Biglaw L&E Midlevel Associate in NYC - AMA

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kaiser

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Biglaw L&E Midlevel Associate in NYC - AMA

Postby kaiser » Mon Oct 22, 2018 8:22 pm

Currently a midlevel associate in labor & employment group at a large firm in NYC. Happy to answer any Q's about L&E, biglaw life, etc.

cayleystark

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Re: Biglaw L&E Midlevel Associate in NYC - AMA

Postby cayleystark » Mon Oct 22, 2018 8:33 pm

Thanks so much for this! Currently a 3L interested in labor and employment- what's your work-life balance like? Did you go straight in to L&E or did you start out as a generalist and then specialize? Did you start at your firm as a summer or transfer in? Thanks!

kaiser

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Re: Biglaw L&E Midlevel Associate in NYC - AMA

Postby kaiser » Mon Oct 22, 2018 8:42 pm

cayleystark wrote:Thanks so much for this! Currently a 3L interested in labor and employment- what's your work-life balance like? Did you go straight in to L&E or did you start out as a generalist and then specialize? Did you start at your firm as a summer or transfer in? Thanks!


My work-life balance is fairly good by biglaw standards. That's partly because my firm has a slightly lower billable hours requirement compared to other firms. It's also partly because my particular group is pretty humane and empathetic when it comes to respecting work-life issues. Though you definitely need to keep that in perspective. My non-lawyer friends would laugh pretty hard if I ever told them I have fairly good work-life balance. I usually stay late 1 or 2 nights per week depending on workflow. If its a busy week when multiple briefs are due, I may be there late every night. But I balance that out with true vacations where I can relax and essentially never get bothered with work. Part of that is because I hold my ground pretty clearly in setting those limitations and making it clear to partners and peers that I have no intention of working during my vacation unless its an emergency.

I started out as a generalist but not by choice. I wanted to do L&E from the very beginning, back when I was in law school. I went to a firm that had L&E but ended up being placed into general lit. I had no interest in general lit because my interest is much more the substance than the procedure. After about 1.5 years in general lit at my first firm, I made a a lateral move to break into L&E and have been doing it ever since.

cayleystark

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Re: Biglaw L&E Midlevel Associate in NYC - AMA

Postby cayleystark » Mon Oct 22, 2018 8:48 pm

kaiser wrote:
cayleystark wrote:Thanks so much for this! Currently a 3L interested in labor and employment- what's your work-life balance like? Did you go straight in to L&E or did you start out as a generalist and then specialize? Did you start at your firm as a summer or transfer in? Thanks!


My work-life balance is fairly good by biglaw standards. That's partly because my firm has a slightly lower billable hours requirement compared to other firms. It's also partly because my particular group is pretty humane and empathetic when it comes to respecting work-life issues. Though you definitely need to keep that in perspective. My non-lawyer friends would laugh pretty hard if I ever told them I have fairly good work-life balance. I usually stay late 1 or 2 nights per week depending on workflow. If its a busy week when multiple briefs are due, I may be there late every night. But I balance that out with true vacations where I can relax and essentially never get bothered with work. Part of that is because I hold my ground pretty clearly in setting those limitations and making it clear to partners and peers that I have no intention of working during my vacation unless its an emergency.

I started out as a generalist but not by choice. I wanted to do L&E from the very beginning, back when I was in law school. I went to a firm that had L&E but ended up being placed into general lit. I had no interest in general lit because my interest is much more the substance than the procedure. After about 1.5 years in general lit at my first firm, I made a a lateral move to break into L&E and have been doing it ever since.


Thanks! Do you know what the prospects are if you ever leave the firm? Obviously litigation is harder to transfer in-house but from looking I've seen a reasonable amount of L&E in-house postings. Do you have any suggestions for someone not starting out in big law but might like to have the option to get into a biglaw L&E group at some point?

kaiser

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Re: Biglaw L&E Midlevel Associate in NYC - AMA

Postby kaiser » Mon Oct 22, 2018 9:06 pm

cayleystark wrote:
kaiser wrote:
cayleystark wrote:Thanks so much for this! Currently a 3L interested in labor and employment- what's your work-life balance like? Did you go straight in to L&E or did you start out as a generalist and then specialize? Did you start at your firm as a summer or transfer in? Thanks!


