During the July 4, 2008 naturalization ceremony at Monticello, protesters disrupted President George W. Bush’s address to the crowd of brand new U.S. citizens, guests, and visitors. During President Obama’s September 9, 2009 address to a joint session of Congress, U.S. Representative Joe Wilson yelled “You lie” in response to one of the President’s comments. In late summer 2009, town hall meetings across the country organized by elected representatives to discuss health care reform reportedly became shouting matches between those holding different views.
The United States Department of Justice will offer two presentations on the agency's volunteer legal intern recruitment. On Friday, November 13, at noon, in WB152, Jennifer Rivera '88, Director of Federal Programs, will discuss hiring in the Civil Division. Next week, November 16, at 2:00pm, in WB152, Criminal Division's Jonathan Rusch ('80), Deputy Chief for Strategy and Policy, Fraud Section, and Julie Zebrack, Acting Deputy Executive Office of Human Resources, will discuss the division's work and expected hiring for next summer. Please join us with your questions.
The Raven Society funds several fellowship awards of up to $2500 each every year for undergraduate and graduate research projects at the University of Virginia. Last year, the Raven Society funded a diverse set of projects that studied Native American sovereignty in Montana, monastic rituals in India, Rajasthani painting in India, children's perspectives in design in Denmark, and genocide and ethnic cleansing in Bosnia.
The Public Service Center and Virginia Law Veterans will be hosting an information session on Judge Advocate General's JAG Corps' on Monday, November 9, at 11:45am in WB128. Representatives from the U.S. Army, Air Force, Coast Guard, Marine Corps, and Navy will speak about careers as military lawyers and the application processes for summer internships and permanent positions with the various JAG Corps. All classes are welcome. As a reminder, we have also included a list of application deadlines for the various Corps: JAG Corps Deadlines.
Partnership for Public Service recently posted a list of occupational areas and positions for attorneys and projected federal government hiring on its site here. Information for individual agency hiring is listed here.
The Washington
Post reported in September 2009 that the federal government needs to hire more than
270,000 workers for "mission critical" jobs by the fall of 2012 and almost 600,000 for all
positions in the next three years. Of these, 23, 596 are legal jobs.
On Monday, October 19 at 7:00 pm, the Legal Aid Justice Center will show a screening of Jail, an installment of Morgan Spurlock's documentary series, 30 Days, and a panel discussion about prison reform. The event will be hosted by author John Grisham and other special guests including David Fathi, Director of Human Rights Watch (U.S. program) and Senator Jim Webb (D-VA) (invited).
The Albemarle County Attorney's Office is seeking a part-time law clerk for the 2009-2010 school year. The law clerk will research complex and timely issues in education and local government law and may have an opportunity to gain experience in other areas based upon the law clerk's interest and availability. The application deadline is October 30, 2009.
The Richmond Pro Bono Fellowship is a two-year program during which Fellows represent clients at the firm's own Church Hill neighborhood pro bono offices as well as at the Central Virginia Legal Aid Society (CVLAS) in Richmond. Approximately 25-30% of the Fellow's time will be devoted to Church Hill clients and 70-75% devoted to CVLAS clients.
Please join us for a brownbag presentation with attorneys from the CIA Office of General Counsel on Monday, September 21, 2009, at 12:00, in WB105. The Office of the General Counsel (OGC) handles legal issues relating to foreign intelligence and counterintelligence activities, international terrorism, international narcotics trafficking, nonproliferation, personnel and security matters, contracting, finance and budget matters, legislation, and both civil and criminal litigation. The OGC attorneys will discuss the work of the office, its legal honors program (for 3Ls and judicial law clerks) and summer law clerk program (2Ls). All classes are welcome.
Equal Justice Works (EJW) is a Washington, D.C.-based nonprofit organization that focuses on public interest careers for lawyers. Every year, in October, the organization hosts a conference and career fair in Washington that brings together the largest gathering of public interest and government employers to recruit second- and third-year law students (and recent graduates) for internship and permanent positions. The conference also features conference programing sessions that offer, among other things, advice on opportunities outside the classroom that students can pursue to prepare for a career in public interest law. This year's event will take place on October 24 and 25 at the Omni Shoreham Hotel.
