Cowen Group Survey Predicts Big Revenue Spike for Litigation Support

By Monica Bay| Law Technology News | January 30, 2012

http://eugeniantoniou.com/work_items/sabi/ Estimated revenue of $275 million in 2011 could rise this year to $535 million, a 105 percent increase

There’s a startling statistic in the new “Salary Survey & Market Landscape” about law firm litigation support staffing, from New York-based The Cowen Group, a headhunter and research consultancy that focuses on electronic data discovery staffing. The sixth annual survey, released Jan. 18, 2012, was conducted in 2011, with 22 firms participating. But for the first time, the report attempted to evaluate the ratio of salary to revenue, says managing partner David Cowen. The results are intriguing.
The most dramatic finding: Revenue from litigation support services, estimated at $275 million for 2011, is expected to spike this year to $535 million — a spike of 105 percent. During 2011, law firms employed about 2,600 litigation support and EDD professionals, spending $200 million on salaries, and generating $275 million in hourly revenue, the survey reports. Cowen predicts that 57 percent of firms will add staff this year, to the tune of 375 positions — a market growth rate of 13.7 percent.
The predicted breakdown of percentage of firms adding positions in 2012:
• 44 percent analysts (100 positions), 2011 headcount 1,200.
• 38 percent specialists (85 positions), 2011 headcount 800.
• 29 percent project managers (65 positions), 2011 headcount 400.
• 22 percent regional managers (15 positions), 2011 headcount 220.
• 7 percent firmwide managers (5-7 positions), 2011 headcount 100.
8 percent firmwide directors (5-7 positions), 2011 headcount 80.
Says Cowen in the survey’s executive summary: “2011 was a pivotal year for executives who are managing litigation support at major law firms.” E-discovery practice groups converged with litigation support departments, “causing firms to invest in attorneys to manage technologists, cases, and client relationships,” while some firms struggled with “how to offer competitive, value-added support by evaluating widely varying service models and alternative billing arrangements,” he continues. The report also says that directors, firmwide managers, and EDD practice group heads have taken on “elevated executive leadership roles” and are managing departments that spend millions of dollars on salaries alone, and in return are realizing comparable revenue.
What’s driving the growth? Cowen cites four factors:
1) Exploding workload: 86 percent of firms reported that their litigation support caseload had increased in 2011, and 95 percent cited increase in volume.

2) “Hiring is concentrated in positions that are relatively highly billable and low cost,” including analysts, specialists, and project managers. The report says that analysts billed an average of 1,600 hours, at $160/hour. Specialists: 2,000 hours at $185/hour; PMs: 1,150 hour at $200/hour.
3) “Highly profitable firms are making larger investments in headcount,” the report notes, with a quarter of firms accounting for 65 percent of 2011 revenue. Those same firms are expected to add 45 percent of the new positions, and generate 68 percent of new 2012 revenue, TCG predicts.
4) Some firms are investing in upgrading their departments, “turning cost centers into revenue generators.”
Methodology: TCG surveyed 22 firms, 17 in major urban areas (five from New York; two each in San Francisco, Los Angeles, Boston, and Atlanta; one each in Chicago, Dallas, Philadelphia, and Washington, D.C.). Three participants were from secondary markets: Pittsburgh, Columbus, and Columbia. Seven firms were in the Am Law top 50, six were in the top 51-100, seven in the top 101-200, and two “others.” Respondents included 12 directors, one CIO, one chief knowledge officer, and eight managers; 95 percent of participants were heads of their departments.
A strong motivator, to no one’s surprise, appears to be corporate counsel. “Sophisticated corporations continue to invest in e-discovery capabilities, records management, and service provider relationships, creating a new client landscape for law firm e-discovery and litigation support departments,” the report notes. “Evolving client expectations require law firms to provide elevated levels of strategic, tactical, and operational competencies — all with direct implications on their hiring needs.”
The survey also evaluates trends in how firms are billing for specific EDD tasks. For example, 56 percent of respondents say they bill hourly for collection and preservation, and only 2 percent bill per gigabyte, and 33 percent say “other.” Document review — an area where many firms have struggled to find the best formula (see LTN’s February cover story, “True Grit”) — shows a whopping 79 percent of respondents saying their firm bills by the hour for those services.