My work-life balance is fairly good by biglaw standards. That's partly because my firm has a slightly lower billable hours requirement compared to other firms. It's also partly because my particular group is pretty humane and empathetic when it comes to respecting work-life issues. Though you definitely need to keep that in perspective. My non-lawyer friends would laugh pretty hard if I ever told them I have fairly good work-life balance. I usually stay late 1 or 2 nights per week depending on workflow. If its a busy week when multiple briefs are due, I may be there late every night. But I balance that out with true vacations where I can relax and essentially never get bothered with work. Part of that is because I hold my ground pretty clearly in setting those limitations and making it clear to partners and peers that I have no intention of working during my vacation unless its an emergency.

I started out as a generalist but not by choice. I wanted to do L&E from the very beginning, back when I was in law school. I went to a firm that had L&E but ended up being placed into general lit. I had no interest in general lit because my interest is much more the substance than the procedure. After about 1.5 years in general lit at my first firm, I made a a lateral move to break into L&E and have been doing it ever since.


Thanks! Do you know what the prospects are if you ever leave the firm? Obviously litigation is harder to transfer in-house but from looking I've seen a reasonable amount of L&E in-house postings. Do you have any suggestions for someone not starting out in big law but might like to have the option to get into a biglaw L&E group at some point?


L&E has some of the best exit options of any group in biglaw. Its one of the many things that drew me to L&E in the first place (though more as an added benefit than anything else). You have to keep in mind that L&E, although it usually falls within the "litigation" umbrella, is not a purely litigation group. L&E work is divided into both litigation and counseling. Yes, we handle disputes when things go south. This can involve discrimination charges with administrative agencies, unfair labor practice charges with the National Labor Relations Board, wage & hour cases under the FLSA, etc.

But a huge part of the practice is proactively working with employers on various issues. For example, we may help a client develop a new vacation policy in light of constantly-changing state laws, or we may draft employment agreements or employee handbooks. That kind of work distinguishes L&E from other litigation groups, and provides L&E associates with a very valuable skillset that really lends itself to in-house work in essentially any industry. Of course, in-house is just one option. L&E attorneys can also work for government agencies like the DOL, NLRB, EEOC, state division of human rights, etc. So the exit options are very strong.

As for the last question, its really two separate issues. Starting in non-biglaw and transitioning into biglaw is a topic worthy of its own thread, and not something I really have experience in. So I can't really comment on how difficult that may be or what it would entail. Though I can comment on the second issue, which is breaking into L&E having started in something else. The key is not waiting too long or else the substantive gap builds up. Sure, its fine for a 1st or 2nd year litigation associate to make the jump since they can catch up on the substance fairly easy (and since the first year is really more about procedure than substance anyway). But a 5th year associate can't be learning the basics of L&E for the very first time. It just wouldn't work.

adil91

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Re: Biglaw L&E Midlevel Associate in NYC - AMA

Postby adil91 » Mon Oct 22, 2018 9:11 pm

kaiser wrote:
cayleystark wrote:
kaiser wrote:
cayleystark wrote:Thanks so much for this! Currently a 3L interested in labor and employment- what's your work-life balance like? Did you go straight in to L&E or did you start out as a generalist and then specialize? Did you start at your firm as a summer or transfer in? Thanks!


My work-life balance is fairly good by biglaw standards. That's partly because my firm has a slightly lower billable hours requirement compared to other firms. It's also partly because my particular group is pretty humane and empathetic when it comes to respecting work-life issues. Though you definitely need to keep that in perspective. My non-lawyer friends would laugh pretty hard if I ever told them I have fairly good work-life balance. I usually stay late 1 or 2 nights per week depending on workflow. If its a busy week when multiple briefs are due, I may be there late every night. But I balance that out with true vacations where I can relax and essentially never get bothered with work. Part of that is because I hold my ground pretty clearly in setting those limitations and making it clear to partners and peers that I have no intention of working during my vacation unless its an emergency.

I started out as a generalist but not by choice. I wanted to do L&E from the very beginning, back when I was in law school. I went to a firm that had L&E but ended up being placed into general lit. I had no interest in general lit because my interest is much more the substance than the procedure. After about 1.5 years in general lit at my first firm, I made a a lateral move to break into L&E and have been doing it ever since.


