MyShingle : Solo and Small Law Firm Management and Marketing

Can any biglaw associates answer this question for me:  why would you write posts for a biglaw blog?  Recently, I've been checking out some of the biglaw blogs, like Sheppard Mullin's Antitrust Law Blog, Davis, Wright & Tremaine's Telecom Law Blog or Preston, Ellis, Gate's e-Discovery Blog.  Though presumably associates write the bulk of the posts, none of the blogs give any attribution to the individual writer.  In that regard, associates are far better off writing a traditional article, where at least they can show authorship.   

None of this is surprising, of course, in light of the phenomenon of the "invisible associate," discussed here or here.   This isn't anonymous blogging by choice, but by fiat.  And what's both troubling and sad is that smart, young attorneys would so willingly forego ownership of their writing and analytical work, one of the few things that gives us any currency in this profession, simply because the firm demands it.  Yes, I may be a lowly solo in the eyes of biglaw, but at least I can say that not only is my name on the door of my firm, it's on my web posts as well, every one of them.

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In this recent post at More Partner Income, Tom Collins asks whether an attorney who has a one day turn-around to respond to email and phone calls is being responsive.  Tom Collins says no, as does Ed Poll.  As a practicing attorney, however, I don't completely agree.

Some days, I might return late to my office from depositions or meetings and simply don't have the energy to respond to an email or phone call.  There are some days when I'm under or close to a deadline and I simply can't pick up the phone or answer every email that comes in.  Collins criticizes this approach, asking whether clients would be "happy dealing with someone who places a greater priority on their own efficiency than yours?"  Maybe not, but at the same time, I'm certain that those same clients would not want you to miss one of their deadlines because you were responding to someone else's emails. 

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If you're going solo and can't afford an office, don't feel badly.  In fact, celebrate - because the lack of an office will enable you to follow in the tradition of Thomas Hall, the subject of this article, He house calls; attorney breaks free from tradition (Journal Times, 1/27/06).    As the article describes:

Since starting a business-law practice here last June, Hall meets all clients on their turf. They don't come to his office; he goes to theirs. It's sort of the legal profession's version of a doctor who only makes house calls.  "I liked the idea of going to see the clients where they are," said Hall, 45, of Wind Point. "It gets me out of the office, and it doesn't disrupt their day so much.  "I think I learn more when I go to the client's shop," he continued. "And usually everything they need is there."

When Hall travels, he does so on his dime, starting the clock when he arrives at his destination.

Convenience for clients, the opportunity to learn the business and an excuse to get out of the office.  What's not to like about a house-call based practice?

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David Giacalone of f/k/a writes this post about a New Hampshire bill that would reduce the jurisdictional limit in small claims court in New Hampshire from $5000 to $2500.  Lest anyone think that this kind of legislation is a lawyers-relief bill in disguise, I can assure you that it is not.  A case valued at $2500, particularly of the sort commonly brought in small claims (contract disputes, lost earnings, individual attempt to collect a debt) are rarely worthwhile for a lawyer to take or a client to bring.  (do the math - it's going to take a lawyer at least 3 hours to gather facts, draft a complaint and file suit, which is $450 at a rate of $150 an hour, plus at least $100 for filing fees.  So you're out $550 at the outset, even if the lawyer doesn't bill another minute on the matter.  For a $2500 matter, that's 20 percent even before you start).  So in the absence of small claims court, most of these claims simply won't be brought at all. 

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Remember back in the dotcom days, when everyone's goal was to develop that killer app, a computer program that is so useful that people will invest in a particular machine or hardware simply to run that program?  In law, a killer app is harder to come by, yet  Henry Zapruder, who died earlier this week of brain cancer (Wash. Post, 1/27/06) helped create one, by bringing the concept of IOLTA (Interest on Lawyers' Trust Accounts) to legal practice in our country.  According to the article, since their inception, IOLTA funds have raised more than $1 billion for legal fees for impoverished clients.  Reading on,  I also learned that though Zapruder eventually became a senior partner at biglaw firm Baker and Hostetler in 1998, for nine years prior to that, he was a shingler with a firm he'd formed,  Zapruder & Odell.

What's your killer app for our profession, the thing that will improve it measurably, the idea that will bring real meaning to concepts like "client service" and "equal justice" and "access to law"?  Because we need those killer apps now more than ever, before our profession kills itself.

