Duane Morris LLP - The Inside View

A true Millennial, Duane Morris went global after Y2K and hasn't looked back.

'GO big or go home' is not a phrase generally associated with law firms, but we think it fits Duane Morris. Since 2000 this decent-sized stalwart of the Philadelphia legal scene has grown to 27 offices worldwide, adding global outposts from Hanoi to London on the way. It's not just litigation – or 'trial' as it's called at Duane Morris – these days, either. The firm gets top marks from Chambers USA for its bankruptcy, construction, corporate and IP practices. Compare this to its founding in 1904, when it had just four partners and was more likely to help you buy or sell farmland than defend a class action suit or restructure a company.

Much of this expansion has taken place since the turn of the century, and the firm doesn't plan to stop soon. “We want to continue to grow our US platform,” chairman and CEO John Soroko tells us, as well as seeking opportunities overseas. We hear a Taiwan foothold is in the offing. The approach seems to be working: 2014 saw “all-time highs in firm revenue and partner profitability.” Even Harvard Business School's impressed: they have twice studied DM's rise from Philadelphian to citizen of the world.

The Work

In a process described as “a bit like rush week,” summer associates rank their three preferred practice areas. The firm then tries to match associates to practice areas, taking into account an applicant's preferences, their personality and the quality of their work product. Trial associates “come with three official assigning partners” but tend to get the bulk of their work by “knocking on people's doors and figuring out what they need.” This, we're told, is “stressful, but character-building.”

Duane Morris may have branched out but trial remains the largest department. It hosts “the plurality of the associates” and offers a practice range so broad that one associate told us that “any dispute between two parties that might end up in court could land on my desk.” Associates described working on everything from construction, to product liability, to banking disputes. “On cases with a lower dollar value, the partner might give me the file and tell me to run with it,” said one courtroom brawler. Another praised the firm for “doing a better job than most law firms in getting junior associates into the courtroom.” On the larger cases typical tasks fall under three broad headings: “The first is doc review, the second is legal research covering a number of issues, and the third is motion drafting and brief writing.”

"They do a better job than most firms at getting junior associates into the courtroom."

Corporate associates “start off as generalists and can work with anyone who needs assistance,” which means “when you specialize you'll know what sort of issues can arise.” A lot of the work falls under the heading of mergers and acquisitions, although it can include anything from equity financing to reinsurance. There's a lot of responsibility: “I've been to more in-person closings than usual for a junior associate,” said one. Corporate deal-doers “often lend a hand” to other departments “when they need transactional work done.” If it all gets a little overwhelming, everyone we spoke to felt comfortable refusing work. “After all,” said one, “they want you to give the project your full attention,” and “if you're getting too much work, you can talk to your practice group head and let them sort it out.”

Pro Bono

While “there's no pressure” on associates to do pro bono work, it's certainly encouraged. “All the resources are all there,”  and all the right incentives are in place, too, with the chance to treat 100 pro bono hours as billable and the “opportunity to do work that junior associates wouldn't be able to do for a paying client.” DM associates have worked on everything from “veterans' benefits to forming nonprofits to helping the victims of sex trafficking expunge their criminal records.” As with paid work, pro bono cases are assigned through both formal and informal channels. “Individual partners might ask you to join in on something they're doing,” explained an associate, “but the firm has a dedicated pro bono partner.”

Pro Bono hours  

  • For all attorneys across all US offices: 22,120
  • Average per US attorney: 34


The fictional law firm Wolfram & Heart – villains of the TV show Angel – may not be the greatest legal role models in the world, but it does have one thing in common with Duane Morris. No, Duane Morris is not (to our knowledge) plotting to take over the world. In season 5, Angel and Spike travel to Wolfram & Heart's Rome office, only to find that it's identical to the one they've been dealing with back in LA. Similarly, Duane Morris's offices are deliberately set up to look alike. As a result, visiting different offices is “both comforting and weird,” we were told. However, each office is “slightly different.” One associate quipped that this makes different offices “feel like a familiar setting, even if you still can't figure out where the copy room is.”

"On New Year's Eve we gather in the boardroom and watch the ball drop in Times Square."