Thanks! Do you know what the prospects are if you ever leave the firm? Obviously litigation is harder to transfer in-house but from looking I've seen a reasonable amount of L&E in-house postings. Do you have any suggestions for someone not starting out in big law but might like to have the option to get into a biglaw L&E group at some point?


L&E has some of the best exit options of any group in biglaw. Its one of the many things that drew me to L&E in the first place (though more as an added benefit than anything else). You have to keep in mind that L&E, although it usually falls within the "litigation" umbrella, is not a purely litigation group. L&E work is divided into both litigation and counseling. Yes, we handle disputes when things go south. This can involve discrimination charges with administrative agencies, unfair labor practice charges with the National Labor Relations Board, wage & hour cases under the FLSA, etc.

But a huge part of the practice is proactively working with employers on various issues. For example, we may help a client develop a new vacation policy in light of constantly-changing state laws, or we may draft employment agreements or employee handbooks. That kind of work distinguishes L&E from other litigation groups, and provides L&E associates with a very valuable skillset that really lends itself to in-house work in essentially any industry. Of course, in-house is just one option. L&E attorneys can also work for government agencies like the DOL, NLRB, EEOC, state division of human rights, etc. So the exit options are very strong.

As for the last question, its really two separate issues. Starting in non-biglaw and transitioning into biglaw is a topic worthy of its own thread, and not something I really have experience in. So I can't really comment on how difficult that may be or what it would entail. Though I can comment on the second issue, which is breaking into L&E having started in something else. The key is not waiting too long or else the substantive gap builds up. Sure, its fine for a 1st or 2nd year litigation associate to make the jump since they can catch up on the substance fairly easy (and since the first year is really more about procedure than substance anyway). But a 5th year associate can't be learning the basics of L&E for the very first time. It just wouldn't work.


Are there any laterals from government agencies at your firm?

How much do you make?

kaiser

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Re: Biglaw L&E Midlevel Associate in NYC - AMA

Postby kaiser » Mon Oct 22, 2018 9:15 pm

adil91 wrote:
kaiser wrote:
cayleystark wrote:
kaiser wrote:
cayleystark wrote:Thanks so much for this! Currently a 3L interested in labor and employment- what's your work-life balance like? Did you go straight in to L&E or did you start out as a generalist and then specialize? Did you start at your firm as a summer or transfer in? Thanks!


My work-life balance is fairly good by biglaw standards. That's partly because my firm has a slightly lower billable hours requirement compared to other firms. It's also partly because my particular group is pretty humane and empathetic when it comes to respecting work-life issues. Though you definitely need to keep that in perspective. My non-lawyer friends would laugh pretty hard if I ever told them I have fairly good work-life balance. I usually stay late 1 or 2 nights per week depending on workflow. If its a busy week when multiple briefs are due, I may be there late every night. But I balance that out with true vacations where I can relax and essentially never get bothered with work. Part of that is because I hold my ground pretty clearly in setting those limitations and making it clear to partners and peers that I have no intention of working during my vacation unless its an emergency.

I started out as a generalist but not by choice. I wanted to do L&E from the very beginning, back when I was in law school. I went to a firm that had L&E but ended up being placed into general lit. I had no interest in general lit because my interest is much more the substance than the procedure. After about 1.5 years in general lit at my first firm, I made a a lateral move to break into L&E and have been doing it ever since.


Thanks! Do you know what the prospects are if you ever leave the firm? Obviously litigation is harder to transfer in-house but from looking I've seen a reasonable amount of L&E in-house postings. Do you have any suggestions for someone not starting out in big law but might like to have the option to get into a biglaw L&E group at some point?


L&E has some of the best exit options of any group in biglaw. Its one of the many things that drew me to L&E in the first place (though more as an added benefit than anything else). You have to keep in mind that L&E, although it usually falls within the "litigation" umbrella, is not a purely litigation group. L&E work is divided into both litigation and counseling. Yes, we handle disputes when things go south. This can involve discrimination charges with administrative agencies, unfair labor practice charges with the National Labor Relations Board, wage & hour cases under the FLSA, etc.

But a huge part of the practice is proactively working with employers on various issues. For example, we may help a client develop a new vacation policy in light of constantly-changing state laws, or we may draft employment agreements or employee handbooks. That kind of work distinguishes L&E from other litigation groups, and provides L&E associates with a very valuable skillset that really lends itself to in-house work in essentially any industry. Of course, in-house is just one option. L&E attorneys can also work for government agencies like the DOL, NLRB, EEOC, state division of human rights, etc. So the exit options are very strong.