Education Pioneers is a national nonprofit that tackles the most critical public education challenges by recruiting business, law, education and policy professionals and matching them with partner organizations. These partners include, among others, charter schools, research organizations, college preparatory programs, and legal services and advocacy programs.
Please join the Mortimer Caplin Public Service Center for a brownbag presentation with Tom Wornom ('83) from the New York County District Attorney's Office on Friday, September 25, 2009, at noon, in SL294.
The New York County District Attorney's Office is one of the premier prosecutors' offices in the United States. The unparalleled opportunities for challenging and sophisticated work have consistently drawn top law students and attorneys to the office over the years. The office has a well-established Summer Intern Program, which affords first and second year law students the opportunity to see first-hand the responsibilities of an Assistant District Attorney.
The Fried Frank Fellowship Program is a collaboration between the law firm Fried, Frank, Harris, Shriver & Jaconson and the public interest organizations Mexican American Legal Defense and Education Fund (MALDEF) and NAACP Legal Defense and Education Fund (LDF). The Fellowship is a four-year program where fellows spend their first two years as an associate in Fried Frank's litigation department and the following two years as staff attorneys at MALDEF or LDF.
Do you have a bold idea to solve a major problem in the world? If so, consider applying for an Echoing Green Fellowship to receive up to $90,000 in seed funding, leadership training, and organizational technical assistance. Apply by December 2, 2009 to make a difference.
The White House Internship Program accepts students and recent graduates (two years or less since graduation) to work in one of many presidential departments during the fall, spring or summer. Interns serve the White House in such functions as researching, managing incoming inquiries, attending meetings, and writing memos. Projects vary among the departments but all interns participate in a long term community service project and attend a weekly speaker series presented by senior staff members. In addition, interns take field trips around the Washington D.C. area.
On September 9, 2009 at 1:00 pm, The Association of Pro Bono Counsel and NALP will offer a two-hour online training session designed for attorneys beginning volunteer public interest placements. The training session will contain an overview of the differences in law firm and nonprofit practice settings, insight on working with low-income clients, and background on the economic challenges presently being confronted by the public interest community. Presentations will be made by public interest leaders from the legal aid community and the private bar. Immediately following the training session, a discussion on issues relevant to fellowships will take place.
Through the ASPIRE program, 2009 graduates who are currently working in the public interest can receive free LexisNexis access for the coming year. Among those eligible are deferred associates pursuing public interest work during their deferrals. Some important rules include: (1) while work for a nonprofit or charitable organization is eligible, government work is not; (2) access ends September 2010 or when your public service employment ends; (3) you must submit documentation from your employer confirming your eligibility.
Eligible applicants who are currently working will receive free access to federal and state cases, codes, regulations, and law reviews within two days of submitting documentation. To apply, please visit Lexis's attorney deferral page here.
The Osborne Fellowship is a two-year commitment during which fellows represent indigent defendants facing the death penalty. The fellowship is granted by Fair Trial Initiative, a Durham, North Carolina organization that seeks to fill the resource gap in competent counsel for capital cases and to encourage talented lawyers to join this area of practice, one that is often overlooked.
The PMF Program is a prestigious federal government fellowship sponsored by the Office of Personnel Management (OPM) for graduate students from various academic
disciplines who expect to graduate during in the 2009-2010 academic year and who seek a two-year paid fellowship with one or more federal government agencies. The application period will open on October 1 and ends on October 15, 2009. See program and application overview here.
More than 80 federal agencies currently partner with the PMF Program to hire fellows who have an interest in, and commitment to, excellence in the leadership and management of public policies and programs.
The Powell Fellowship in Legal Services honors former Supreme Court Justice Lewis F. Powell Jr., and awards $35,000 to a graduating student of the University of Virginia School of Law (or to a judicial clerk). Open only to third-year law students at Virginia Law or recent Virginia graduates who will complete a judicial clerkship by fall 2010, the fellowship enables applicants to work in public interest law and to enhance the delivery of legal services to no- or low income persons under the sponsorship of a public interest organization.
The award is made for one year, with the expectation that it will be renewed for a second year. In addition to the salary, fellows receive health and other benefits that an employee of his or her sponsoring organization would ordinarily receive.
Registration for the 2009 Conference and Career Fair is now open. (Seehere for a previous posting on this important event). Students and recent graduates interested in attending may sign up for a Symplicity account and submit their cover letter and resume beginning today, Monday, August 31.