While the New York office's Times Square location is “kinda horrible because of all the tourists,” it is a great spot for the office New Year's Eve party. “We gather in the boardroom and watch the ball drop,” said an associate. On a more mundane note, it's also conveniently located for people commuting from outside the city, and only an hour and a half from the Philadelphia headquarters. Philadelphians raved about Morris' Cafe, which is named after the firm and resides in their building but is open to the public and run by Stephen Starr. “It's so good that lawyers from other firms eat there,” one informed us.


In 2015, Philadelphia's newly elected mayor Jim Kenney picked head of diversity and inclusion Nolan Atkinson to head the city's diversity drive. The firm clearly has City Hall's approval, but what do the associates think? “Our loss is Philly's gain,” mused one. When it comes to recruitment our sources were impressed with DM's efforts at recruiting female attorneys, telling us that “there are more women joining the firm than men,” but thought that more could be done to attract top attorneys from ethnic minority backgrounds. “I think we need to reach out to candidates earlier in the pipeline,” one New Yorker opined.

The use of the word 'inclusion' in Nolan Atkinson's title was deliberate, according to our sources. “It's not enough to recruit a diverse workforce,” explained someone in Philadelphia. “You also need to make sure they feel like a part of the firm.” To that end, the firm focuses on “reaching out to the diverse attorneys here and making sure they have the opportunity to build relationships with the firm's clients.” There are “regular lunches and happy hours” to make sure that attorneys of all backgrounds interact, and there is an annual diversity retreat which allows individuals “to get to know people better,” one informed us.

Hours & Compensation

“We work hard, within reason,” explained one of our sources. There's a billable hours target of 1,950, “and we can bill 100 hours of pro bono, so in reality it's more like 1,850.” Associates told us that the firm wants people “who focus on producing the best work possible, rather than on billing 2,400 hours.”  Not, we hasten to add, that the firm would object if attorneys did produce 2,400 hours – “I'm sure they'd be delighted” – but they'd rather attorneys didn't “burn themselves out,” not least because “the quality of your work is likely to diminish.”

"Your work product has to be the best."

The flipside of this is that the firm won't settle for half-measures from attorneys. “You can never just write up a memo, slap the word 'draft' on it and hand it in hoping it'll be OK," explained a New York associate, "your work product has to be the best.” And, of course, sometimes when deadlines loom late nights are inevitable, although there was some disagreement about just how late is necessary. “I've done a couple of all-nighters,” claimed one, “but that's because there was a deal that needed to close.” Another claimed “never to have stayed in the office past ten o'clock,” while a third thought that “staying until 11.30pm or so is not unusual.”

Overall, though, hours tend to be pretty good and all-nighters relatively rare, with associates leaving at 6.30 or 7pm. “If I need to work late I'd rather go home at a reasonable hour, have dinner with my family and remote in for a little while,” stated one. There were some grumbles about the salary, $150,000 for first-years, which was described as “a little below-market, whereas we do market work,” but overall most of our interviewees thought that sacrificing a little salary for a better quality of life was a fair trade. “Anyone can say they want more money,” said one sanguine lawyer, “but I'm convinced that my life is objectively better than my friends' at other firms.”


Those of a callous and mercenary disposition are unlikely to fit in at Duane Morris, which has a “no jerk policy.” There's a close-knit atmosphere among associates, which is helped by the fact that the firm's incoming class is relatively small, which is like having “a load of little families throughout the firm,” in the words of one insider. “I refuse to use the word 'collegial,' because it's only ever used in law firm marketing,” a legal eagle told us, “but there is a camaraderie and a sense that you're never alone.”

"There's a camaraderie and a sense that you're never alone."

More tangibly, we hear that associates are happy to “decorate their offices in quirky ways” and “play pranks on one another.” Don't worry, it doesn't get too crazy: “This is still a firm of sophisticated lawyers representing sophisticated clients,” but one where people are happy to help each other out. Socially, “Duane Morris is too big to have a firmwide social scene,” but individual practice groups and offices are quite active on the social front.

