In the movie The Firm, there’s a moment when Tom Cruise realizes the job he accepted fresh out of Harvard Law School (“HLS”), with the apparently staid tax law firm of Bendini, Lambert & Locke, has one major drawback: the Morolto crime family is the firm’s biggest client, and most of its lawyers are heavily involved in money laundering and tax fraud. This raises a question. Could that really happen? John Grisham thrillers are best enjoyed when such doubts are set aside, of course, but the question is a serious one nonetheless, because the plot of The Firm springs from the very real imbalance of power that exists between law students and the law firms that hire them. When law students graduate, they are in the position of apprentices, with little or no experience in the actual practice of their profession. At the same time, the average “apprentice” now starts a career in the law with more than $100,000 in student debt.[1] This combination of inexperience and financial need creates a powerful incentive for law students to seek employment with large corporate law firms, which may pay double or triple the starting salary of a job in government or the non-profit sector. Suppose, then, that such a firm violates the law or rules of professional conduct. Would it be required to disclose that fact as a condition of its participation in the On-Campus Interview (“OCI”) program at HLS? And if not, what safeguards are in place to ensure that students don’t wind up like Tom Cruise, inadvertently agreeing to work for a firm that engages in unethical or even criminal conduct?
I started pondering these questions as a result of my work representing Ralph Nader (HLS ‘58) in a matter arising from his 2004 independent presidential campaign. During that election, the Democratic Party and its allies filed a total of 29 complaints against Nader’s campaign in 19 different jurisdictions nationwide. Their stated goal was to remove Nader’s name from state ballots or, failing that, to drain his campaign of resources. At least 52 law firms represented or materially supported the various plaintiffs in these cases, including several that regularly participate in the OCI program at HLS. And while I would not suggest that all 52 of those firms necessarily violated the law or rules of professional conduct, I believe that one of them almost certainly did. In fact, based on undisputed evidence in the public record, it appears that this firm not only committed serious ethical violations, but also engaged in conduct which – knowingly or not – enabled a criminal conspiracy to succeed and evade detection. Neither the firm nor its lawyers were charged with any crime, however, and it continues to participate in HLS’s OCI program. According to Assistant Dean for Career Services Mark Weber, the firm is expected to return to HLS this fall, when it will resume recruiting students who likely have no inkling of the relevant facts.
Pittsburgh-based behemoth Reed Smith, LLP was one of the few law firms that succeeded in removing Nader from the ballot in 2004. It did so by convincing a Pennsylvania state court to invalidate more than 30,000 signatures on his nomination petitions based on technicalities – because signers used a nickname like “Bill” instead of the formal name “William,” for example, or because their current and registered addresses didn’t match.[2] All the while, the Reed Smith attorneys claimed to have found “pervasive fraud” in the petitions, even though, as Pennsylvania Supreme Court Justice Thomas Saylor observed, there was “no evidence” to support that claim.[3] A majority of the state’s high court nonetheless cited the alleged “fraud” as justification for affirming an unprecedented trial court judgment awarding Reed Smith $81,102.19 in litigation costs.[4] In a cogent dissent, now-Chief Justice Saylor demonstrated that the majority had misread the plain language of the applicable statute, which did not authorize the imposition of such costs against a defending candidate, but the majority simply disregarded his opinion.[5] Nader thus became the first candidate in American history to be penalized financially by a state for attempting to run for public office – an outcome rendering the majority’s novel misconstruction of the statute “most certainly unconstitutional,” according to constitutional law professor Mark Brown.[6]
Here is where the story takes an almost Grisham-esque twist. In May 2007, seeking to enforce its judgment, Reed Smith initiated attachment proceedings against Nader in the District of Columbia Superior Court, freezing his personal bank accounts. I had been working for Nader since graduating law school in 2005, and he enlisted me to research his legal options. Looming over my investigation was the mystery of why a majority of the Pennsylvania Supreme Court would affirm an unprecedented judgment imposing a draconian penalty on a candidate’s protected First Amendment activity, without any apparent basis in law or fact. What I would discover seemed shocking at the time, although now it pales in comparison to the revelations that later emerged from a criminal investigation by the state attorney general.