The Public Service Center requests that all second- and third-year students
who worked for public service and public interest organizations (including
state and federal government agencies) complete a Public Service Summer
Survey. The surveys are critical
for students looking for summer and permanent positions in the public
interest. We ask all students who interned for a Public Service employer
last summer fill out a survey, even if it was only for part of the summer.
A 10-minute preview of a 75-minute video presented by NALP/ALI-ABA that offers advice on how to navigate your job search in today's economy. The full video is available here.
Students interested in
learning about career paths at the DOJ and DHS are highly encouraged to attend an upcoming presentation on August 24, at noon, in WB101. The DOJ's Director of Federal Programs, Civil Division, Jennifer Rivera ('88), and DHS Special Assistant Ron Rosenberg ('98), Special Assistant, Office of Refugee, Asylum & International Operations will discuss hiring programs for entry-level attorneys at their respective agencies.
Home to some of the grittiest public defenders in the country, the Public Defender Service for the District of Columbia
receives hundreds of applications for a handful of available attorney
positions each year. To many, PDS has become the national
standard-bearer and the benchmark by which other public defender
systems measure themselves.
As advocates for indigent
individuals, PDS attorneys handle criminal appeals, parole revocation
hearings, Drug Court sanction hearings, and represent individuals
facing involuntary commitment in the mental health system, children
with special education needs facing delinquency charges, and clients in
civil proceedings that were triggered by their criminal charges or
their incarceration.
The Equal Justice Works AmeriCorps Program is an 11-month fellowship in which fellows work to increase the availability of pro bono legal services to low income persons. Fellows work nationwide in areas such as health care, public benefits, affordable housing, lost wages, protection orders, and education. AmeriCorps fellows gain experience in both pro bono management and provision of legal services.
During their terms, fellows recruit 100 or more volunteer law students and lawyers, increasing their impact. ILast year's 35 Equal Justice Works AmeriCorps Fellows represented a total of 17,200 clients.
The General Counsel is the chief legal advisor to the Secretary and the chief legal officer for the Department of Homeland Security. Attorneys from the Office of the General Counsel and its major components play major roles in crafting, developing, and defending policies relating to many of the most important issues facing the nation today, including counterterrorism, immigration and border security, emergency response and recovery, and countless other matters.
The FCIP allows individuals in various disciplines to obtain a
two-year, full-time internship with a number of federal government
agencies.It was created by executive
order for the purpose of recruitinggraduates with diverse professional and academic experiences and to
create opportunities to develop their skills for a career in the federal
government.
Unlike the Presidential Management Fellows Program which is centrally managed by the Office of Personnel Management (OPM), the FCIP order requires each
participating agency to establish its own training and development program for a minimum of two years.Extended programs
can last up to three years, but these are the minority. The FCIP is designed to hire interns at the
GS-5 ($33,269 to $43,251), 7 ($41,210 to $53,574), or 9 ($48,108 to $65,531)
levels and there is no limit to promotion level.
Because the intern programs are run
individually by the participating agencies, application deadlines and hiring
frequency vary.Many, but not all,
agencies post FCIP positions on USAJobs as they become available (search
keywords "FCIP" and "CIP;" you should also register with USAJobs to receive e-mail alerts). Frequently, agencies list
positions on their websites, so it is necessary to research individual
agencies in which you are interested (search for the agency name plus "FCIP"). The only centralized resource were were able to find online was on Making the Difference (download the Excel document).
Finally, please note that agencies change the
availability of FCIP positions from year to year.For example, the Departments of Justice and Commerce, and Bureau of Land Management have all hired through
the FCIP in the past, but it is unclear whether they will do so in the upcoming
year.
The Peggy Browning Fund will host it's eleventh annual National Law Students Workers' Rights Conference on October 16 and 17, in Washington D.C.
The aim of the conference is to create greater understanding of, appreciation for, and interest in, the issues facing American workers and to provide law students with opportunities for networking with fellow law students, top labor lawyers, professors, nonprofit practitioners, and government officials.
For more information about the conference, please see the Fund's brochure.
The conference is available to all Virginia Law students but space is limited and applicants will be taken on a first-come, first-served basis. Also, due to limited funds, students are responsible for the conference fees listed in the brochure.
To register for the conference please complete the registration form and return it with payment for the associated conference fees to the Public Service Center no later than Friday, August 21, 2009.