Training & Development

Respondents told us that “law firm training is a hard thing to get right,” but thought that DM was on the right track. “I mean, there's some excruciating computer training at the start,” recollected one, “but they also provide us with enough CLEs that we never need to leave the firm.” The whole thing starts in Philadelphia and continues back at the individual offices. During the initial orientation period the firm stresses the importance of “getting frequent feedback from all your projects,” something the juniors we spoke to agreed with. “Without feedback you can drive yourself crazy,” they explained. “You don't know if someone hasn't come back to you because your work was bad, or just because they're busy.”

"Candid but constructive."

In any event, there is a regular formal review process, which takes place twice (at six month intervals) during each attorney's first year of practice and once a year thereafter. Lawyers are asked to nominate their assessors from attorneys they have worked with. “You can pick lawyers that you've done a lot of work for in one go, or those you've done lots of little bits of work for,” one told us. Assessees are provided with a copy of their feedback before meeting with the partners, which helps eliminate surprises. “It's candid but constructive,” one told us, and a good way for attorneys to learn where they need improvement.

Get Hired

While it participates in the usual OCI process, Duane Morris is also “open to attorneys joining through other routes,” such as write-ins for specific opportunities, law school resume books and, in one case, “hounding them until they agreed to meet.” The OCIs themselves are conducted by partners rather than associates, and interviewing partners tended to be alums of the school in question. At the callback stage, one interviewee noted that “they had read my resume thoroughly,” but that the interview was “more like a chat," and there were “no 'put them on the spot and see how they react' type questions.”

"Challenge yourself with the most interesting and, if you will, most difficult courses in the law school curriculum."

Chairman and CEO John Soroko tells us: "One of the things that I always tell our summers is to take advantage of the opportunity while you're in law school to challenge yourself with the most interesting and, if you will, most difficult courses in the law school curriculum. Take courses in transactional law, taxation, antitrust... it's a wonderful opportunity to get that grounding."

Strategy & Future

Associates identified booming Asia and rapidly thawing Cuba as two of the firm's key target markets. Newbies aren't just kept in the loop about the firm's future plans, they're also encouraged to bring them to fruition. The firm provides “a lot of different business marketing and development courses,” and also encourages associates to “make connections with potential clients, even if they aren't in a position to give us business now, with a view to creating business down the line.”

Doing Business in Cuba

Cuba, the final frontier. After more than half a century long stuck in the permafrost of the Cold War, US-Cuban relations starting to thaw. At the same time, Cuban President Raul Castro has introduced a number of key reforms to allow much-needed private capital to grease the wheels of the island's creaking socialist economy. While the island offers new and exciting investment opportunities, doing business in Cuba is still fraught with pitfalls.

Much of Cuba's economy remains state- controlled, obliging investors to co-operate with the country's opaque bureaucracy. Exporters can't sell directly to end users, but to the Cuban government. For example, agricultural produce is purchased by an agency called ALIMPORT, which then sends it on to the next stages of the state-run distribution system. Additionally while the government has eased sanctions, they haven't lifted the economic blockade. For example, US citizens will be able to travel to Cuba on business or to visit relatives, but tourism is still prohibited.

This means that US businesses in Cuba need to be doubly careful- not only do they need to navigate the country's own rules, they'll need to make sure that they comply with US sanctions as they do so. Fortunately, Duane Morris' Cuba Business Group is on hand to help companies avoid falling foul of this tangled legislative web. The group builds on Duane Morris' experience liaising with US regulatory bodies, and follows the firm's pioneering work in opening offices in important and unconventional emerging markets like Myanmar and Sri Lanka.

Interview with chief diversity and inclusion officer Joseph West 

Chambers Associate: First off, big news: Your predecessor, Nolan K Atkinson has been tapped by the City of Philadelphia to serve as its first Chief Diversity Officer. What legacy does he leave?

Joseph West: Nolan leaves very large shoes to fill. First of all, he's the consummate professional and an extraordinarily talented lawyer. He's also been a strong voice and advocate, not only for diversity and inclusion within the firm and throughout the wider legal profession. It was through my respect and admiration for him that I was intrigued by the idea of coming to Duane Morris. I owe him a debt of gratitude.

CA: Is there anything in particular that you think our student readers should be aware of?

JW: The legal profession remains the least diverse of all white-collar professions, and in the last five to seven years, people have come to realise that this has less to do with a lack of focus on diversity in recruiting, and more to do with the lack of inclusiveness. Nolan took a great job in focusing resources on inclusion- on inclusiveness – as a tool for retention and advancement, and the programs that I'm inheriting are steeped in that understanding.