In November 2005, while Nader’s appeal of its judgment was pending before the Pennsylvania Supreme Court, Reed Smith began representing then-Chief Justice Ralph Cappy (who joined the majority) as his defense counsel in a state ethics investigation. Reed Smith and its co-counsel from another firm also gave a combined $10,000 in campaign contributions to Justice Sandra Schultz Newman, who authored the majority opinion. In total, these two firms and their lawyers had given at least $67,900 in past and present contributions to five of the six justices in the majority. And finally, yet another member of the majority, Justice Ronald Castille, was of counsel at Reed Smith immediately before joining the bench. Neither Reed Smith nor the justices themselves disclosed any of these facts on the record of the proceedings.
Based on this newly-discovered evidence, we asked the District of Columbia Superior Court to vacate Reed Smith’s judgment, on the ground that the firm’s undisclosed ties with the Pennsylvania Supreme Court justices created an appearance of impropriety and destroyed any semblance of due process. It was a long shot – final judgments are rarely disturbed – but it was our only option. Then, while that motion was pending, Pennsylvania Attorney General Tom Corbett dropped a bombshell.
In a 75-page Grand Jury indictment filed in July 2008, Corbett alleged that the state House Democratic caucus had orchestrated a massive criminal conspiracy to misappropriate millions of dollars in taxpayer funds and resources for private political purposes. One of the most “outstanding examples” of such crimes, the Grand Jury found, was the illegal preparation, at taxpayer expense, of the challenge that Reed Smith filed to Nader’s 2004 nomination petitions. Reed Smith had filed the challenge in the names of several private citizens it claimed to be representing,[7] but the Grand Jury found that state House Democrats were behind the effort. Specifically, the Grand Jury found that “a veritable army” of state employees, totaling as many as 50, had illegally worked “a staggering number of man-hours” to prepare the challenge at taxpayer expense.[8] Trial testimony later revealed that the state employees delivered their completed work-product to Reed Smith’s Pittsburgh offices, where partner Efrem Grail accepted it and gave them more materials to prepare.[9] Grail was responsible for “coordinating” the state employees’ effort, according to the testimony, and he “definitely knew” that they worked for the state House Democratic leadership.[10]
Neither Grail (who has since left the firm) nor any one of the other 15 Reed Smith attorneys who litigated the Nader petition challenge has ever disputed the foregoing facts.[11] Instead, the firm issued a terse statement insisting it had “been assured” the state employees who worked on the challenge were “volunteers”[12] – an assertion at odds with the trial testimony, as well as the attorneys’ duty to know who prepared their litigation, how they did it, and who paid for it.[13] Rather than addressing this discrepancy, however, Reed Smith and its attorneys have remained silent.
In sharp contrast with their current reticence, the Reed Smith attorneys were happy to comment on – and take credit for – the challenge while it was ongoing. In one media report, for example, the attorneys were portrayed as the “workhorses” behind the effort, who claimed to have worked “thousands of hours” to prepare the challenge, which their firm undertook as a “pro bono” matter.[14] “We had the resources to do a statewide review,” partner Daniel Booker claimed.[15] Another report estimated that “about a dozen Reed Smith attorneys, including seven partners, spent 1,300 nonbillable hours reviewing signatures.”[16] Reed Smith’s then-managing partner, Gregory B. Jordan, said that the firm’s pro bono committee approved the project. “We were satisfied it was a worthwhile thing for our people to do,” Jordan said.[17] Efrem Grail also chimed in, telling the New York Times that his firm was protecting the “sacred process” by which candidates gain ballot access.[18]
If these statements now seem disingenuous, it’s not only because there’s nothing sacred about misappropriating taxpayer funds and resources. Campaign finance reports filed with the Federal Election Commission after the election revealed that the Democratic National Committee had retained Reed Smith during the Nader petition challenge, and paid the firm $136,142 for “political consulting” and “legal consulting” services. Reed Smith has also long represented the business and philanthropic interests of Teresa Heinz Kerry, wife of 2004 Democratic presidential nominee John Kerry – the man the Grand Jury identified as the primary intended beneficiary of the challenge.[19] And so, while Reed Smith held itself out as a defender of the public good, the services it provided actually benefited two important clients, one of whom hoped to be residing in the White House when the case concluded.
