Saturday, March 3, 2012

Fordham Law School creates course on legal services marketing to help new grads land business

According to this column from Law.com, Fordham law has hired a specialist in legal services marketing to help students learn business development skills. Adjunct Professor  Silvia Hodges, says her Fordham faculty profile, is the first person to obtain a PhD in law firm marketing. In addition to teaching at Fordham, she is also a full-time faculty member at Emerson College in Boston where she teaches in the department of marketing communication.

One of her key tips for law students hoping to develop a book of business is to blog, whether as a guest for someone else's blog or by starting their own. Professor Hodges maintains a legal marketing blog here which includes a page where her Fordham students can try their own hand at blogging (check out the student posts here).

Professor Hodges tells Law.com:

It is never too early to start developing your personal brand . . . . "Why wait?" she said. "Take courses in the area you want to focus on, join associations and interest groups, etc. — and blog about it. All this will help build your own brand and distinguish you from the many other young lawyers out there. This will put you in front of firms and potential clients."

This message has resonated with Hodges' students. "I'll be working at a Manhattan law firm this summer and hope to begin my career there, and want to give myself as many tools as possible to improve my value to that firm," 2L Andrew Fleischman said.

Building your brand is all about improving your value. "Blogging is a great tool to help law students accomplish this," Hodges said. "Great posts show that you are familiar with the topic. You become part of the discussion, become known among those interested in the topic. Having valuable contacts online is part of becoming a thought leader. You get your name out, it gives you visibility and helps you with search engine optimization. Your name and content will pop up when people look for your topic. Hopefully, this will help you get hired."

Launching a blog can be intimidating, but free platforms like Wordpress and Blogger make it easy. Hodges recommended that aspiring lawyers begin by "focusing on a niche you are really interested in. Do research and understand which platform works best for your viewpoint. Learn as much as you can about this topic and write brief, intriguing, easy-to-read blog posts on a regular basis."

Keep reading here.

(jbl).

March 3, 2012 | Permalink | Comments (0)

When Should You Quit Your Job: Five Indicators

This is a hard issue to face. And once you’ve faced it and decided that you should move on, it can be very hard to actually initiate the move. Academic program specialist Brent Miller offers five indicators that it’s time to pack your suitcase.

 Always doing more with less.

Horrible leadership.

You're not making a difference.

The slow punishment of boredom.

No room at the top.

Shudder. The full article is at the Chronicle of Higher Education online.

(ljs

March 3, 2012 | Permalink | Comments (0)

Friday, March 2, 2012

Why Tuition Has Skyrocketed At State Schools

From the New York Times:

"But at least at public colleges and universities — which enroll three out of every four American college students — the main cause of tuition growth has been huge state funding cuts."

"Why? Struggling states have to prioritize other mandatory spending, like Medicaid. Higher education usually falls under the “discretionary spending” part of the budget — and in fact is often one of the biggest programs, if not the biggest, in the discretionary category."

"Sure, state tax revenues are growing again, but so are state spending obligations. States will soon have to pay out trillions in public pensions for the retiring baby boomer generation — squeezing the funds for training the next generation of workers even more."

(Scott Fruehwald)

 

March 2, 2012 | Permalink | Comments (0)

Courts begin to use Twitter to announce release of opinions.

Over at the Legal Blog Watch, Bruce Carton has compiled a list of courts that are starting to use Twitter for various purposes, including letting the public know when decisions are released. 

My quick research as to state courts' use of Twitter in the U.S. indicated that many states are already using Twitter for various purposes, including:

On the federal level, the U.S. Supreme Court is using Twitter to distribute opinions, as is the 9th Circuit and courts such as the U.S. Bankruptcy Court for the Southern District of New York. I could not find a comprehensive guide to "courts on Twitter" but it seems likely that one exists out there somewhere. If you know of such a guide, please shoot me a link to it and I'll update this post.

Continue reading here to learn about how Canadians courts have been making use of Twitter too.

(jbl).

March 2, 2012 | Permalink | Comments (0)

Tuition Three Times Faster than Inflation, But Some Schools Buck the Trend

Tuition for private law schools grew from an average of $21,790 in 2000 to $37,702 in 2010, an increase of 73 percent.

Public schools have increased their tuition at a far higher percent — more than 150 percent. Tuition for residents has increased from $7,790 in 2000 to more than $20,000 in 2010.