The second thing he did was focus on diversity and inclusion with respect to vendor relationships. Nolan was an advocate of looking outward to entities that the firm did business with outside the purely legal realm. This is unusual but also admirable, and is something that I hope to continue to work on.

CA: You've mentioned 'inclusion'  already, and I noticed that your title is Diversity and Inclusion Officer, rather than just Diversity Officer. How do the terms inclusion and diversity differ?

JW: The differences are straightforward. 'Diversity' speaks to numbers, it's a question of how many women, how many minorities, lawyers with disabilities, LGBT lawyers you've brought into your organisation. Inclusiveness goes a step further. It's a question of whether diverse people feel like they have a role to play in the success of the organization, about whether they are made a part of the culture and fabric of the organization.

Because of a lack of focus on inclusion, a lot of firms that do a decent job recruiting diverse talent, still see a lot of those lawyers leave the firm. The attrition rate for minority women in large law firms hovers around 100%. I'm not talking about laterals, but home-grown attorneys who have started off with an organization. After six or seven years, almost none of them are still there. Firms are missing out on a huge amount of talent, and the next step is making sure that this talent is retained and has the opportunity to advance to leadership ranks. Inclusion is a key part of that, and that's why my role is Diversity and Inclusion Officer.

CA: What is Duane Morris doing, not only to recruit more diverse attorneys, but to retain them and make sure they make partner?

JW: The first thing is mentoring. We're creating mentoring circles where senior attorneys and senior partners, particularly those with a significant book of business, can take diverse attorneys under their wing. They can make sure they navigate the politics that exist, not only at Duane Morris, but in all firms, and develop the emotional intelligence and skills to become successful within the firm structure. We're also working to get our clients more involved in investing in the success of the talent. We want diverse associates to receive as much practical exposure working for our clients as possible.

Duane Morris already has a collaborative working environment, with lawyers working across practice groups and geographies. We need to make sure that people across the firm understand the importance of collaborating on these initiatives. It's also important that diverse lawyers have a voice and can communicate their concerns. I know that [chairman] John Soroko is a very strong advocate of making sure information flows two ways, so that we have as much real-time feedback from associates and staff about what we should be doing differently. All the well-intentioned programs in the world mean nothing unless you are able to monitor their effectiveness and make changes.

CA: Why do you think retention is such an issue?

JW: There are a number of challenges that any serious retention effort faces. Sometimes people leave for reasons that aren't negative. They might be appointed to the bench, or to a governmental or in-house position where they can act as clients of the firm. Like any other attorney, diverse lawyers might also move jobs for family or personal reasons. But let's not kids ourselves. A lot of people leave because their talents aren't being addressed. There are some extraordinarily talented diverse lawyers out there, and retaining them doesn't just benefit them, but also benefits their firms and their clients. At the end of the day, firms are about servicing clients and making sure that they're successful, and a strong focus on inclusion facilitates that role.

CA: There can be a feeling that a lot of diversity initiatives are just window-dressing or box-checking exercises. What makes Duane Morris different?

JW: One of my tasks is to chair the firm's diversity and inclusion committee. I've seen committees at other firms that themselves were not diverse and that weren't staffed by people with gravitas and influence. At Duane Morris, we have a very diverse committee, with lawyers from every ethnic background, women lawyers, LGBT lawyers and lawyers with a disability. The committee members are also people with a long tenure at Duane Morris, who have substantial books of business and a significant voice in firm management. This sends a very strong message that this this an important initiative, not something that is ancillary or likely to be jettisoned at the first sign of trouble.

We have a strong level of staff support, not only from attorneys, but from people like the marketing group, HR and almost every major group in the firm. We not only need ideas from the committee, but we also need people who can take the ideas and implement them. Ideas are worthless without implementation.

I'll make one other point: increasingly we see corporate clients taking a more serious approach to diversity and inclusion. They have robust internal programs and they expect the same from the law firms that serve them. Ten years ago, there were only three or four Fortune 500 companies that had a chief diversity officer position. Now more than two thirds have one. Corporations don't create these positions because they're the flavour of the month, they do so because they understand the importance of diversity and inclusion.