This posting is an addendum to our July 1, 2009 memorandum re: federal government honors programs.
Google has created a search engine for those seeking federal government jobs. The site is available at http://www.google.com/unclesam.
Once you get there, a keyword search by "Attorney Honors Programs" (without quotes) will reveal a significant number of entry-level honors programs for attorneys across a wide range of federal agencies. This is an invaluable resource that we hope you will take advantage of.
Did you know that the third year practice certificate allows students to appear in court (and before administrative tribunals) in the Commonwealth of Virginia and in other jurisdictions? A practice certificate allows you to engage in substantial legal work while in law school and is highly recommended if you are interested in pursuing a career in litigation in both the public and private sectors.
To be eligible, in addition to being a 3L (you must have completed at least four semesters in law school and passed Civil Procedure and Criminal Law), you only need to have completed two electives: Evidence and Professional Responsibility.
Under the rules of the Supreme Court of Virginia:
(i) An eligible law student may, in the presence of a supervising lawyer, appear in any court or before any administrative tribunal in this Commonwealth in any civil, criminal or administrative matter on behalf of any person if the person on whose behalf he is appearing has indicated in writing his consent to that appearance. The eligible law student must obtain written approval from the court or administrative tribunal prior to any appearance before the court or administrative tribunal.
For more information about third year practice certificates, please contact the Student Record's Office.
Described as "a legal Peace Corps" by the Los Angeles Times,
the Skadden Fellowship Program was established by the law firm Skadden,
Arps, Slate, Meagher Flom in 1988 in recognition of the need for
greater funding for graduating law students who wish to devote their
professional lives to providing legal services to the poor, the elderly, the homeless and the disabled, as well
as those deprived of their civil or human rights. The aim of the
foundation is to give Fellows the freedom to pursue public interest
work; thus, the Fellows create their own projects at public interest
organizations with at least two lawyers on staff.
A civil rights attorney in Northern Virginia is seeking students to assist him with a case involving the alleged abuse of a female prisoner. The student volunteers would conduct interviews with inmates at the Fluvanna Correctional Center for Women and help with legal research.
Interested students must have access to a car.
The completion date for this project is Sept. 15, 2009
To Apply: Interested students should submit a resume to lawprobono@virginia.edu by Monday, July 13, 2009, by 5:00pm.
All the Lifestyle that Legal Aid Wages Can Buy CARYN TAMBER The Daily Record (MD), June 5, 2009
The Daily Record writes:
When Janine A. Scott started at the [LSC-funded] Legal Aid Bureau more than 10 years ago, her salary was $28,000 a year. She soon discovered that she loved the work, but the money was a sticking point. How could she have the kind of life she wanted on such a paltry salary? 'I wanted to stay, and so I became motivated to make the salary work within what my expenses are,' said Scott, 38, who is now the supervising attorney for the domestic law unit at Legal Aid. Scott, who briefly worked as an accountant before going to law school, sat down and made a list of all of her financial goals. There were a lot of them: She wanted to pay down her law school and credit card debt, buy a house and travel once a year . . . . She looked at her going-out spending habits and determined that she should create a 'fun account' and keep it at $250 at all times . . . . Scott said she has achieved her goals by meticulously charting every bit of money that comes in and goes out. She waits for sales on clothing and discount deals on travel, and she would not dream of buying snacks from a vending machine when she could get them in bulk from Target or Wal-Mart for so much less...
To learn more about Scott and her book, visit her website.
On July 1, 2009, the College Cost Reduction and Access Act (CCRAA) became fully effective making Income-Based Repayment available for borrowers. Graduates working full-time in
government and nonprofit positions are eligible to earn Public Service Loan
Forgiveness. Students interest in learning about public service loan forgiveness or income-based repayment are encouraged to check Equal Justice Works' Student Debt Relief page here. Additional information on the Act is also available on EJW's blog.
The Partnership for Public Service will host its annual Public Service Career and Internship Fair on July 16 from 3:00-7:00pm at the National Building Museum in Washington, D.C.
Last year's event connected 67 federal agencies with 3,000 students and young professionals. This year, agencies will be recruiting for a variety of positions including program analysts, Foreign Service Offices, federal investigators, and attorney, as well as for internships and fellowships.