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Not sure how many folks remember a tagline for one of the Yellow Pages books - "Let your fingers do the walking...." Seems that our fingers are doing just that, walking right out of the Yellow Pages and over to the computer keyboard.  Or at least, that seems to be the trend as first this earlier post and now this article, Still the Gold Standard? (ABA e-report, 1/27/06) question whether yellow pages ads are still worth the money  - especially, now that the cost of ads is increasing:

Now that lawyers have a variety of options for getting their information out, it would stand to reason that Yellow Pages advertising rates would drop, right? Wrong. Because the Yellow Pages has a high level of overhead due to distribution, rates have in fact skyrocketed, says Charles Laughlin, vice president and program director at the Kelsey Group, a Princeton, N.J., firm that analyzes trends in the Yellow Pages, electronic directories and local media.

Results, however, have not risen in conjunction with rates, and experts say that reason alone should persuade lawyers to reallocate their ad dollars. But what's the best alternative outlet? It often depends on whom you talk to.

There's nothing in the article that gives any reason, from what I can tell, for continuing to advertise in the Yellow Pages.  Perhaps the best thing the article has to conclude about Yellow Pages is that you might be able to negotiate more favorable rates.  But Yellow Page ads will have to come down significantly in price and generate far better return to compete with these kinds of results.

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Adding to this earlier compilation of resources on leaving a firm is this recent article, Practicing Ethics: Soliciting Clients, David Keyko, New York Lawyer (1/27/06).  The
article summarizes various New York professional code provisions governing client solicitation, including when lawyers depart a firm. 

In researching this issue lately, I consulted fellow blogger Dennis Kennedy's excellent chapter in Flying Solo  entitled "Leaving a Firm:  Guidelines for A Smoother Transition."  Dennis writes:

You might think the applicable rules and procedures of [leaving a firm] would be (1) easy to find and (2) quite clear and well settled.  If that is what you think, you will be surprised.  The guidance on this matter varies widely from state to state, and applying rules in any given situation can be a difficult exercise.

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This article, Speaking Opportunities Need to Be BAD to Be Effective, Julie Meyer (Legal Intelligencer, 1/19/06) starts out promisingly enough, with BAD tips (Before, During and After) on making the most of speaking opportunities.  Among other tips, Mayer recommends sending out an invitation or announcement before making your speech and obtaining the list of conference attendees so you can follow up after.

But the other advice misses the mark.  For example, Mayer suggests:

No need to be shy about selecting a nonclient or two to contact [after the event], either. The approach can be that you were flattered they made the time to attend, you hoped they found it worthwhile and they should contact you if they have any questions in the future. Eager for an opportunity to further develop the relationship? Propose a follow-up meeting of some sort with yourself and someone else from your network who will be an asset to theirs.

Contact one nonclient or two?  You should prioritize contacting nonclients and introducing yourself.  And why invite someone else along for the ride the first time, unless that person's going to help you snag the client. 

In addition, Mayer's article doesn't mention that During the conference, you ought to approach nonclients and introduce yourself.  Sure, you can follow up with a letter, but there's nothing like making an impression in person.  Plus, you have the advantage of approaching people from a position of strength and authority when you're a speaker on a panel. 

For a collection of other tips on getting more out of speaking engagements, check out this link at Legal Sanity.

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Via this post from Allison Shields as LegalEase is a link to this ABA e-report article (1/20/06) on the Ohio Bar's disiplinary board's recent ruling that ocupons for free or discounted legal services violate the Ohio Code.   The board found that coupons characterize a lawyer's legal services as "discount" and thus, run afoul of commentary to the Ohio rules that provides:
"Characterization of rates or fees chargeable by the lawyer or law firm such as 'cut-rate,' 'lowest,' 'giveaway,' 'below cost,' 'discount,' or 'special' is misleading."

As with all bar regulation, the rules sound benign enough in practice - protecting consumers from deceptive practices and preventing lawyers from acting like undignified hucksters.  Here's the reality, though.  Services like We the People aren't subject to bar rules - and thus, they're able to proclaim, as a tag line, that they offer "Low cost accurate document preparation."  Can an Ohio lawyer do the same?  As I read the commentary, I'd argue yes, but it's a close call since both "low cost" and "accurate" are charaterizations of service.  And for that reason, the Ohio Bar's rules have a chilling effect on lawyers who want to advertise their service in a way that allows them to compete with We the People.