It's important to their customer base, and to the regulators who hold sway over them. It's also important to the ever-more diverse bench whose judgments affect them, and even to the directors themselves. There's also an international dimension- legislation in the US and EU seeks to hold companies' feet to the fire on the subject of diversity, and as soon as those law firms looking to build their global presence understand its importance, the better they'll be. I'm always intrigued when people claim diversity isn't important. Very few businesspeople claim that diversifying their economic portfolio is a bad idea. I think the same principle applies to the makeup of their workforce.

CA: What is your response to people who claim that trying to increase diversity is un-meritocratic?

JW: I think people who believe that are misguided. The Minority Corporate Counsel Association, which I used to head, did a study called 'the Myth of the Meritocracy'. It shows that in most instances non-minority hiring managers in major law firms did not meet the same hiring criteria that they were applying to minority candidates. This whole notion that society and the legal profession are steeped in meritocracy is simply false. Most people who are a successful gained their success through a combination of their skills and their network. If you're not a minority, you benefit from access to a wider network. That's not even up for debate.

CA: How diverse is Duane Morris at the moment? 

JW: We have work to do. I don't think anyone at the firm will dispute that. Like other large firms, Duane Morris has work to do when it comes to retaining the diverse talent that comes through our doors. There are two things that distinguish us from other firms- the first is the level of commitment to making a difference in this area. We put a huge amount of firm resources into this, including support staff, programming and gathering and examining data.

The second is our annual diversity retreat. In 2016 it will take place on May 20th and 21st and is anchored by the George B. Vashon lecture. This is named in honor of the first African-American attorney admitted in New York. He was an abolitionist who was denied the right to practice in Duane Morris' home state of Pennsylvania because of the colour of his skin. At the retreat itself the entire leadership get together and focus on where we need to go from a recruitment and retention standpoint.

CA: You mentioned earlier that the bar is the least diverse white-collar profession in the US. Why do you think this is?

JW: A number of reasons. The first is that even in the face of consumer demand the legal profession is very slow to change, and not just in the diversity field. Back in 2008-2009 one of the by-products of the economic downturn was that corporate clients became more savvy consumers of legal services and begin to expect more value-based billing arrangements from their outside law firms. Yet, with some exceptions the firms themselves have been very reluctant to explore any other billing arrangements beyond the billable hours model. It's the same culture of resistance to change in the diversity field. Over the last 20 years, we've seen more women and minorities holding leadership positions in corporate legal departments, but similar numbers in law firms have remained flat.

Another problem is that in corporate departments, someone with sharp elbows who hoards contacts and doesn't work collaboratively will find themselves ostracised and pushed out of the organisation, whereas in a law firm the same attributes will often get a person rewarded. This can make the atmosphere hostile. A lot of corporate clients are starting to expect a more collaborative approach from their law firms, but this has also been partially resisted.

Another reason, frankly, is the constricted pipeline. In the last few years it has become more cost-prohibitive to attend law school and diverse lawyers are disproportionately affected. And even before college or law school, otherwise ideal candidates aren't made aware early enough that this is an option. We need to eliminate barriers and create opportunities all through the pipeline, starting many years before college so that good candidates from minority backgrounds matriculate. This isn't about giving minorities unequal treatment, it's about removing the barriers that do exist so that people have an equal opportunity. Barriers steeped in bias affect recruitment, work assignment, evaluation of that work and discussions around advancement. Eliminating these barriers will benefit both firms and the profession.

CA: How big a role does bias, particularly unconscious bias, play in recruitment and retention and how can we guard against it?

JW: It plays a huge role. The Minority Corporate Counsel Association Worked with a company called Nextions which published a study entitled 'Written in Black and White.' Sixty partners from major law firms in a particular city were asked to participate in what they were told was a research project for third year associates. Half of them were given a memo purportedly written by a third year NYU graduate who happened to be African-American. The other half were given the same memo, but were told it was written by a Caucasian third year NYU graduate.

The study's organizers put a number of errors of fact, citing mistakes, typos and formatting errors in the memo and asked the partners to rate the memos out of five, with five being the best. Even though the memos were identical apart from the ethnicity of their alleged authors, the 'Caucasian' memo was ranked almost a full grade higher than the 'African-American' one. A larger number of errors were spotted on the 'African-American' memo than in the 'Caucasian' memo.