The statistics are compliments of the National Jurist’s Employer Insider.

Overall, however, only eleven law schools have kept tuition below 60 percent growth over the past ten years. Inflation has grown by 25 percent over the same period.

A higher number of law schools — 36 — have kept tuition increases below $10,000. Most of these are public schools that started with very low tuition.

Still, more schools now plan either no tuition increases or are offering current students flat-rate tuition. Schools planning no increases or very low increases include University of Tulsa School of Law, Michigan State University College of Law, St. Louis University School of Law, South Texas College of Law in Houston.

The article offers more statistics.  I think law school administrators have known that eventually they would hit a ceiling on tuition—that higher tuition would dissuade a significant number of applicants  (and their parents) from the law school track. I suspect that we have reached that ceiling or are rapidly approaching it.

(ljs)

March 2, 2012 | Permalink | Comments (0)

Thursday, March 1, 2012

In Defense of Mandatory Curves

Joshua M. Silverstein has undertaken an extensive study of mandatory curves.  You can see his results here.

Abstract: This article sets forth the first comprehensive defense of mandatory curves. It begins with a case study of one law school. That institution lacked formal grade normalization policies during the period of the case study. As a result, the school suffered from dramatic grade disparities. This article contains a list and statistical analysis of the most significant disparities. The statistical analysis supports the conclusion that the grade disparities were caused by differences in teacher grading philosophy, and not by student merit or any other factor. Next, this article presents several arguments in favor of mandatory curves. The most crucial is that grade variances that flow from differences in professor grading philosophy are grossly unfair to students. A second important defense of forced curves is that grade disparities distort the process of course selection, inducing students to register for classes based on the grading practices of the professor rather than on substantive concerns, such as topical importance, career relevancy, and skill development. The article then responds to the eight most significant and common objections to mandatory curves. Several of these objections are deeply problematic, such as the contention that curves prevent professors from awarding students the grades they deserve. Others have some merit, such as the argument that mandatory curves encourage excessive competition among students. But the latter set of criticisms ultimately does not undercut the case for curves, principally because mandatory curves are the lesser evil. For example, the competition objection fails because the significant grade disparities that frequently result in the absence of a curve probably cause more competition than mandatory curves do. And even if forced curves do increase competition, the unfairness of grade disparities flowing from differences in professor grading philosophy is the more pressing concern. Finally, the article ends with a discussion of some issues regarding the structure and scope of mandatory curves, including the applicability of curves to smaller classes, seminars, and clinics.

(Scott Fruehwald) 

March 1, 2012 | Permalink | Comments (0)

Friday Fun: Nano-copters play the theme from James Bond

What does this have to do with "legal skills?"  Well, there's no literal connection, as Walter Sobchak might say. Ok, maybe there's no connection at all. Except insofar as nano-copters are being programmed to play musical instruments, how long until replicants are taking the depositions you used to do? 

Enjoy!

(jbl).

March 1, 2012 | Permalink | Comments (0)

Tips for dealing with abusive opposing counsel

Law students, trust me, you need to learn this skill too. One of the more vexing aspects of practice.  From the blog Attorney@Work:

If you’re going to be a lawyer today—and be a professional—it’s best to arm yourself with some effective ways to react in the face of the incivility. To that end, here is advice about how to respond in two situations where bad behavior is most likely to occur.

On the Phone

From time to time, opposing counsel may act in an uncivil or unprofessional manner during a telephone call, where there is no official record as there might be in a deposition or a written communication. They may call you or your client names, or make implied or overt threats (such as going to the court, or serving discovery requests that will make your life unbearable). In these situations, it is important that you stay calm and civil—and most importantly, do not respond in kind.

The best practice is to write a letter memorializing the telephone call as soon as it is done, and send it to opposing counsel. Objectively summarize what was said, making sure to include the uncivil behavior. Your tone should be measured and reasonable, but your letter should accurately reflect the events of the phone call. This creates a record that you can later use as a submission to the court, if necessary. The letter, though, is usually enough to curb such behavior because it shows opposing counsel you are serious. Most will not want the record reflecting that they have been acting inappropriately.

During a Deposition

Opposing counsel may try to intimidate you during a deposition, hoping to fluster you if you are inexperienced. This can take many forms, but typically opposing counsel will make many speaking objections, instruct the witness how to answer, or sometimes tell you how to run the deposition.