Many bars have tried going after companies like We the People but the problem remains, that it's a service that fills a void for consumers who don't want to handle a case pro se and need affordable service.  Given that a need for affordable, basic service remains unmet, don't we want to do all we can to ensure that this service is provided by attorneys?  Overbearing and restrictive regulations like those of the Ohio Bar sure don't make that easy.

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This article, Attorneys' education is an ongoing process (Business Journal of Phoenix, 1/23/06) reports on Continuing Legal Education (CLE) in Arizona, which has been a required since 1989.  The article talks about the importance of CLE and the bar's flexibility in allowing the requirements satisfied through a variety of differently priced options.  But I'd have liked to see statistics, such as whether lawsuits or grievances based on attorney incompetence have declined or whether public perception of attorneys has improved, during the 16 years that the requirement has been in place. 

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Home Office Lawyer -Guru Grant Griffith shares these tips from  LifeHack on how to improve productivity working from home.  Tips include setting up a designated work area, setting a schedule and avoid volunteering for too many activities because people assume that when you work at home, you have more free time. Check out the post for more ideas.

Actually, one item missing from the list was figuring out how to keep from snacking all day long when you work from home.  Years ago, I asked a friend of mine if she'd like it if her husband, who put in long hours at a big law firm, could work at home.  I thought she'd say something like "Yes, but the firm won't allow it" but instead, her response was: "No way, if [my husband] were at home, he'd be eating all day and be the size of a house."  I guess that's another, oft-overlooked hazard of working from home (and one which challenges me as well). 

solotips

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Jon Stein posts a link to an article concerning the ethics of trolling for clients in online chat rooms under California law.  As you might expect, there are no clear cut answers; basically, you ability to ethically solicit clients in a chatroom depends upon the type of chatroom involved and whether participants have an expectation of being solicited by an attorney.

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This article, Did Barnes Firm Lawyer Tell the Whole Truth?, Michael Beebe, 1/22/06 reports on somewhat deceptive advertising by Thomas Goldstein, a lawyer with Cellino and Barnes, who advertised that he was uniquely qualified to handle Vioxx cases in light of his status as a former physician.  Trouble was, the ads didn't explain why Goldstein no longer practices medicine:  seems his license was revoked for providing misleading information about his medical training. 

Goldstein's points out that his license wasn't revoked for incompetence, but for a technicality.  If that's the case, Goldstein should have simply disclosed in his ads that his license was revoked for administrative reasons.  By hiding this information, he's only made his situation worse now.  Of course, considering the ethics history of the firm where he works, Goldstein doesn't really have much in the way of role models.
(see also this earlier post).

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Casemaker, a free legal research service included in participating state bar membership fees is a trend we've been following for a long time.  As this article fom bizjournals.com (1/20/06) reports, New Mexico is the 23d state to join the Casemaker consortium.
New Mexico Bar joins legal research consortium, hich according to the article, now serves 424,000 American lawyers. 

I'm a member of the New York, Maryland and District of Columbia bars, none of which participate in Casemaker.  So I'm publicly asking why not?  And you should do the same if your bars haven't joined either.

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Jim Calloway has generously named MyShingle as his website of the week, notwithstanding his perception that I sometimes have a negative view of bar associations.  I'd like to clarify.  Generally, I've lauded the bars for programs like these that help solo and small firm practice law.  Likewise, I'm a huge fan of the work that LPM experts like Jim, Reid Trautz, Pat Yevics and others have done to support solos (and especially Reid, just because I'm most familiar with his work here in DC, a biglaw dominated bar, where he could have easily taken up biglaw interests and ignored solos, but hasn't). 

But while I admire the individuals, I can't help but criticize bar policies or decisions like this or this or this that make life more difficult for solos and smack of unfairness, given that solos are often disproportionately targeted for ethics violations (which isn't to say that we solos don't have our share of bad apples, something that I try to point out so that other solos can learn from their mistakes).   Fortunately, I find myself blogging about this kind of thing less and less as I happen upon many more inspiring stories or good advice worth passing on.  That's certainly the beat I'd prefer to cover.

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The recent outing of formerly anonymous Opinionistas as biglaw associate Melissa Lafsky , close on the heels of the reveal of David Lat as Underneath Their Robes and Jeremy Blachman as Anonymous Lawyer has Orin Kerr wondering whether the trend of blogging anonymously and snagging a book deal might provide a a new career path for unhappy lawyers.