As for the last question, its really two separate issues. Starting in non-biglaw and transitioning into biglaw is a topic worthy of its own thread, and not something I really have experience in. So I can't really comment on how difficult that may be or what it would entail. Though I can comment on the second issue, which is breaking into L&E having started in something else. The key is not waiting too long or else the substantive gap builds up. Sure, its fine for a 1st or 2nd year litigation associate to make the jump since they can catch up on the substance fairly easy (and since the first year is really more about procedure than substance anyway). But a 5th year associate can't be learning the basics of L&E for the very first time. It just wouldn't work.


Do you work at an L&E specialist firm like Littler?

How much do you make?


I work for a full-service firm that has an L&E group, not an L&E-specialized firm. I make slightly below market since my firm doesn't quite follow the market scale for all years. Though I'm certainly happy with my comp, and given how much I like being here, I wouldn't leave even in it meant a fairly substantial pay bump at a comparable firm. I have enough friends who were making 30 or 40k more than me who were absolutely miserable to know that I"m in a good place and need only look at things objectively.

kaiser

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Re: Biglaw L&E Midlevel Associate in NYC - AMA

Postby kaiser » Mon Oct 22, 2018 9:20 pm

adil91 wrote:
kaiser wrote:
cayleystark wrote:
kaiser wrote:
cayleystark wrote:Thanks so much for this! Currently a 3L interested in labor and employment- what's your work-life balance like? Did you go straight in to L&E or did you start out as a generalist and then specialize? Did you start at your firm as a summer or transfer in? Thanks!


My work-life balance is fairly good by biglaw standards. That's partly because my firm has a slightly lower billable hours requirement compared to other firms. It's also partly because my particular group is pretty humane and empathetic when it comes to respecting work-life issues. Though you definitely need to keep that in perspective. My non-lawyer friends would laugh pretty hard if I ever told them I have fairly good work-life balance. I usually stay late 1 or 2 nights per week depending on workflow. If its a busy week when multiple briefs are due, I may be there late every night. But I balance that out with true vacations where I can relax and essentially never get bothered with work. Part of that is because I hold my ground pretty clearly in setting those limitations and making it clear to partners and peers that I have no intention of working during my vacation unless its an emergency.

I started out as a generalist but not by choice. I wanted to do L&E from the very beginning, back when I was in law school. I went to a firm that had L&E but ended up being placed into general lit. I had no interest in general lit because my interest is much more the substance than the procedure. After about 1.5 years in general lit at my first firm, I made a a lateral move to break into L&E and have been doing it ever since.


Thanks! Do you know what the prospects are if you ever leave the firm? Obviously litigation is harder to transfer in-house but from looking I've seen a reasonable amount of L&E in-house postings. Do you have any suggestions for someone not starting out in big law but might like to have the option to get into a biglaw L&E group at some point?


L&E has some of the best exit options of any group in biglaw. Its one of the many things that drew me to L&E in the first place (though more as an added benefit than anything else). You have to keep in mind that L&E, although it usually falls within the "litigation" umbrella, is not a purely litigation group. L&E work is divided into both litigation and counseling. Yes, we handle disputes when things go south. This can involve discrimination charges with administrative agencies, unfair labor practice charges with the National Labor Relations Board, wage & hour cases under the FLSA, etc.

But a huge part of the practice is proactively working with employers on various issues. For example, we may help a client develop a new vacation policy in light of constantly-changing state laws, or we may draft employment agreements or employee handbooks. That kind of work distinguishes L&E from other litigation groups, and provides L&E associates with a very valuable skillset that really lends itself to in-house work in essentially any industry. Of course, in-house is just one option. L&E attorneys can also work for government agencies like the DOL, NLRB, EEOC, state division of human rights, etc. So the exit options are very strong.

As for the last question, its really two separate issues. Starting in non-biglaw and transitioning into biglaw is a topic worthy of its own thread, and not something I really have experience in. So I can't really comment on how difficult that may be or what it would entail. Though I can comment on the second issue, which is breaking into L&E having started in something else. The key is not waiting too long or else the substantive gap builds up. Sure, its fine for a 1st or 2nd year litigation associate to make the jump since they can catch up on the substance fairly easy (and since the first year is really more about procedure than substance anyway). But a 5th year associate can't be learning the basics of L&E for the very first time. It just wouldn't work.