The first line of defense is to merely ignore the speaking objections and other chatter. Oftentimes opposing counsel is just trying to annoy you, and if you don’t take the bait, they will tire and stop the inappropriate behavior. If they persist, however, make a statement on the record. Say that the attorney’s actions are inappropriate and if they persist you will seek intervention from the court with all available remedies after the deposition, including re-deposing the witness. Threatening to call the judge or head over to the courthouse is often enough to put an end to it.

Remember, too, that depositions are transcribed and often videotaped. If opposing counsel gets agitated or starts yelling, stay calm and make sure you come across as the civil party here. At the end of the deposition, make a statement on the record about counsel’s uncivil behavior, describing clearly any behavior that would not be reflected in a written transcript, such as yelling, exasperated sighs, etc. State that because of such behavior, you are not closing the deposition, but rather keeping it open in order to seek all available relief.

Play Your Own Game

Never respond in kind when you encounter opposing counsel who act in an uncivil manner—no matter the circumstances. Do not play their game and do not learn from them. Instead, make your practice your own.

(jbl).

March 1, 2012 | Permalink | Comments (1)

Should Lay People Forgo Legal Representation and Use Standardized Forms?

The issue is coming to a head in Texas. The Texas Supreme Court created the Uniform Forms Task Force in March 2011 and ordered it to work with the Texas Access to Justice Commission to create standardized forms to help low-income Texans represent themselves when they can't afford lawyers. In early January, the task force submitted forms for simple, uncontested divorces with no children and no real property. Many Texas family lawyers take issue with the project.

Here is the accompanying article from the Texas Lawyer. It includes a 5:38 minute video featuring advocates on both sides of the issue.

 Although I once  favored creating such standardized forms, my experience as a  Legal Services lawyer has left me with serious doubts about the ability of low income lay people (and lay people at a  higher economic level) to maneuver through the judicial system alone. Qualification: I opine having never seen the proposed Texas forms and instructions.

(ljs)

March 1, 2012 | Permalink | Comments (2)

Wednesday, February 29, 2012

Perfectionism is the cause of much procrastination

If you weren't aware of that already, check out this story from the ABA Journal blog.

Procrastinators May Be Perfectionists Looking for an Out, Expert Says

Perfectionism can be linked to procrastination, according to a consultant who has written a book on time management.

Productivity consultant Julie Morgenstern, author of Time Management from the Inside Out, tells the New York Times that perfectionists often need deadline pressures to force themselves to finish projects.

She elaborates in a blog post. “Perfectionists feel compelled to do everything at the same level of excellence, often driven by a ‘If I can’t do this perfectly, I’m not going to do it at all’ mentality,” she writes. Morgenstern suggests practicing “selective perfectionism”—deciding which tasks need to be perfect and which can be done just well enough. Delegating trivial tasks can also help.

The most effective people focus on progress over perfection, according to corporate trainer Rory Vaden. He outlines the extent of the problem in an interview with the Times. In one survey, employees admitted wasting, on average, two hours a day at work, he says.

(jbl).

February 29, 2012 | Permalink | Comments (0)

Star Jones Criticizes Whiny Law School Grads

Star Jones said the following on the Today Show concerning disgruntled law school grads: "Jones, a litigatrix turned legal commentator, said that there was “no way” the suits would be successful. She suggested that the plaintiffs should focus their energies on their job searches rather than blaming others. 'No one’s going to hand you a job,' she said. 'I hate whiners!'"

Another commentator said this: Donny "Deutsch, who is not a lawyer, viewed the controversy from a cultural rather than legal perspective. 'This isn’t a legal issue,; he said. 'This is what I call the Whiny Generation…. Talk about Brokaw’s ‘Greatest Generation’ — this is the opposite.'"

The full article is here.

(Scott Fruehwald)

P.S.  As Lou said in a post a couple of weeks ago, I am only reporting the news.  I do think the comments are harsh.

February 29, 2012 | Permalink | Comments (0)

Reform Moot Court Competitions

Here’s a thoughtful post from guest blogger Ruth Anne Robbins, Clinical Professor of Law and Director of Lawyering, Rutgers Law School—Camden.