Don't get me wrong - I'm thrilled for my colleagues who've found notoriety through blogs.  It's just more proof of the power of the blog.  But at the same time, the anonymous-lawyer-turned-celebrity has too much of a fantasy feel to it for my taste - which is probably why it appeals to large firm attorneys, the excitement of the dotcom start-ups in the 1990s lured so many biglaw attorneys away from their firms.  It all kind of makes me wonder whether anyone at biglaw really wants to be a lawyer or whether they're biding their time, waiting for a book deal or stock options or a winning lottery ticket.  Did biglaw attorneys ever want to practice law to begin with, or was law just an easy way to suppress other passions or avoid a deeper exploration of their desires.  Or does the large firm, through its merciless, grinding caste system, kill young lawyers' vision of law as a noble, empowering career that can change lives and promote justice?

It makes me sad that so many really, really smart young people are so readily seduced by fantasy - first the fantasy of a high power biglaw job, later the fantasy of escape to celebrity.  When there's an option for satisfaction right in front of them, one that Greatest American Lawyer discovered when a year ago, he left the comfort of a cushy firm job "for the feel of the breeze in my hair and a goal to change the way law is practiced."  Maybe GAL isn't as sexy as Opinionista, but he inspires me more by standing his ground and not leaving the law, but staying; staying to reclaim the vision that made him - and so many of us - want to be lawyers to begin with. 

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Via Stay of Execution and Rob Hyndman comes this link to a great piece by Paul Graham on
How to Do What You Love.   Because after all, that advice to "do what you love" is easy, it's finding what you love and figuring out how to do it that's a life work. 

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As I pointed out in this earlier post, finding a niche can help grow your practice.  And, as Tom Kane pointed out months ago (don't know how I missed it), a niche can help a solo survive in the big city.  And now, there's yet another article, Finding a Niche (Jan. 2006) that describes how lawyers with niche litigation practices in specific localities are beating biglaw firms big time for big clients.  (see also this earlier post).  Here's Larry Bodine's money quote from the article:

You do have to target," he says. "That's the difference. You never used to have to do that. Nobody wants a generalist. A generalist is nothing to nobody. Everybody wants an expert. Stick to a niche. Be an inch wide and a mile deep, and then you will get all the business that's related to the niche.

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Fellow shingler Lisa Solomon's 's company, The Billable Hour, that she runs with her lawyer-husband Mark has hit the bigtime with this press the Wall Street Journal Law Blog.  It's sure to get lots of reads, as it  mentions the recent  unveiling of formerly anonymous law blogger,  Opinionistas.

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Fellow shingler Frank Yunes (www.yunes.org), a trusts and estates attorney from Lexington, MA has an idea for a New Year's Resolution [which I have not been timely in posting - CE] Frank writes:

I just finished the process of forming a single-member LLC for my law firm. I wonder how many of us out there are pure sole proprietors and might benefit from a discussion of how to create a formal entity to shield our personal assets from professional liability.

Although we all have liability insurance, in some cases this protection is not quite enough. The creation of a legal entity is an additional layer of protection that might be appropriate depending on your practice area.

The single-member LLC seems to me a perfect fit for attorneys in solo practice. I believe all 50 states now have a single-member LLC statute (if memory serves, MA became #50 in 2003). In addition to the obvious liability protection, a single-member LLC is treated as a "disregarded entity" for personal income tax purposes. This means formerly sole proprietors can continue to file Schedule C with their personal income tax return for as long as the entity is a law firm of one. The formation of a single-member LLC will not, therefore, necessitate filing a corporate tax return like a C or S Corp.

The process of forming an LLC is remarkably easy... In MA we can form an LLC online at the Secretary of State's website. We can obtain a tax ID number ("EIN") at the IRS website in a matter of minutes. A new bank account in the name of the LLC can also be established online. The hardest part is probably deciding what to name the entity! I went back and forth on this (The Law Office of Frank B. Yunes, LLC just didn't sound right to me) and decided on Frank B. Yunes, Attorney at Law, LLC.

I chose to form the entity at the end of the year so I could make a smooth calendar-year bookkeeping transition. Starting Jan 1st, all receivables and payables will be conducted through my LLC. This separation, of course, is critical to any subsequent argument that my law firm is separate from my personal assets!

