.

    • Experience

      • Resident physician in the Department of Internal Medicine at Johns Hopkins Hospital.
      • Experience in healthcare payment policy and novel technology reimbursement through work at Humana, Independence Blue Cross, and the Department of Health and Human Services.
      • Former clinical advisor for Google Health.
      • Recent academic work focusing on evaluating the role of private equity acquisitions on health outcomes, the use of telehealth for cardiac care delivery, and the role of novel biomarkers in cardiac risk assessment.

    • Awards

      • American Heart Association Council on Quality of Care and Outcomes Research Early Career Investigator Award.
      • Healthcare Fellow Merit Award, The Wharton School.
      • Recognized by the American Medical Women’s Association as one of the top female medical graduates in the nation.
      • Truman Scholar.

    • Memberships and Organizations

      • Member of Alpha Omega Alpha Honor Medical Society.

    • Education

      • Internal Medicine Residency, Osler Internal Medicine Residency, Johns Hopkins Hospital.
      • Doctor of Medicine (M.D.) and Master of Business Administration (M.B.A.) from the Perelman School of Medicine and The Wharton School, University of Pennsylvania.
      • Majored in Health Care Management at The Wharton School.

    • Outside of work

      • Reading
      • Podcasts
      • Traveling
      • Bollywood dancing.
  • Headshot of Brian Cortese on an outdoor background with tree leaves and a lamp post behind him.

    Brian Cortese M.D., M.B.A.

    Senior Fellow

    • Resident physician in the Department of Urology at Vanderbilt University Medical Center.
    • M.B.A. from The Wharton School, with academic work analyzing the impact of public-private partnerships on Medicare Part D spending.

    Brian Cortese M.D., M.B.A.

    Senior Fellow

    • About

      An innovative professional who brings a unique combination of foundational clinical knowledge and strong business intuition to Rubrum Advising’s market access services.

    • Experience

      • Resident physician in the Department of Urology at Vanderbilt University Medical Center.
      • Former Summer Consultant at Boston Consulting Group (BCG), working on patient-facing operations for a large, multinational pharmaceutical client.
      • Research at the Gordon Center for Medical Imaging associated with Harvard Medical School and Massachusetts General Hospital, focusing on the intersection of immunology and radiology.

    • Education

      • Doctor of Medicine (M.D.) and Master of Business Administration (M.B.A.) from the Perelman School of Medicine and The Wharton School, University of Pennsylvania.
      • Majored in Health Care Management at The Wharton School, graduating as a Palmer Scholar.

    • Outside of work

      • Philadelphia sports fanatic
      • Marathon runner
      • Indie rock enthusiast
  • Headshot of Michael Karamardian on an outdoor background with a tree behind him.

    Michael Karamardian

    Fellow

    • Former Associate Consultant at Bain & Co. and current M.D./M.B.A. candidate, Perelman School of Medicine and The Wharton School, University of Pennsylvania.
    • Recent academic research project: Deep-dive into Private Equity’s impact on healthcare.

    Michael Karamardian

    Fellow

    • About

      Dynamic individual who brings a diverse set of analytical and strategic experiences to Rubrum Advising’s market access services.

    • Experience

      • University of Pennsylvania’s Health Care Transformation and Innovation initiatives drive improvements to care delivery in the health system.
      • Recent academic research project: Deep-dive into Private Equity’s impact on healthcare.
      • Prior to graduate school, Associate Consultant at Bain & Co., where the majority of his efforts were within their healthcare practice.
      • Following graduation in 2025, goal is to begin a medical residency in Internal Medicine.
      • Beyond clinical training, plans to pursue a career blending clinical practice with roles at the intersection of healthcare delivery, technology, and therapeutic innovation.

    • Education

      • M.D./M.B.A. candidate, Perelman School of Medicine and the Wharton School, University of Pennsylvania.

    • Outside of work

      • Tennis
      • College basketball
      • Amateur ice hockey
      • Perfecting my cheesecake recipe!
  • Headshot of Nikki Perry on an outdoor background with tree leaves behind her.

    Nikki Perry

    Fellow

    • M.D./M.B.A. candidate, Perelman School of Medicine and The Wharton School, University of Pennsylvania.
    • Analyzes large patient datasets to identify and address disparities in dermatologic and oncologic care.

    Nikki Perry

    Fellow

    • About

      Passionate individual with a unique blend of clinical expertise, strategic insight, commitment to advocacy, and dedication to advancing dermatologic care through healthcare innovation and delivery. Nikki focuses on our market access services.

    • Experience

      • Chair of the Dermatology Trainee Advocacy Day: Leads efforts to champion several healthcare-related bills before state congresspeople.
      • Analyzes large patient datasets to identify and address disparities in dermatologic and oncologic care. Most recent project was assessing the impact of implementing a decision tree within the Penn call center, which significantly reduced patient wait times from appointment scheduling to actual visits.
      • Another recent paper discussed the impact of Mark Cuban Cost Plus Drugs on drug pricing for common dermatologic conditions.
      • University of Pennsylvania Center for Healthcare Transformation and Innovation initiatives focused on improving patient care systems and access.
      • Wharton Global Health Volunteers: Traveled to Peru as Project Leader of a group of student consultants to develop and implement the fundraising and communications strategy for the Catholic Medical Mission Board.

    • Education

      • M.D./M.B.A. candidate, Perelman School of Medicine and the Wharton School, University of Pennsylvania.
      • Following graduation in 2026, plans to pursue a dermatology residency with the long-term goal of integrating clinical practice with research and leadership roles at the intersection of healthcare delivery, innovation, and policy.

    • Outside of work

      • Scuba diving
      • Skiing
      • Golf
      • Piano (Young Steinway Artist, performed in Severance Hall)
      • Singing (former member of the Heinz Chapel Choir at the University of Pittsburgh)

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    Two illustrated, textured, and pink- and green-colored Rubrum lilies next to each other. The left is shorter than the right.