It is moot court season. Law students looking quite purposeful in their conservative suiting as they tell you that they will have to leave class early today or that they will be missing a class or two next week. It’s the season when all law schools and practitioners involved with these competitions might tell ourselves that we can use them to help reform legal education.  

The existing paradigm of moot court competition has been in place for several decades. Teams of students prepare briefs and practice oral arguments about some of the nattier legal issues facing experts in a particular field of law. There’s a minimal record involved, and the standard of review is usually de novo. The competitions prioritize pure legal analysis and the technical skill of advocacy at the high federal levels. Although faculty coaches can provide feedback during the oral argument practices, the students write their briefs without the individualized feedback that students received in their legal writing courses.

If we want to teach our students essential skills that they will need and use early in their legal careers, organizers of moot court competitions need to reassess their pedagogical goals.. 

When we talk about modifying the law school curriculum to better help our students become “practice-ready,” we are actually talking about helping students become client-ready. Clients need lawyers to muck around in facts, to problem-solve, and generally to exercise judgment as well as technical skills. To get there, we need to create more lawyering moments for our students: a combination of legal analysis, factual analysis, skills, and client-centeredness. Clinicians are experts at creating these moments. It makes sense to make these moot court programs more clinical. 

What does a client-centered moot court program look like? It looks like a program that:

1. Bridges legal writing and clinical education.

2. Focuses on persuasive advocacy on behalf of a lifelike client.

3. Teaches students to understand and then tell the client’s story in order to advocate for an outcome that is acceptable to the client.

4. Asks the student to grapple with much more common mixed standards of review.

5. Permits a professor to give individualized feedback on the brief as well as the oral argument.

In other words, make the moot court competition worthy of being a part of modern legal education.

(ljs)

 

February 29, 2012 | Permalink | Comments (4)

Law Review Circulation Drops in 2011

This post from the Wall Street Journal Law Blog discusses the 2011 law journal circulation data. 

“George Mason University law professor Ross E. Davies, who delights in calling out law reviews for puffing up their circulation numbers, has crunched the 2011 data. It wasn’t a good year.”

Access Professor Davies’ article and data here.

(dkh)

February 29, 2012 | Permalink | Comments (0)

Tuesday, February 28, 2012

"Law Deans in Jail"

That's the title of a new article by Professors Morgan Cloud and George B Sheperd (both Emory) and available here on SSRN. In the article, the authors posit that law deans who submitted false data (graduate employment figures, entering class LSAT scores, etc.), to bolster their school's USNWR rankings may have committed criminal fraud. 

From the abstract:

A most unlikely collection of suspects - law schools, their deans, U.S. News & World Report and its employees - may have committed felonies by publishing false information as part of U.S. News' ranking of law schools. The possible federal felonies include mail and wire fraud, conspiracy, racketeering, and making false statements. Employees of law schools and U.S. News who committed these crimes can be punished as individuals, and under federal law the schools and U.S. News would likely be criminally liable for their agents' crimes.

Some law schools and their deans submitted false information about the schools' expenditures and their students' undergraduate grades and LSAT scores. Others submitted information that may have been literally true but was misleading. Examples include misleading statistics about recent graduates' employment rates and students' undergraduate grades and LSAT scores.

U.S. News itself may have committed mail and wire fraud. It has republished, and sold for profit, data submitted by law schools without verifying the data's accuracy, despite being aware that at least some schools were submitting false and misleading data. U.S. News refused to correct incorrect data and rankings errors and continued to sell that information even after individual schools confessed that they had submitted false information. In addition, U.S. News marketed its surveys and rankings as valid although they were riddled with fundamental methodological errors.

Hat tip to the Chronicle of Higher Ed.

(jbl).

February 28, 2012 | Permalink | Comments (0)

Thinking Outside The Box II: Creativity

As I mentioned a couple of days ago, it is important to teach our students to think outside the box so that they can come up with creative answers.  Creativity has two parts: thinking up a unique solution, then criticizing it to make sure it works.  The first part is called "brainstorming," which means to come up with as many ideas as possible without being critical.  Being critical is the second step.

Here is a classic problem.  Come up with as many uses of a brick as possible.  Do not be critical in this stage!  Then, determine how many of your uses might be practical.

(Scott Fruehwald) 

February 28, 2012 | Permalink | Comments (0)

"How to Publish While You Are in Law School"

From the always informative Lawyerist blog:

Why Publish In Law School?