Are there any laterals from government agencies at your firm?

How much do you make?


Most of the laterals at my firm came from other firms. But I know of one person who came from the government side, and had many years of invaluable litigation experience.

km0ney

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Re: Biglaw L&E Midlevel Associate in NYC - AMA

Postby km0ney » Thu Oct 25, 2018 12:26 pm

Thanks for this.

What would you say are the most important qualities of becoming a successful LE litigator? I’ve heard things like strong writing, communication skills, knowledge of the LE law, outgoing, etc.

As a junior associate at a general lit mid size firm, I’m seeking to lateral to a LE firm in 2-3 years (hopefully). What should I do to start gaining experience that’ll boost my marketability? I’m considering taking on pro bono cases to get a shot at doing depositions, drafting my own motions, etc., since I don’t expect to get that type of experience in 2 years at my firm.

How do you go about finding your own clients/book of business? I’m not good at networking—not yet at least. Has that been a problem for you? Does your firm expect it?

Are you looking to become partner? What’s in the future for you in the next 3-5 years?

kaiser

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Re: Biglaw L&E Midlevel Associate in NYC - AMA

Postby kaiser » Fri Oct 26, 2018 11:27 pm

km0ney wrote:Thanks for this.

What would you say are the most important qualities of becoming a successful LE litigator? I’ve heard things like strong writing, communication skills, knowledge of the LE law, outgoing, etc.

As a junior associate at a general lit mid size firm, I’m seeking to lateral to a LE firm in 2-3 years (hopefully). What should I do to start gaining experience that’ll boost my marketability? I’m considering taking on pro bono cases to get a shot at doing depositions, drafting my own motions, etc., since I don’t expect to get that type of experience in 2 years at my firm.

How do you go about finding your own clients/book of business? I’m not good at networking—not yet at least. Has that been a problem for you? Does your firm expect it?

Are you looking to become partner? What’s in the future for you in the next 3-5 years?


The most important qualities to being a successful L&E litigator aren't really all that different compared to other kinds of litigation. The most successful litigators tend to be extremely well-organized and have efficient habits for staying on top of things and keeping everything in order. Of course, excellent writing skills are a must if you want to be a successful litigator. Oral advocacy and communication skills are important, but it is secondary to writing. The most successful litigators are very detail-oriented and relish the nitty-gritty, since thats so often the difference between winning and losing. As far as substance, L&E is sort of like chess. Easy to learn the basics, but very hard to master the nuances. Those with the detail-oriented mind to really understand the nuances are highly valued.

If you are interested in possibly making a lateral move to break into L&E, the best thing you can do is make the move quickly, before the substantive gap builds up. But while you are at your current firm, continue building up your procedural knowledge, and practical skills, as you mentioned. If you have experience writing briefs, handling discovery requests, attending hearings, conducting depositions, etc., it can only help you. Another good idea is to stay current on recent L&E developments, as this area of law changes very often. If you can legitimately speak to current L&E issues at your interview, it will show how committed you are to going that route. Finally, see if your firm partners with any pro bono organizations that specifically have L&E or discrimination matters available. For example, maybe you can get involved in a housing discrimination case. Sure, its not L&E but there is quite a bit of applicable cross-over.

I'm admittedly still green in the world of business development. And as a 5th year in biglaw, I'm still in the stage where its not really expected of me. Though the opportunities are certainly there and my firm backs me every step of the way through my attempts. Networking is not my thing because I am very introverted. I do not like schmoozing one bit because its so artificial. But where interactions are genuine and organic, the trick is to find reasons to stay in touch. Keep the business cards you get, offer to meet folks over coffee, learn a bit about what they do. And you never know when that may turn into something. And its not a problem if it simply doesn't happen. Will you become a partner without a book of business? No. But that doesn't mean there aren't great opportunities available to the folks who, despite not having much business, are simply excellent lawyers.