MIXED REACTIONS
We polled e-discovery experts, as well as members of LTN’s Editorial Advisory Board, to get their take on the Cowen survey assertions. The reactions were mixed.
“These results don’t surprise us at all,” said attorney Matthew Kesner, CIO of Mountain View, Calif.-based Fenwick & West. “We have seen the amounts of electronically stored information increase at a rate of 150 percent every nine months. The increasing amounts of data created by all businesses seems to be the primary driver. Clients also seem more able to access the data quickly,” he said. Kesner notes that Fenwick’s workload for in-house litigation support is “way up. We are worried about burning them out.” But, he caveats, “as our methods get better and we get faster we do seem to be helping clients resolve matters an investigations faster. In that sense it is a ‘win-win.'”
Phoenix consultant Michael Arkfeld, a former federal prosecutor, says firms of all sizes are still adapting to their legal responsibilities for ESI. The rise in personnel, he suggests, may reflect the growing sophistication of counsel about the need to more thoroughly conduct identification, location, and collection, triggering the need for more skilled personnel.
Attorney Albert Barsocchini, a San Francisco-based consultant, agrees: “The growth of regional vendors and outsourcing confirms the survey,” he says. “With the current state of technology, corporations are reaching the proper balance between insourcing and outsourcing.”
David Kessler, partner and co-chair of Fulbright & Jaworski’s e-discovery and information governance practice group, says the figures may reflect “the rise in importance of litigation support groups, given our clients’ increased focus on value, innovation, and project management in the delivery of legal services. With the rise of e-discovery, sophisticated litigation support departments were the first to adopt these principles to address highly complex ESI challenges in a cost-effective manner.”
Philadelphia-based Paul Weiner, a shareholder and national e-discovery counsel at Littler Mendelson, is a member of that choir. “Even lawyers (and clients) who resisted entering the digital age now realize that there are baseline standards that must be followed when handling electronic data in litigation, and there are serious consequences for not meeting those standards. Thus, the demand for e-discovery litigation support services and skilled professionals to staff those departments has spiked,” he said. “While some law firms were early adopters, most major law firms that have not already done so have recognized that they need to have, develop, or build some in-house e-discovery and litigation support capabilities to handle modern litigation.”
Thomas Lidbury, partner at Drinker Biddle & Reath and chair and president of its subsidiary, Drinker Discovery Solutions, agrees that law firms are playing “catchup,” which may explain the hiring surge. “Litigation support services are natural law firm functions. As e-discovery emerged, the volume of data that needed to be managed grew beyond many law firms’ ability to handle it and their clients’ ability to pay for it under the traditional law firm model,” said Chicago-based Lidbury. “The gap was filled by outside technology companies and contract attorney services, and law firms were slow to adapt. Law firms are now catching up and providing the litigation-related services that their clients need. As David concludes, that means people, process and technology.”
One manager of litigation support at a Global 50 firm, who asked to speak anonymously, says that new technology is helping deliver shorter turnaround, suggests that the economy may be a key factor: “The revenue increase may also possibly relate to the willingness of clients to pursue litigation in a seemingly more stable financial environment than experienced in 2009 through 2011, thus creating more work.” While the managers’ firm has not created new posts, it is still looking to fill existing positions that are vacant.
Steve Fletcher, CIO of Parker Poe, suggests that email may be a factor in the employment hike. “Our litigators know the profound value of emails and attachments — people say things in email that you’d never find in a formal report or letter. Our daunting challenge is to make sure we deliver those key emails at trial that we culled from a hundred gigabyte mountain of data — and at a fair price to our clients,” says Fletcher, who is based in Charlotte, N.C.
Craig Ball, LTN’s e-discovery columnist, said that as the “need for and cost of litigation support has grown, firms have become more adept at accounting for the effort and passing the costs on to clients. Clients, in turn, increasingly push counsel to delegate work to lower-cost skilled personnel.” Ball, an Austin-based attorney/consultant, says that “in part, it’s a recognition that the highest paid personnel in the firm are too often the least adept at scoping or managing projects requiring significant litigation support in areas like electronic discovery.”
But Ball offers a caveat: “While it’s encouraging to see litigation support personnel grow in stature as profit centers, I hope it’s not an indication that lawyers are becoming less hands-on with the digital evidence in their cases. Each time someone stands between the lawyer and the evidence, the lawyer gleans a little less and edges closer to failure. With luck, it’s a harbinger that firms are moving beyond the creation of e-discovery practice groups as a marketing ploy and genuinely seeking to develop real expertise that clients are willing to pay for.”