One might think the revelation that a lawsuit had been prepared illegally, at taxpayer expense, would be grounds for vacating a judgment awarding $81,102.19 in litigation costs to the law firm that filed it. Not in Pennsylvania. In violation of their own rules of civil procedure, the state courts refused to allow Nader to present evidence arising from Attorney General Corbett’s investigation and prosecution of the conspiracy, and then ruled as a matter of law that Reed Smith had done nothing wrong.[20] And what of Corbett, the hard-charging prosecutor whose anti-corruption probe rattled the Capitol in Harrisburg to its foundations? Despite obtaining felony convictions or guilty pleas from 11 of the 12 defendants charged – almost all of them low-level state employees – he took no action against the 16 Reed Smith attorneys who litigated the challenge. Here, too, campaign finance reports may shed light on the vagaries of justice, Pennsylvania-style: in August 2008, not six weeks after Corbett charged the state employees, Reed Smith and its attorneys contributed $15,900 toward his reelection as the state’s top prosecutor.[21] And despite pledging not to accept money from parties involved in his ongoing investigation, Corbett declined Nader’s request that he return the funds.[22]
The upshot of all of this is that Reed Smith remains free to pursue enforcement of its judgment, which it is doing in the District of Columbia courts, where Nader’s bank accounts have now been frozen for eight years.[23] Meanwhile, Reed Smith has taken the position that it has “no duty” to address the evidence of criminality associated with its challenge to Nader’s nomination petitions.[24] And like the Pennsylvania courts, the District of Columbia courts have obligingly disregarded that evidence.[25] The result is a perfect inversion of the courts’ basic function: they are punishing an innocent party for engaging in First Amendment protected conduct, while rewarding another for filing a lawsuit that was prepared illegally, at taxpayer expense. This Alice-in-Wonderland outcome was made possible only because the courts used procedural rulings to avoid addressing the merits of Nader’s defense. If law professor and civil procedure expert Arthur R. Miller is correct that a “deformation of procedure” is transforming our system of justice, such that courts increasingly invoke dubious procedural grounds to deny litigants a meaningful day in court, then this case must be a textbook example.[26]
Presumably, few law firms bear much resemblance to Grisham’s fictional Bendini, Lambert & Locke. But since Reed Smith first initiated action against Nader more than a decade ago, it appears to have violated its ethical obligations, and possibly the law, on multiple occasions. The firm’s failure to disclose its representation of Pennsylvania Supreme Court Chief Justice Ralph Cappy, for instance, seems to be a clear case of “professional misconduct” as defined by the American Bar Association.[27] Reed Smith’s campaign contributions to a presiding justice and a prosecutor engaged in a criminal investigation of a matter in which it was involved also raise serious questions. As law professor and white collar crime expert Robert Fellmeth (HLS ‘70) concluded:
if the law firm of Reed Smith is (a) benefiting from the violations of law properly prosecuted by the Attorney General vis-a-vis legislators and legislative staff (e.g., the firm is attracting business from the political enemies of Nader in a manner attributable to the improper expenditure of public monies alleged), or (b) knew or should have known of the violations alleged by the Attorney General in its capacity as counsel for the violators during the conduct of the violations, it is unethical for him to accept campaign contributions from that firm. In my opinion, it is a violation appropriate for inquiry by the U.S. Attorney with Pennsylvania jurisdiction for the proffering of “dishonest services.”[28]
Most serious of all, however, is Reed Smith’s conduct relating to the criminal conspiracy. Pennsylvania House Democrats couldn’t file the Nader petition challenge themselves, or take credit for their illegal effort to prepare it, without running the risk that their entire criminal enterprise would be exposed. That problem was solved, whether by accident or by design, when Reed Smith publicly presented the challenge as the product of its own “pro bono” efforts, aided by state employees it incorrectly portrayed as “volunteers”. By accepting the state employees’ work product, Reed Smith thus appears to have received services stolen from the taxpayers of Pennsylvania. To the extent that Reed Smith knew or should have known that, it also appears to have aided and abetted the conspiracy, in violation of both the law and its duty of candor to the court and other ethical obligations.
It’s possible that Reed Smith’s apparent misconduct in the Nader matter is an aberration, of course, but there seems to be no shortage of cases in which the firm has been accused of wrongdoing.[29] Since I became acquainted with Reed Smith, for example, one of its former clients, a Christian charity, sued the firm for charging nearly $1 million in legal fees based on an initial estimate of $50,000 – even though Reed Smith lost the “run-of-the-mill” employment discrimination case, and the charity reportedly had to pay the plaintiff an additional $463,000 in damages and attorneys’ fees.[30] In another case, a former client sued Reed Smith for engaging in “a frenzy of self-dealing, fee-churning and malpractice, in order to enrich [itself]” after he suffered a “widow-maker” heart attack.[31] Then there was the former Reed Smith partner who sued the firm, alleging that her colleagues in the corporate securities group doled out desirable assignments in exchange for sexual favors.[32] Each of these cases quietly settled.