I feel a sense of relief knowing that if I find myself on the wrong end of a lawsuit moving forward, my personal assets will be more protected than if I were merely a sole proprietor.

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Though it comes in number 5 on this list of law firm questions, client relations tops the blog charts for this week.  Allison Shields' Legalease offers a great round up.  Of course, one of the best essays I've ever seen on how to get to know your client is this one (though I can't find the full text online anymore).

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This month's buzz word must be "niche marketing," (see here for my earlier posts on interesting niches).  Last Thursday, I listened in on the Nader Anise teleconference that I posted about here last week.  The mystery guest was The Pet Lawyer, Molly Gaussa and the focus of the call was Niche Marketing (Nader is offering a kit, Niche Your Way to Wealth, email at naesquire@aol.com; I haven't seen the material so I cannot endorse it).  And here at LexBlog, Kevin O'Keefe points us to this post from Duct Tape Marketing on niche blogs, which offer a great way to attract clients, as I posted here.

As a lawyer with an expertise in offshore renewable energy for a dozen years, you can't get much nichier than I am.  And based on this experience, I have some advice about what works and what doesn't for niche practice as well as what to expect.

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With so many lawyers turning solo, it's surprising how little has been written about the issues that departing attorneys face, such as when you can solicit clients or sharing fees.  But this article, Associate Says Ex-Firm Misused His Name on His Web Site, The Connecticut Law Tribune (January 11, 2006) reports on another issue:  keeping a departing lawyer's name up on the website long after he leaves.  According to the article, Robert Murphy is suing his former law firm for allegedly continuing to list his name, biographical information and e-mail address on its Web site long after his termination.  Murphy claims that the firm's continued use of his name at its site confused potential clients and directed business from his new solo practice to his former employers.

Just another issue to keep in mind when you leave your firm.

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This past weekend, my husband and I attended the thirty fifth anniversary bash of the firm where I worked over a dozen years ago, the one that sent me packing and in so doing, pushed me on to my present path.  I've stayed in touch with all the partners (never burn bridges if you can help it), and our relationship over the years has improved, from subordinate and boss to actual colleagues who enjoy each others' company.  The founding partner created a slide show with photos from the firm's history.  Looking at the slides and what the founding partner (with his partner, who is now deceased) created - municipal electric systems, law offices in Africa, mining codes for numerous countries, a legacy of top energy lawyers, many of whom work at other firms but comprise an elite group at the top of the field and a firm that despite some hard times remains intact when so many others have failed - I wondered what my legacy will be when I've practiced for thirty five years, what my slides will show.  What about you?

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This article from AP,  Lawyers Can Be Sued for False Advertising (1/11/06)
reports on a recent ruling by the Colorado Supreme Court, holding that the state's consumer protection act applies to lawyers.  Thus, plaintiffs can bring civil actions against attorneys for false or deceptive advertising. 

Frankly, I don't have a problem with this ruling.  In some respects, letting the court system rather than the bar make decisions about what constitutes a deceptive practice may be preferable. (as you might recall, here's what the Florida Bar considers deceptive)  I realize that lawyers aren't likely to fare well in front of juries, but I'm guessing that many of these deceptive advertising cases won't survive summary judgment and that they'll be costly to bring because they'll require expert testimony.  In short, I don't see the Colorado decision as open season on lawyers, but rather, an opportunity to develop a potentially more credible test of what's deceptive than what the bars currently provide.

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I do plan on joining the podcast world before the first quarter of the year is out.  But for now, I'll have to content myself with my 15 seconds on Legal Talk Network's Coast to Coast, hosted by fellow bloggers Bob Ambrogi and Craig Williams.  

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Are lawyers rocket scientists or what?  According to these survey results, just released by Robert Half (1/11/06), attorneys identify client service as key to long term career success.
Most of us solo and small firm lawyers have always known that client service counts, because that's what allows us to compete with large firms.  Even now that the rest of the profession is waking up to our secret, I'm not concerned.  Solos and small firms have been focus ed on client service for so long, that it's going to take the rest of the profession some time to catch our lead (as GAL's here and here bear out).

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Last Saturday, the Washington Post published this op-ed piece, Pro Bono:  A Better Alternative  by Joel Sheptow, a Stanford Law student who's participating in a student project that provides pro bono service.  Based on his experience, Sheptow proposes that rather than refer pro bono matters to already over-worked large firm associates, the bar should encourage them to give money to fund legal aid programs.  It's an idea that I endorse, though not particularly new; I wrote an almost identical piece entitled "Just Give Money" that appeared in American Lawyer in January 1993 (yes, I go back a long way with ALM). 