One CIO at a national firm, who spoke only on condition of anonymity, said his team initially evaluated the amount of money spent sending the work to vendors about $3 million a year before the firm decided to bring much of the work in house. In the past, the equipment and software was too expensive to bring this work in house, he said, but with prices dropping, and technology improving, in-house operations now can handle more. His firm uses LexisNexis’LAW PreDiscovery, and kCura’s Relativity, among other technologies, and can now “equal the vendors” in cost and production.
“My lit department showed value to the firm by increasing monthly billing from $9K a month to $70K plus,” he said. “We did the work quicker and without errors. The lawyers did lose the free breakfasts and sports tickets brought by the vendors, but they quickly forgot about the vendors when the lawyers saw the revenue generated by the lit department,” he said.
“My costs are about $400K (people and equipment), we bring in about $900K, and we are just getting started. I expect this to hit $3 million plus as the growth of e-discovery continues. The genie is out of the bottle,” he said.
DISSENTERS
But not everyone is on the bandwagon. A few privately quipped that they expect Cowen’s numbers to “always point towards ‘Law firms must hire!'” because, after all, he’s a headhunter. Said one, “I feel like Spock from ‘Star Trek,’ with one thought, ‘Interesting … .’ ” Several suggested that the distinctions between the job titles were vague, and might need better definition.
Nixon Peabody’s John Roman Jr., director of IT operations and legal technology services, questioned the assertion that lit support staff bill an average of 2,000 hours per year. “The problem with Cowen’s analysis is it provides a 50,000-foot level of detail.” It is also a bit contradictory, says Roman, who is based in Rochester, N.Y. “For example, if tech is allowing firms to do more with less people, why will there be 375 new positions created,” an observation echoed by New York-based consultant George Rudoy, CEO of Integrated Legal Technology. Rudoy suggests that larger firms may be replacing their directors/managers with more junior staff — following a trend at both corporations and law firms for fewer high-level specialists and decision makers. “But even then the number is just too big,” he says.
But Parker Poe’s Fletcher rebuts that position: “Sure, the new technology enables our litigation teams to do twice as much — but when the mountain of e-discovery increases 10-fold, you’ll have to find other ways to increase efficiency and overall value to clients.”
Chicago’s Bruce Blank, director of litigation services and support at Foley & Lardner, says the 375 number is possible. “We increased staff by two positions last year. However, not because of increase volume, but more for efficiencies and address the quality of life for our team by adding staff and lowering overall hours per person.”
Roman also wants to know what tasks constitute billable time and “how much of the EDD specialist fees are actually being collected, as opposed to written off,” and “what specific technology are the specialists using to make their jobs so much more efficient that they can do so much more?” He agrees that data volume are growing, as is productivity from legal technology specialists, but he attributes that more to streamlined process and experience, rather than the latest tech tools. “Our litigation case load is up, which contributes to more e-discovery and billable hours per [specialist], but our intellectual property litigation cases have increased a lot of data) as well as labor … lawsuits.
Scottsdale-based Sally Gonzalez, senior director with HBR Consulting, also questions the role of write-offs. “One of the historical problems was that firms tended to write off a lot of in-house lit support for a number of reasons: Clients refused to pay but expected firms to provide the services, lawyers thought the in-house services were not efficient and so should be discounted, clients pushed for write-offs on entire bill for some reason and lawyers pushed the write-off to lit support so as not to penalize lawyers, etc.,” she observed. “How much of the increase has to do with firms dealing more realistically and proactively on these write-off pressures?”
RELATIONSHIPS
Then there are the ever-cranky relationships between firms and their counsel: “Law firms are less and less in control of the EDD process — the number of corporations calling shots in e-discovery with assistance from consultants is growing rapidly,” observed Rudoy. “It would be more logical to predict that corporations will be hiring more staff to be even more in control of their process … but law firms hiring more? Unlikely. If a law firm is not in control the process and completely at the mercy of their clients, how do you create new positions and add staff?”