One thing is certain: the consequences of Reed Smith’s actions in the Nader matter have reverberated far beyond its persecution of a single candidate. In July 2014, the Third Circuit Court of Appeals concluded that the judgment Reed Smith obtained against Nader, and the precedent it set, has created “a chilling effect on protected First Amendment activity.”[33] People in Pennsylvania are simply afraid to run for statewide public office without the consent of the two major parties. As a result, in the last decade, Pennsylvanians have usually had no choice in such elections but to vote for the Republican or Democrat.[34] That should change, finally, following a ruling by District Court Judge Lawrence Stengel in July 2015, which struck down the statute Reed Smith relied on to obtain its judgment. In holding the statute unconstitutional, Judge Stengel observed (quoting the Court of Appeals) that Republicans and Democrats had used the Reed Smith precedent “as a cudgel against non-major parties and their candidates.”
If there is some good that can come from telling this story, our hope is that it will spur Harvard Law School – and other law schools nationwide – to take an active role in determining whether law firms are eligible to participate in on-campus recruiting. Currently, Assistant Dean Weber confirmed, HLS does not even require law firms participating in its OCI program to disclose violations of the law or rules of professional conduct. Instead, students are simply advised to “conduct their due diligence” before accepting any job offer. But it would take students a great deal of time and effort to do so, and they likely would have limited success. Large corporate law firms like Reed Smith are experts at concealment – note Reed Smith’s practice of settling cases that threaten to expose its alleged wrongdoing – and it’s unrealistic to expect that students with limited time and resources will pierce their veil of secrecy. Here again Reed Smith provides an illustrative example: in 2007, before Attorney General Corbett exposed the criminality associated with its Nader petition challenge, the firm was touting the effort in the Vault Guide to Law Firm Pro Bono Programs as a case where it received “special recognition” for its “pro bono” work.[35] Since then, Reed Smith has removed similar language from its own website.
So what are students to do? For a start, take Assistant Dean Weber’s advice seriously, and seek out independent information about the law firms recruiting you. Consult the materials available from the Office of Career Services, but don’t stop there. Talk with those who know the firms best – not only firm insiders and their colleagues, but also non-profit citizen groups that have experience with the firms, as well as adverse parties, and even the firms’ own clients. You may be surprised at what you can learn when you start digging.
But law schools, including HLS, can and must do more. When they invite law firms to recruit on campus, they provide the firms with an implicit, if not explicit, imprimatur on which students inevitably rely. Law schools therefore have an obligation to conduct their own due diligence. At a minimum, they should require law firms and other potential employers to disclose recent violations of the law or rules of professional conduct. After all, according to HLS Director of Admissions Tom Robinson, students are required to disclose their own disciplinary infractions – both academic and behavioral – when they apply for admission. Law firms participating in OCI should be subject to the same standard.
There is precedent for this proposal. In 2009, Fordham Law Dean William Treanor banned a law firm from on-campus recruiting for five years, citing its “unprofessionalism” for canceling interviews with students after they had already committed.[36] If that relatively minor infraction merits disciplinary action, then surely more serious legal or ethical violations do too. The firm that raised Dean Treanor’s ire, incidentally, was Reed Smith.
[1] See American Bar Association, Average Amount Borrowed 2001-2012, available at http://www.americanbar.org/content/dam/aba/administrative/legal_education_and_admissions_to_the_bar/statistics/avg_amnt_brwd.authcheckdam.pdf (last visited July 10, 2015).
[2] See In Re Nomination Paper of Ralph Nader, 865 A.2d 8, 18 (Pa. Commw. 2004).