I am not looking to become a partner. Becoming a partner requires that you have a large book of business that is of value to the firm. And it also requires that you navigate the political aspect. That means maintaining the right relationships, knowing the right people, etc. Again, I'm more the introverted type who likes to just keep my head down and do great work for the clients. I don't like schmoozing and I don't play the firm politics games. And that combination would likely take me out of the running for certain things. Though I'm fine with that. My firm is great and its certainly possible I could stay with them long-term, perhaps in an of counsel role. Or its possible I may transition to an in-house role, since L&E lends itself toward in-house work. I've got an open mind at this point, and am just seeing where things take me.

km0ney

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Re: Biglaw L&E Midlevel Associate in NYC - AMA

Postby km0ney » Mon Oct 29, 2018 1:35 pm

Appreciate the thorough response(s).

As a bit of a introvert myself, how do you deal with networking? Some attorneys tell me it's not necessary to be good at networking and let my work product speak for itself. Still, speaking at relevant LE conferences or attending the local LE association bar nights or whatever seem beneficial.

What did you mean that it's hard to get the nuances of LE? Pardon my ignorance, of course. Or, in other words, I personally don't see it any more nuanced than other areas of law. Appreciate some elaboration.

How often is your time spent counseling/responding to emails & phone calls? What's your typical day like?

kaiser

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Re: Biglaw L&E Midlevel Associate in NYC - AMA

Postby kaiser » Mon Nov 12, 2018 7:16 pm

km0ney wrote:Appreciate the thorough response(s).

As a bit of a introvert myself, how do you deal with networking? Some attorneys tell me it's not necessary to be good at networking and let my work product speak for itself. Still, speaking at relevant LE conferences or attending the local LE association bar nights or whatever seem beneficial.

What did you mean that it's hard to get the nuances of LE? Pardon my ignorance, of course. Or, in other words, I personally don't see it any more nuanced than other areas of law. Appreciate some elaboration.

How often is your time spent counseling/responding to emails & phone calls? What's your typical day like?


I'm also an introvert, and schmoozing and networking certainly isn't my element. I try and do it to get out of my comfort zone, and a just dipping your toes in can make you much more comfortable. In the first few years, networking and biz development is somewhat secondary because at that stage, you are simply gaining basic skills and learning how to do the work. Without that foundation, biz development doesn't really matter anyway. So yes, work product and performance always comes first. But as you move up in associate years, you will want to start building your network and getting your name out there. As you mentioned, speaking at conferences, attending networking events, lunches, etc. can all be great avenues for making contacts. Be sure to speak with the partners you see as mentors and they can point you in the right direction. Partners love to hear that associates are interested in and understand the business aspect of law firm practice, and would likely be happy to help you out.

As to the second question, what I meant to convey was that the basics of L&E are deceptively simple. Pretty much anyone can understand the basics of employment law fairly quickly, with minimal learning curve. And in that sense, it is more accessible and simpler at the front end compared to other areas of law, where the initial learning curve is much steeper. But the counterpart to that is the heavy amount of nuance once you get beneath the surface. That is not to say that other areas of the law are any less nuanced or complex once you dig deep enough. Rather, its that the differential between the basics and the high-level nuances is larger in L&E than in pretty much any other group. I compare L&E to chess, in that its easy to learn, but extremely hard to master. Whereas I wouldn't compare something like tax law or securities litigation to chess since even the basics are largely inaccessible to the majority of folks.

As a mid-level associate, about 1/3 of my time is spent on counseling, with the other 2/3 spent on litigation matters. But it really varies, and its that variety that really defines the practice. I am often drafting briefs, trying to negotiate settlements, attending hearings, strategizing with clients, etc. I have client calls essentially every day at some point, most related to litigations, but a number involve counseling issues. Many of the counseling issues are spur-of-the-moment since its often helping deal with a crisis or something unexpected. For example, an unexpected strike is occurring and the employer needs to know what their rights are. Or an employer is looking to onboard a new employee and needs some advice in structuring the employment agreement. It really could be anything, and you are always on your toes. Because of the variety, my days usually fly by, and no two days are precisely the same.

chickenb00b

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Re: Biglaw L&E Midlevel Associate in NYC - AMA

Postby chickenb00b » Mon Nov 19, 2018 9:17 pm

This thread has been helpful. Thank you.

kaiser

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Re: Biglaw L&E Midlevel Associate in NYC - AMA

Postby kaiser » Fri Nov 23, 2018 6:32 pm

chickenb00b wrote:This thread has been helpful. Thank you.


No problem. If anyone else has questions, I am happy to answer.



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