Said Foley’s Blank: “I think the biggest factor that will cause the growth in lit support is the corporate and vendor demand. Litigation support in the corporate market has dramatically grown as well as the vendor market. It was if you could hear the sucking sound in the void of supply for quality people,” he said. “Technology is not getting simpler but extremely complex. Lets face it, assisted reviews using artificial intelligence is not the same discovery of our fathers. The days of attorneys just doing discovery are long, long gone and for the most part attorneys failed to stay with the technology, which is understandable. As a result the need for specialized staff grows.”
FUTURE OPPORTUNITIES
Kenneth Jones, COO of Xerdict Group, a subsidiary of Sedgwick, says current e-discovery technology is just the beginning of how litigation support teams can streamline costs and generate revenue. He suggests that firms “use collaboration technologies in non-traditional, creative ways to provide client service in new-but-related areas.” For example, firms could implement a workflow-based discovery/research system to help a corporate client track and manage discovery requests; build systems to track and manage internal investigations at companies (vis-à-vis managing legal cases); or create systems to track and manage the location of litigation document and artifacts within a company facility.
If your litigation support technology is agile and nimble litigation support teams can quickly construct a tool matching what are usually unique business needs at a corporate client, says Jones. “When you can do that, it is a great opportunity to improve client service, strength the relationship and ties between law firm and client, and provide billable services to a client.”
2) “Hiring is concentrated in positions that are relatively highly billable and low cost,” including analysts, specialists, and project managers. The report says that analysts billed an average of 1,600 hours, at $160/hour. Specialists: 2,000 hours at $185/hour; PMs: 1,150 hour at $200/hour.
3) “Highly profitable firms are making larger investments in headcount,” the report notes, with a quarter of firms accounting for 65 percent of 2011 revenue. Those same firms are expected to add 45 percent of the new positions, and generate 68 percent of new 2012 revenue, TCG predicts.
4) Some firms are investing in upgrading their departments, “turning cost centers into revenue generators.”
Methodology: TCG surveyed 22 firms, 17 in major urban areas (five from New York; two each in San Francisco, Los Angeles, Boston, and Atlanta; one each in Chicago, Dallas, Philadelphia, and Washington, D.C.). Three participants were from secondary markets: Pittsburgh, Columbus, and Columbia. Seven firms were in the Am Law top 50, six were in the top 51-100, seven in the top 101-200, and two “others.” Respondents included 12 directors, one CIO, one chief knowledge officer, and eight managers; 95 percent of participants were heads of their departments.
A strong motivator, to no one’s surprise, appears to be corporate counsel. “Sophisticated corporations continue to invest in e-discovery capabilities, records management, and service provider relationships, creating a new client landscape for law firm e-discovery and litigation support departments,” the report notes. “Evolving client expectations require law firms to provide elevated levels of strategic, tactical, and operational competencies — all with direct implications on their hiring needs.”
The survey also evaluates trends in how firms are billing for specific EDD tasks. For example, 56 percent of respondents say they bill hourly for collection and preservation, and only 2 percent bill per gigabyte, and 33 percent say “other.” Document review — an area where many firms have struggled to find the best formula (see LTN’s February cover story, “True Grit”) — shows a whopping 79 percent of respondents saying their firm bills by the hour for those services.
MIXED REACTIONS
We polled e-discovery experts, as well as members of LTN’s Editorial Advisory Board, to get their take on the Cowen survey assertions. The reactions were mixed.
“These results don’t surprise us at all,” said attorney Matthew Kesner, CIO of Mountain View, Calif.-based Fenwick & West. “We have seen the amounts of electronically stored information increase at a rate of 150 percent every nine months. The increasing amounts of data created by all businesses seems to be the primary driver. Clients also seem more able to access the data quickly,” he said. Kesner notes that Fenwick’s workload for in-house litigation support is “way up. We are worried about burning them out.” But, he caveats, “as our methods get better and we get faster we do seem to be helping clients resolve matters an investigations faster. In that sense it is a ‘win-win.'”
Phoenix consultant Michael Arkfeld, a former federal prosecutor, says firms of all sizes are still adapting to their legal responsibilities for ESI. The rise in personnel, he suggests, may reflect the growing sophistication of counsel about the need to more thoroughly conduct identification, location, and collection, triggering the need for more skilled personnel.
Attorney Albert Barsocchini, a San Francisco-based consultant, agrees: “The growth of regional vendors and outsourcing confirms the survey,” he says. “With the current state of technology, corporations are reaching the proper balance between insourcing and outsourcing.”