[3] See In Re Nomination Paper of Ralph Nader, 860 A.2d 1, 8 n.13 (Pa. 2004) (Saylor, J., dissenting). The trial court had suggested, in dicta contradicted by its own factual findings, that Nader’s nomination petitions were “fraudulent” and contained “thousands of names that were created at random.” See In Re Nomination Paper of Ralph Nader, 865 A.2d at 18. As Justice Saylor explained, however, the trial court’s findings demonstrate that only a small number of signatures – 687 or 1.3 percent of the total – were designated as “forged,” see In Re Nomination Paper of Ralph Nader, 860 A.2d at 8 n.13, and this category included obviously fictitious names that suggest not fraud but pranks or sabotage. Moreover, Reed Smith itself conceded that the trial court “did not reach” its allegations of “pervasive fraud”. See Brief of Appellee at 5 n.3, In Re Nomination Paper of Ralph Nader, 905 A.2d 450 (Pa. 2006).
[4] See In Re Nomination Paper of Ralph Nader, 905 A.2d 450 (Pa. 2006).
[5] See In Re Nomination Paper of Ralph Nader, 905 A.2d at 461 (Saylor, J., dissenting).
[6] See Mark Brown, Political Peril in Pennsylvania: Ballot Access Penalties Create Chilling Effect, Green Institute Publications (February 17, 2007) (Disclosure: Professor Brown has represented Nader in other matters). The Supreme Court of the United States declined to hear Nader’s appeal. See Nader v. Serody, 127 S.Ct. 995 (2007). In a constitutional challenge to the statute now pending in federal court, however, the Third Circuit Court of Appeals concluded, without reaching the merits, that the statute imposes an “intolerable” burden on minor political parties’ First Amendment rights. See Constitution Party of Pa. v. Aichele, 757 F.3d 347, 364 (3rd. Cir. 2014).
[7] Formally known as the “objectors,” Reed Smith’s nominal clients are Pennsylvania residents Linda S. Serody, Roderick J. Sweets, Ronald Bergman, Richard Trinclisti, Terry Trinclisti, Bernie Cohen-Scott, Donald G. Brown and Julia A. O’Connell.
[8] See 28th Statewide Investigating Grand Jury Presentment at 55-56 (filed July 10, 2008).
[9] See Transcript of Proceedings at 46-47, Commonwealth v. Ramaley, et al., No. 1207 M.D. 08/4664 (Ct. Comm. Pl., Dauphin Cty., October 7-8, 2008).
[10] See Transcript of Proceedings at 28, 48, Commonwealth v. Ramaley, et al., No. 1207 M.D. 08/4664 (Ct. Comm. Pl., Dauphin Cty., October 7-8, 2008).
[11] The docket lists the following Reed Smith attorneys as counsel to the nominal challengers: Mark Lawrence Tamburri; John M. McIntyre; Cynthia E. Kernick; James Michael Doerfler; Andrea Beth Simonson; Jeremy David Feinstein; Milind Madhukar Shah; Barbara Kiely; Jeffrey John Bresch; Christopher K. Walters; Daniel I. Booker; Ira Steven Lefton; Melissa Joy Oretsky; Kim M. Watterson; Lisa M. Campoli; James P. Williamson; Efrem M. Grail. See In Re Nomination Paper of Ralph Nader, 865 A.2d 8 (Pa. Commw. 2004).
[12] See Ralph Nader Chimes in on Bonusgate, Pittsburgh Post-Gazette (March 9, 2010).
[13] See Pa. R. Civ. P. 1023.1 (requiring attorneys to conduct “an inquiry reasonable under the circumstances” into the law and facts relating to every “pleading, motion, or other paper” filed with court).
[14] See Melissa Nann Burke, Foiling the Spoiler, The Legal Intelligencer (Nov. 2, 2004).
[15] See Burke, supra n.14.
[16] See Carlyn Kolker, Anti-Nader Raiders, American Lawyer (October 1, 2004).
[17] See Burke, supra n.14.
[18] See Kate Zernike, Nader Ballot Petitions Present a Phone Book Full of Problems, New York Times (October 8, 2004).
[19] See 28th Statewide Investigating Grand Jury Presentment at 55 (filed July 10, 2008).
[20] See In Re Nomination Paper of Ralph Nader, No. 568 M.D. 2004 (December 4, 2008) (unpublished opinion). The Supreme Court of Pennsylvania denied Nader’s request for oral argument and affirmed without opinion. See In Re Nomination Paper of Ralph Nader, No. 94 MAP 2008 (October 23, 2009).
