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Almost 30 years ago when I began my career consulting to law firms, the then managing partner of Donovan Leisure Newton & Irving used that term to refer to the months of October through December. It was his way of pointing out to his fellow partners that the necessary activities of practice management that so many of them had avoided for the first nine or 10 months of the year now had to be addressed. Clients that had not been billed as frequently as firm policy required now had to be invoiced. Outstanding invoices, many issued in the cold days of early March and April, now had to be collected and current work would not only have to be billed but collected as well.
Donovan was one of those old New York "White Shoe" firms that regrettably did not survive into the new century, but one where I first encountered afternoon tea time ("iced, two sugars and a mall-o-mar please") and where I learned the craft of consulting and therefore will always have a special place in my memory.
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The DOJ's Criminal Division issued three declinations since the issuance of the revised CEP a year ago. Review of these cases gives insight into DOJ's implementation of the new policy in practice.
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