David Kessler, partner and co-chair of Fulbright & Jaworski’s e-discovery and information governance practice group, says the figures may reflect “the rise in importance of litigation support groups, given our clients’ increased focus on value, innovation, and project management in the delivery of legal services. With the rise of e-discovery, sophisticated litigation support departments were the first to adopt these principles to address highly complex ESI challenges in a cost-effective manner.”
Philadelphia-based Paul Weiner, a shareholder and national e-discovery counsel at Littler Mendelson, is a member of that choir. “Even lawyers (and clients) who resisted entering the digital age now realize that there are baseline standards that must be followed when handling electronic data in litigation, and there are serious consequences for not meeting those standards. Thus, the demand for e-discovery litigation support services and skilled professionals to staff those departments has spiked,” he said. “While some law firms were early adopters, most major law firms that have not already done so have recognized that they need to have, develop, or build some in-house e-discovery and litigation support capabilities to handle modern litigation.”
Thomas Lidbury, partner at Drinker Biddle & Reath and chair and president of its subsidiary, Drinker Discovery Solutions, agrees that law firms are playing “catchup,” which may explain the hiring surge. “Litigation support services are natural law firm functions. As e-discovery emerged, the volume of data that needed to be managed grew beyond many law firms’ ability to handle it and their clients’ ability to pay for it under the traditional law firm model,” said Chicago-based Lidbury. “The gap was filled by outside technology companies and contract attorney services, and law firms were slow to adapt. Law firms are now catching up and providing the litigation-related services that their clients need. As David concludes, that means people, process and technology.”
One manager of litigation support at a Global 50 firm, who asked to speak anonymously, says that new technology is helping deliver shorter turnaround, suggests that the economy may be a key factor: “The revenue increase may also possibly relate to the willingness of clients to pursue litigation in a seemingly more stable financial environment than experienced in 2009 through 2011, thus creating more work.” While the managers’ firm has not created new posts, it is still looking to fill existing positions that are vacant.
Steve Fletcher, CIO of Parker Poe, suggests that email may be a factor in the employment hike. “Our litigators know the profound value of emails and attachments — people say things in email that you’d never find in a formal report or letter. Our daunting challenge is to make sure we deliver those key emails at trial that we culled from a hundred gigabyte mountain of data — and at a fair price to our clients,” says Fletcher, who is based in Charlotte, N.C.
Craig Ball, LTN’s e-discovery columnist, said that as the “need for and cost of litigation support has grown, firms have become more adept at accounting for the effort and passing the costs on to clients. Clients, in turn, increasingly push counsel to delegate work to lower-cost skilled personnel.” Ball, an Austin-based attorney/consultant, says that “in part, it’s a recognition that the highest paid personnel in the firm are too often the least adept at scoping or managing projects requiring significant litigation support in areas like electronic discovery.”
But Ball offers a caveat: “While it’s encouraging to see litigation support personnel grow in stature as profit centers, I hope it’s not an indication that lawyers are becoming less hands-on with the digital evidence in their cases. Each time someone stands between the lawyer and the evidence, the lawyer gleans a little less and edges closer to failure. With luck, it’s a harbinger that firms are moving beyond the creation of e-discovery practice groups as a marketing ploy and genuinely seeking to develop real expertise that clients are willing to pay for.”
One CIO at a national firm, who spoke only on condition of anonymity, said his team initially evaluated the amount of money spent sending the work to vendors about $3 million a year before the firm decided to bring much of the work in house. In the past, the equipment and software was too expensive to bring this work in house, he said, but with prices dropping, and technology improving, in-house operations now can handle more. His firm uses LexisNexis’LAW PreDiscovery, and kCura’s Relativity, among other technologies, and can now “equal the vendors” in cost and production.
“My lit department showed value to the firm by increasing monthly billing from $9K a month to $70K plus,” he said. “We did the work quicker and without errors. The lawyers did lose the free breakfasts and sports tickets brought by the vendors, but they quickly forgot about the vendors when the lawyers saw the revenue generated by the lit department,” he said.
“My costs are about $400K (people and equipment), we bring in about $900K, and we are just getting started. I expect this to hit $3 million plus as the growth of e-discovery continues. The genie is out of the bottle,” he said.