[21] See Editorial, Bonusgate’s Coattails, Philadelphia Inquirer (March 11, 2010). Corbett went on to be elected Governor in 2010, running as a tough-on-crime candidate, then became the first incumbent chief executive to lose his bid for reelection in the 40 years since Pennsylvania permitted a second term. See Associated Press, What Will History Say of Gov. Tom Corbett’s Tenure in Pennsylvania?, Harrisburg Patriot-News (December 25, 2014).
[22] See supra n.21, Bonusgate’s Coattails.
[23] Reed Smith prematurely seized the funds from Nader’s PNC Bank accounts in violation of the automatic 10-day stay imposed by D.C. Civil Rule 62(a), thus denying him his right to oppose enforcement of its judgment – another violation of the rules facilitated, perhaps, by Reed Smith’s failure to disclose yet another conflict of interest. This time, Reed Smith named PNC Bank as a garnishee-defendant in the proceeding, but failed to disclose its long-standing attorney-client relationship with the bank. See Tracie Mauriello, Nader Retaliates for PNC Bank’s Handling of Court Order, Pittsburgh Post-Gazette (January 4, 2014). The District of Columbia Court of Appeals excused this violation on the ground that “Nader has not been harmed.” See Nader v. Serody, 43 A.3d 327, 337 (D.C. 2012).
[24] See Brief of Appellee at 18, Nader v. Serody, 43 A.3d 327 (D.C. 2012).
[25] See Nader v. Serody, supra n.17. As the D.C. Court of Appeals has elsewhere observed, however, in a precedent it declined to apply to Reed Smith, the basis for drawing an adverse inference “is at its zenith when the party who remains silent has been accused of fraud or like conduct,” and consequently, “the failure to deny charges of fraud is tantamount to an admission of the truth of those charges.” Murphy v. McCloud, 650 A.2d 202, 217 (D.C. 1994) (citation omitted).
[26] See Arthur R. Miller, Simplified Pleading, Meaningful Days in Court, and Trials on the Merits: Reflections on the Deformation of Federal Procedure, 88 N.Y.U. L. REV. 286 (2013). Professor Miller focused on federal courts, but it would appear that the same phenomenon is occurring in state courts.
[27] See ABA Comm. on Ethics and Professional Responsibility, Formal Op. 07-449, 3 (2007) (failure to ensure proper disclosure of representation of presiding judge by lawyer or another lawyer in same firm is “professional misconduct”).
[28] See Formal Opinion of University of San Diego School of Law Professor Robert Fellmeth (June 29, 2009) (on file with author) (Disclosure: Professor Fellmeth worked with Nader 40 years ago and has served on the Board of Directors of Public Citizen, a group Nader founded). For example, the Grand Jury indictment that Corbett filed on July 10, 2008 conspicuously fails to identify Reed Smith by name, despite its extensive detail about the state employees’ illegal activity, and their coordination with a “law firm” – an extraordinary and unwarranted grant of anonymity in the context of a criminal indictment that otherwise names the individuals and entities involved.
[29] For a study of the larger impact of misconduct by large corporate law firms, see Ralph Nader and Wesley J. Smith, No Contest: Corporate Lawyers and the Perversion of Justice in America (Random House 1996).
[30] See Bair Foundation, Inc. v. Reed Smith, No. 11782-07 (Comm. Pl. Ct. Pa., Lawrence Cty.) (Complaint filed November 20, 2007); see also Julie Triedman, Reed Smith Loses Round One of Overbilling Lawsuit, The AmLaw Daily (August 6, 2008).
[31] See West v. Reed Smith, No. L-2911-11 (Sup. Ct. N.J.) (Complaint filed June 8, 2011).
[32] See Dillon v. Reed Smith, No. 2:10-cv-01618-NBF (W.D. Pa.) (Complaint filed December 6, 2010).
[33] See Constitution Party of Pa. v. Aichele, 757 F.3d 347, 363 (3rd. Cir. 2014).
[34] See Constitution Party of Pa., 757 F.3d at 363-34; see also Oliver Hall, Some Political Parties Remain Outlaws in Pa., Philadelphia Inquirer (October 18, 2010).
[35] See Vault Guide to Law Firm Pro Bono Programs 2007 Edition (3d. ed.), 578 (Vault, Inc. 2007).
[36] See News Editor, Fordham Law Bans Firm From On-Campus Interviews for Five Years, The National Jurist (September 3, 2009).