The Equal Justice Works Conference and Career Fair is the largest annual gathering of public interest and government employers in the nation and will be held this year on Saturday and Sunday October 24 and 25 in Washington, D.C., at the Omni Shoreham Hotel.
Over 150 public service/interest employers will be available to
conduct prescheduled interviews for hundreds of internship and permanent positions throughout
the country.
The conference will provide a venue where
participants can learn about various careers in the public interest. The Table Talk sessions provide an informal opportunity for law students to introduce themselves to participating employers and possibly to conduct impromptu interviews. For additional information about the conference and career fair, please see
the 2008 program book, conference sessions, and a list of past
employers here.
The registration fee for attendees is covered by the annual membership that the Mortimer Caplin Public Service Center maintains. However, students are responsible for travel and lodging costs.
The National Black Prosecutors Association (NBPA) will hold its annual Job Fair on Tuesday, July 21, 2009 at the Marriot Memphis Downtown in Memphis, Tennessee. The goal of the NBPA Job Fair is to promote diversity in prosecutor offices by providing a forum where law students, recent law graduates, and experienced attorneys from across the nation can meet and interview with prospective prosecutorial employers at the local, state, and federal levels.
We participated in one of EJW's webinars on the College Cost Reduction & Access Act's Public Service Loan Forgiveness Program
(effective July 2010). We found it extremely informative. The
final presentation is on Wednesday, June 24 (at 3:15 - 4:45pm EDT; 2:15pm
CDT; 12:15pm PDT). The presenter is Heather Jarvis, Esq., a national expert on
educational debt and the financial barriers facing law graduates.
The Public Service Loan Forgiveness Program is one of the most significant
breakthroughs for public interest lawyers in a generation. Briefly, the program
offers loan forgiveness after 10-years of public service employment. To
qualify for loan forgiveness, a borrower must make monthly loan payments for
ten years (120 payments) while working full-time in qualifying public service
employment. Qualifying public service employment is full-time paid
work in the government; a 501(c)(3) nonprofit, an AmeriCorps position, the
PeaceCorps, or a private "public service organization."
The Constitutional Sources Project is seeking students to work on a pro bono project involving an online library of constitutional sources. ConSource is a nonprofit located in Washington, D.C., which was founded to facilitate research, increase understanding, and encourage discussion of the U.S. Constitution by creating and maintaining the first, free, full-indexed, comprehensive online library of constitutional sources.
Student volunteers will read online documents written by U.S. Founders and cross-reference
relevant text to predetermined clauses in the Constitution. Students will enjoy location and time flexibility, completing work on their own schedule and from their own internet connection.
The hours are flexible (anywhere from 5 to 50 hours depending on student availability), and the project is expected to be completed by August 15 2009.
To Apply: Interested students should submit a resume to lawprobono@virginia.edu by Monday, June 22, 2009, by 5:00pm.
The Mortimer Caplin Public Service Center wishes to congratulate the Class of 2009 Pro Bono Graduates. The following graduates deserve recognition for meeting the requirements of the Pro Bono Challenge and for completing a combined 6,130 hours or pro bono work during their three years of law school:
The Legal Aid Justice Center in Charlottesville will be hosting a reception to celebrate the 2nd anniversary of the Virginia Institutionalized Person's Project.
Sunday, May 3, 2009 5:00pm - 6:30pm Legal Aid Justice Center
Drinks and light hors d' oeuvres will be provided.
Meet special guests Jennifer Thompson-Cannino and Ronald Cotton who will be presenting Picking Cotton: Our Memoir of Injustice and Redemption at the Miller Center on Monday, May 4 at 11am. Picking Cotton details Thompson-Cannino's mistaken identification of Cotton as her rapist, his subsequent imprisonment and release, and their unlikely friendship.
PSLawNet continues to be a valuable source of information for law students and graduates who are looking for employment in the Public Service sector.
The appended document contains a list of 36 current entry-level attorney openings throughout the country available on PSLawNet: Current PSLawNet Postings
This is an update for third-year students whose start dates have been deferred. As of today, 333 opportunities have been posted on PSLawNet. These include internships with the US Committee for Refugees and Immigrants, Blue Ridge Legal Services, ACLU, Public Defender Service for the District of Columbia, New York City Law Department, National Employment Law Project, National Juvenile Defender Service, Vera Institute of Justice, The Innocence Project, and Lambda Legal.