There are several good reasons to publish while in law school. First, you will already have to write at least one comprehensive paper during your three years at law school—so why not try to get it published. Moreover, you may be surprised at how little additional work will be required to make it publishable. Depending on your topic and area of expertise, your work may be exactly what a particular journal is looking for.

Second, some journals will publish student work, but will only publish a non-student’s work if the person is an expert in the field. As such, your status as a student can get you an opportunity and audience that you would not otherwise have.

Finally, there may be a significant cost savings associated with publication as a student because many students have the benefit of submitting their papers to as many journals as they like for free through an on-line submission vehicle called ExpressO. If you are not a student, you must pay $2.20 per journal. With hundreds of journals, this can become costly.

What Are The Benefits of Publishing?

Apart from the practical reasons for publishing while in law school, there are also several benefits. First, publication looks excellent on a resume. Moreover, if you publish, you will gain instant credibility and employers, scholarship committees and others will immediately conclude that you are able to write well. Also, a publication will help you find a job and will make you eligible for other accolades such as scholarship money, clerkship positions and praise from faculty and peers. A published work will also assist you if you desire a law professor position some day.

The development of a scholarly piece of work will also enhance your research and writing skills. As with any lengthy paper, you will have to devote a significant amount of time to research. This will not only enhance your knowledge in a particular subject area but will also force you to access various database libraries to search for relevant material. Moreover, a significant amount of time will have to be spent formatting the paper and the related citations and this focus on the detail and blue book format will help you as a lawyer.

Finally, if you publish you will put your name in print and this is a good feeling. You should be proud if you publish something and there is no better feeling than receipt of the finished product with your name boldly splashed across the cover.

How Do I Start?

The first step in the process involves selecting a topic. This sounds easy but unfortunately there is an additional step that must be done. Once you have settled on a topic, you have to conduct something called a preemption search to ensure that your topic has not been written about in the past. This does not mean that you cannot write about the same topic as others but rather means that if you do, you must make it different in some way. The preemption search process involves searching databases for similar topics and reviewing the articles to see what they have covered.

Continue reading here.

(jbl).

February 28, 2012 | Permalink | Comments (0)

New York bar examiners say "Nyet" to online law school grads

The Second Circuit so ruled on February 16, 2012. Click here for the summary order. Below is write-up from the BNA Electronic Commerce and Law Report (subscription required).

Online Law Grads Can't Take N.Y. Bar Exam

New York has the right to keep graduates of online law schools from taking the state's bar examination, the U.S. Court of Appeals for the Second Circuit decided Feb. 16 (Bazadier v. McAlary, 2d Cir., No. 10-4956, 2/16/12).
In an unpublished summary order, the court endorsed the conclusion of the district court that the admissions rules at issue do not violate applicants' rights to equal protection or freedom of association.
The lawsuit was filed by Frank A. Bazadier, a 1999 graduate of Northwestern California School of Law, an online correspondence law school not accredited by the ABA. He was admitted to practice law in California. When Bazadier applied to take the New York bar exam, however, he learned that he was ineligible because he graduated from a correspondence law school.
District Judge Gary L. Sharpe decided that the complaint did not allege a viable equal protection claim. In his opinion, Sharpe found that Bazadier simply invoked the First Amendment in conclusory language without stating any facts to support his claim that the bar exam rules constitute content-based restrictions on speech and association.
The state argued, Sharpe noted, that the different treatment of correspondence-based study is rationally related to the state's interest in ensuring a competent bar. Correspondence-based study lacks the direct supervision typical of classroom-based education, the state contended, and therefore provides less assurance that work is actually being done by the enrolled student and that the student is getting an adequate legal education. Sharpe credited this argument and found that it provides a rational basis for disqualifying bar applicants who studied law through correspondence.
Describing the district court opinion as “thorough and well-reasoned,” the court of appeals affirmed. Rational basis was the correct standard of review, the court ruled, because Bazadier's claims did not implicate a fundamental right or a suspect class. The challenged rules “are not based upon the content of the instruction provided by a law school and do not favor or disfavor any form of speech on the ideas or views expressed,” the court said. “Rather, the Rules are occupational regulations that express a preference for one form of legal pedagogy over another.”
(jbl).