DISSENTERS
But not everyone is on the bandwagon. A few privately quipped that they expect Cowen’s numbers to “always point towards ‘Law firms must hire!'” because, after all, he’s a headhunter. Said one, “I feel like Spock from ‘Star Trek,’ with one thought, ‘Interesting … .’ ” Several suggested that the distinctions between the job titles were vague, and might need better definition.
Nixon Peabody’s John Roman Jr., director of IT operations and legal technology services, questioned the assertion that lit support staff bill an average of 2,000 hours per year. “The problem with Cowen’s analysis is it provides a 50,000-foot level of detail.” It is also a bit contradictory, says Roman, who is based in Rochester, N.Y. “For example, if tech is allowing firms to do more with less people, why will there be 375 new positions created,” an observation echoed by New York-based consultant George Rudoy, CEO of Integrated Legal Technology. Rudoy suggests that larger firms may be replacing their directors/managers with more junior staff — following a trend at both corporations and law firms for fewer high-level specialists and decision makers. “But even then the number is just too big,” he says.
But Parker Poe’s Fletcher rebuts that position: “Sure, the new technology enables our litigation teams to do twice as much — but when the mountain of e-discovery increases 10-fold, you’ll have to find other ways to increase efficiency and overall value to clients.”
Chicago’s Bruce Blank, director of litigation services and support at Foley & Lardner, says the 375 number is possible. “We increased staff by two positions last year. However, not because of increase volume, but more for efficiencies and address the quality of life for our team by adding staff and lowering overall hours per person.”
Roman also wants to know what tasks constitute billable time and “how much of the EDD specialist fees are actually being collected, as opposed to written off,” and “what specific technology are the specialists using to make their jobs so much more efficient that they can do so much more?” He agrees that data volume are growing, as is productivity from legal technology specialists, but he attributes that more to streamlined process and experience, rather than the latest tech tools. “Our litigation case load is up, which contributes to more e-discovery and billable hours per [specialist], but our intellectual property litigation cases have increased a lot of data) as well as labor … lawsuits.
Scottsdale-based Sally Gonzalez, senior director with HBR Consulting, also questions the role of write-offs. “One of the historical problems was that firms tended to write off a lot of in-house lit support for a number of reasons: Clients refused to pay but expected firms to provide the services, lawyers thought the in-house services were not efficient and so should be discounted, clients pushed for write-offs on entire bill for some reason and lawyers pushed the write-off to lit support so as not to penalize lawyers, etc.,” she observed. “How much of the increase has to do with firms dealing more realistically and proactively on these write-off pressures?”
RELATIONSHIPS
Then there are the ever-cranky relationships between firms and their counsel: “Law firms are less and less in control of the EDD process — the number of corporations calling shots in e-discovery with assistance from consultants is growing rapidly,” observed Rudoy. “It would be more logical to predict that corporations will be hiring more staff to be even more in control of their process … but law firms hiring more? Unlikely. If a law firm is not in control the process and completely at the mercy of their clients, how do you create new positions and add staff?”
Said Foley’s Blank: “I think the biggest factor that will cause the growth in lit support is the corporate and vendor demand. Litigation support in the corporate market has dramatically grown as well as the vendor market. It was if you could hear the sucking sound in the void of supply for quality people,” he said. “Technology is not getting simpler but extremely complex. Lets face it, assisted reviews using artificial intelligence is not the same discovery of our fathers. The days of attorneys just doing discovery are long, long gone and for the most part attorneys failed to stay with the technology, which is understandable. As a result the need for specialized staff grows.”
FUTURE OPPORTUNITIES
Kenneth Jones, COO of Xerdict Group, a subsidiary of Sedgwick, says current e-discovery technology is just the beginning of how litigation support teams can streamline costs and generate revenue. He suggests that firms “use collaboration technologies in non-traditional, creative ways to provide client service in new-but-related areas.” For example, firms could implement a workflow-based discovery/research system to help a corporate client track and manage discovery requests; build systems to track and manage internal investigations at companies (vis-à-vis managing legal cases); or create systems to track and manage the location of litigation document and artifacts within a company facility.
If your litigation support technology is agile and nimble litigation support teams can quickly construct a tool matching what are usually unique business needs at a corporate client, says Jones. “When you can do that, it is a great opportunity to improve client service, strength the relationship and ties between law firm and client, and provide billable services to a client.”



Leave a Reply