In addition, we have received a few similar opportunities from some nonprofits which we (together with the Office of Career Services) will continue to post on Symplicity. However, we reiterate that PSLawNet is the clearinghouse for internship positions for deferred associates.
Fran Cannon Slayton ('94), former prosecutor in the Commonwealth of Virginia and author of young adult novel When the Whistle Blows and Kevin Flynn ('82), Assistant United States Attorney (Washington, D.C.) and author of the best-selling, real-life, legal thriller Relentless Pursuit will be visiting the law school for a brown bag presentation on Tuesday, April 21 at 12:00 pm in WB 121. Slayton and Flynn will discuss their books, the writing and publishing process, and how their legal background allowed them to become effective writers.
Light lunch will be provided.
When the Whistle Blows (both books are available at online bookstores) is Fran Slayton's debut novel and tells a coming of age story about a boy growing up in a railroad town in West Virginia during the 1940s when small railroad towns are dying. Slayton tells a heart warming and realistic story about how a young boy comes to terms with his changing world. Slayton has received critical acclaim for her book but one review caught our eye: according to Diane Chen,
[When the Whistle Blows] is fresh, smart, witty, warm, well-written, funny -- all those great adjectives you want to see and that help tip you over the purchasing edge. But it is also SO BOY. I love that. It is something to embrace and to not be ashamed. There is drama and there is football. It is a celebration of living with each new "birth"day chapter, but it is also a recognition of the part of death in our lives. Death is a mystery, a crossing point, a cry, a laugh, a letting-go, a grieving, and a ritual part of living. Sometimes you don't realize how much a book impacts you until someone else asks you what you thought of it. So is the case of When the Whistle Blows by Fran Cannon Slayton. I read it in one sitting and could not put it down. I thought about it and thought about how to review it, but kept putting it off to think. Then, another librarian asked me if it was any good.
What? Any good? This is an amazing novel. You won't get to see it until June, 2009, but you will want to go ahead and pre-order it. To the Teachers at my school who read over my shoulder, I am sorry but you cannot have my advanced reading copy. I like it so much that I actually wrote in it, dog-eared pages, and flagged some of my favorite scenes. Do I want you showing students that sometimes these sacred library books become more than clean pages to glance over and preserve? Do I want you showing students that fictional novels can become an important part of determining who you are? Do I want students to know that books are worthy of study, thinking, and re-reading? Well, maybe I'll let you borrow it but only until I can get the final hardcover.
Relentless Pursuit
is an intense reconstruction of the brutal double murder of Diane
Hawkins and her 13-year-old daughter Katrina. Kevin Flynn tells a gripping account
about the murder, arrest, trial, and verdict, as well as a
behind-the-scenes glimpse into the life of a dedicated federal homicide
prosecutor and Virginia Law alum. Publisher's Weekly offers an excellent synopsis of the book:
In this true crime narrative, prosecutor Flynn presents a "story of extremes ... humanity at its most brutal and noble," and if one can withstand the bleak proceedings—including detailed descriptions of the horrific double murder of a mother and daughter—this title has much to offer. In 1993, Flynn was a 36-year-old U.S. Attorney in Washington, D.C., when he was assigned to a case involving the murders of Diane Hawkins and her 13-year-old daughter, Katrina Harris. All signs point to Norman Harrell, Hawkins' former boyfriend and the father of one of her sons; the murders occurred just days before Hawkins was to meet Harrell in court over a child support dispute. As Flynn works through the tumultuous early days of the trial, he's surprised by the affection and faith of the "populous Hawkins clan," and prodded on by thoughts of his own wife and child. Against a backdrop of everyday life and domestic complications—including his father's diagnosis with lung cancer—the prosecutor chronicles the case in meticulous detail, taking readers step by step through the unfolding courtroom drama. The portrait of Harrell that emerges is chilling; remarking on their similarities (both prosecutor and defendant have "loner's souls"), Flynn surmises that something "had been horribly miswired in him. And the sad thing was, I don't think he ever knew it." Flynn's is a fascinating, rewarding story of one attorney's dogged determination to exact justice.
All students are encouraged to attend this event to hear how two alums sucessfully attained their dreams of becoming published authors. Students interested in writing as well as those considering careers in criminal law are especially encouraged to attend.