February 28, 2012 | Permalink | Comments (1)

Another Ranking of Law Schools

The National Law Journal has ranked the top 50 law schools by the percentage of JD grads who took jobs with the nation’s 250 largest firms. It also identifies the schools where these firms recruited the most graduates and where the most alumni were promoted to partner.

The Go-To Law Schools
The 50 law schools with the highest percentage of graduates who go on to NLJ 250 firms.

Firm Favorites
The schools that top NLJ 250 firms relied upon most to supply first-year associates.

Associates Promoted to Partner
Law schools that saw the most alumni promoted to partner in 2011.

Here’s another link.

I’m not sure we need another ranking. The success of a school’s ranking here depends on a number of factors including the culture of the law school, the location of the law firm, and the reputation of a school among law firms when that reputation may be out-of-date. The importance of this ranking also depends on whether you think getting a job with a megafirm is the goal of all law students.

(ljs)

February 28, 2012 | Permalink | Comments (1)

Twitter Archive – Search Service

Datasift (UK) is offering a service that will allow users to search tweets back to January 2010 according to this post from the BBC News.

“Until today, only the previous 30 days of tweets were available for companies to search. Regular users can access posts from the past seven days….The cost to businesses will depend on the company's size, with Datasift's entry-level package costing £635 ($1,000) per month for "individuals or developers".

Some privacy concerns have been expressed as a result of this movement to mine and archive Twitter:

“People have historically used Twitter to communicate with friends and networks in the belief that their tweets will quickly disappear into the ether," argued Gus Hosein, executive director of Privacy International. ..Companies can get detailed reports showing activity around a certain term or topic "The fact that two years' worth of tweets can now be mined for information and the resulting 'insights' sold to businesses is a radical shift in the wrong direction. “

It will be interesting to watch this unfold in the coming weeks and months.

(dkh)

February 28, 2012 | Permalink | Comments (0)

Monday, February 27, 2012

Canadian Views On Legal Education Reform

Learning by Doing by Heather Gardiner.  Some excerpts:

Osgoode dean Lorne Sossin advocates more hands-on learning in legal education. Regardless of the type of experiential learning, whether it’s participating in one of the law school’s clinics or one of its various intensive programs, he says it breaks down the barriers between the classroom and community, effectively creating better learning opportunities for students. “What we’re hoping is it sets our graduates up to have a real advantage that not every graduate of every law school will have,” he says. “[It’s] that experiential component that is very much what gives them insight into, for example, the different perspectives or lenses that a client might have, or a regulator might have, or the government might have, or the justice system might have. You start to look at issues from those different perspectives when you’ve seen how they play out in action. I think those are things that if you just go to law school and sit in the classroom for three years, you’re just less likely to get exposed to.”

Adam Campbell, an articling student at labour and employment law firm Harris & Co. LLP in Vancouver, agrees that his time at the University of Victoria Environmental Law Centre was his most memorable experience during law school. At the clinic, he worked on one main file related to storm water and the infrastructural issues with the city’s drainage system. He says his clinical work was much more inspiring than any of his classroom work, and even more beneficial than his articling term so far. “At times I actually found [the clinical work] more useful than the articling period that I’m doing right now. I had way more control over an actual file for the entire thing than I have so far while articling,” he says.

In an article he wrote for 4Studentsonline, Michael Oxman points out the benefits he got from working at UVic’s Business Law Clinic. “I found it useful to get feedback from lawyers as opposed to law school professors. While professors may compare work against theoretical models and research papers, practitioners are focused on how work functions in the real world. Rhetoric and purple prose are discouraged. Rather than contemplating remote hypotheticals, students are pushed to consider the practical realities of running a business and the tangible concerns of business people.”

Doug Ferguson, director of Western’s Community Legal Services clinic, says there are several ways for law schools to integrate more practical training into their curricula. He says students should have the choice to take a certain number of credits in clinical and ethical courses to reduce or eliminate their articling term — much like the option suggested by the LSUC’s articling task force. Universities could integrate articling into the three years of law school, or offer a capstone course or a simulated summer program where students work at a virtual law firm, similar to the program at the University of Glasgow in Scotland, he suggests. These alternatives would also help address the current articling crisis in Ontario, he adds.

(Scott Fruehwald) (hat tip: Educating Tomorrow's Lawyers Blog)

February 27, 2012 | Permalink | Comments (0)