Predictably, the idea of money in lieu of pro bono is no more popular now then it was back then when I wrote on it.  In today's post, Esther Lardent of the biglaw funded Pro Bono Institute responded with this Letter to the Editor boasting about the major firms' contribution of 3 million hours of pro bono service and conclusions that "pro bono is not an inefficient response to [the] dismal reality" that the U.S. provides inadequate funding for civil legal services.  What Lardent doesn't mention in her letter is that if large firms stopped running pro bono services, she'd be out of a job, because the Pro Bono Institute provides consulting services and support to biglaw pro bono projects.

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At his Illinois Trial Practice blog, Evan Schaeffer links to the Miller and Zois Attorney Help Center.  The Help Center makes available, online, sample pleadings, motions and discovery materials for personal injury cases in Maryland, though many might potentially serve as a model for other states as well (though don't forget to check applicable state laws and local court rules to make sure).  I'd actually come across this site several weeks ago and used one of the pleadings as a loose model, so I can attest first-hand to the utility of the site.

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Lawyer marketing expert Nader Anise is sponsoring another one of his annual, free teleconferences on Thursday, January 12, 1 p.m. Eastern Time.  Click on the "read more link" for the full announcement.

I have posted about Nader's e-newsletter before which I enjoy, and I found his last free teleconference quite valuable.  I don't often post about solo events because I don't have a formal policy on what to recommend or not after all this time.  But as a general matter, if there's a seminar or phone conference that's free or an otherwise good value for solos, I'm happy to convey the information to my readers. 

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An article I wrote several months ago, Treating Family Like Business, just appeared in Law.com's new Career Center.  Primarily, my article reacts to pieces like this which advise attorneys seeking a home-work balance (mostly women) to pussy-foot around and beg for accomodation instead of taking the bull by the horns and advocating, strategizing and negotiating for their needs as vigorously as they would for a client.  Does this mean that I think lawyer-parents should be strident or whiny or express a sense of entitlement in asking for alternate work schedules?  No way!  I endorse proactive, creative approaches where you take the initiative, as well as advance planning to make yourself sufficiently indispensable so that you can write your own ticket. 

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OK, I've had my law firm website online for almost ten years now, longer than the wayback machine goes.  And in all that time, I've been hobbling along with a clunky URL, http://www.his.com/israel/loce (the "Israel" is my husband's last name, who holds the HIS account, not the country).  Though I regard the URL as a badge of honor that evinces my Internet longevity, after a decade, I realize that it's time to cut the ties to the past and move into the present.  So, for now, I'm using CarolynElefant.com though I will probably soon register Elefant Law (or will this be considered undignified animal advertising?) or some other designation to show that the URL belongs to a law firm website.

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A reader writes:

Do you have any recommendations on how to pick up contract work from local attorneys or solos?  I want to approach local firms to see what their needs are for subcontracting out work.  Do you have any ideas on how one should go about doing this?  I'm not looking to do contract work full time, but only for supplementary income until I get my firm off the ground.

Like my colleague Jon Stein, I've learned about contract work from both the giving and receiving end.  This experience has given me some strong views about what works and what doesn't.  Here's my advice below:

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Like all of you, I've made many New Year's resolutions, long lists of ideas and tasks that I intend to pursue and complete.  So far, I have already accomplished one of them.  Ever since, BlawgThink, I've been smitten by the concept of possibility of the wiki.  Seems like they offer a cheap and efficient way for solo and small firm lawyers to collaborate on projects with each other and with clients. 

But the first wiki that I set up is for a trade association that I helped found this past year.  There's an important rulemaking that issued a couple of days ago that can potentially make or break this particular industry.  As a result, our nascent association must mobilize and file comments.  Ordinarily, filing comments in rulemakings involves numerous meetings, phone calls and hundreds of billable hours - which require time and resources that our group simply doesn't have.  So, I created this wiki here , using the free and incredibly easy PB Wiki  application.  Members can post their responses to the questions posed in the rulemaking right online - which will help eliminate repetitive topics and allow us to collaboratively refine our approach.  We'll have a teleconference for members next week and introduce them to the wiki and see where it goes.

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