The comments on the memo were telling. On the 'Caucasian' memo the comments were very supportive, stuff along the lines of “with some mentoring the author is likely to be very successful.” On the 'African-American' memo the comments were scathing, things like “are we sure this guy's a third year,” and “maybe we made a mistake hiring him.” The graders were looking at the 'African-American' memo with a more critical eye, while giving the 'Caucasian' author more of a pass, which belies the argument that law firm recruitment is a meritocracy.

The graders themselves were quite diverse, and we noticed that even the partners from minority backgrounds were more critical of the 'African-American' author than the 'Caucasian' one.

Bias exists, even when the person holding the bias is themselves a minority. It manifests itself in every major juncture in a person's career trajectory. In job interviews, hiring managers spend three times as much time chatting to someone who looks like them than someone who doesn't, and studies indicate that someone with an 'ethnic'-sounding name is far less likely to get a callback than someone whose name sounds 'white.' Similar biases exist at every stage of the recruitment pipeline and if the profession is serious about addressing diversity and inclusion it has to address these issues head on.

CA: What progress has the profession made? 

JW: I think the fact that we're talking about this now, and that people are talking widely about issues of bias and inclusiveness is itself progress. It's a precursor to practical, meaningful change. Understanding of implicit bias is still in its infancy. There are so many well-intentioned programs that focus on bringing people in, but it won't matter until inclusiveness and bias gain the attention of decision makers.

There are very purposeful efforts underway to make sure that clients send work to the extraordinarily talented diverse lawyers already out there. This helps those lawyers build their books of work, but it also shows the business case for diversity. When you take diverse lawyers off the shelf, dust them off and put them to work, you get an extraordinary work product. Most diverse lawyers are under-utilized, under-appreciated and don't have the same large institutional clients competing for their attention. Their level of responsiveness, attention to detail and quality of their work product is simply tremendous.

Duane Morris LLP

30 South 17th Street,
PA 19103-4196
Website www.duanemorris.com

  • Head Office: Philadelphia, PA
  • Number of domestic offices: 21
  • Number of international offices: 8
  • Partners (US): 362
  • Associates (US): 286
  • Summer Salary 2017  
  • 1Ls: $2,692/week (Phila/Baltimore/NY)
  • 2Ls: $3,077/week (Phila/Baltimore/NY)
  • 1Ls hired? Yes, 1
  • Split summers offered? Case by case
  • Can summers spend time in overseas office? Case by case
  • Summers 2016: 17 (15 2Ls, 2 1Ls)
  • Offers/acceptances 2015: 17 offers (100%), 17 acceptances

Main areas of work Business reorganization and financial restructuring; corporate; employment, labor, benefits and immigration; energy, environment and resources; wealth planning, health law, intellectual property, litigation and real estate Firm profile Duane Morris LLP, a global law firm with more than 700 attorneys in offices across the United States and around the world, is asked by a broad array of clients to provide innovative solutions to today’s legal and business challenges.

Recruitment details
• Number of 1st year associates: 11
• Number of 2nd year associates: 12
• Associate salaries: 1st year: $125,000-$160,000
• 2nd year: Non lock step compensation structure in place
• Clerking policy: Yes Law

Schools attending for OCIs in 2016:
University of Baltimore, Boston College, Boston University, Georgetown, Harvard, Howard, University of Maryland, Michigan, NYU, Penn, Temple, Villanova, among others.

Summer details  

Summer associate profile:
Duane Morris strives to attract the best law students and to offer the ideal environment for lawyers at the beginning of their professional lives. We endeavor to improve our Summer Associates Program each year to make Duane Morris a meaningful and valuable destination for summer associates. The firm’s summer associates rated the firm’s program #12 nationally in The American Lawyer’s 2015 Summer Associates Survey and a #1 ranking in the Philadelphia City ranking for 2015. Duane Morris offers interesting challenges to law students who participate in our summer program. We believe the program offers a realistic picture of our practice to aspiring attorneys who have an interest in sharing our goals and serving our clients. Our program balances challenging work assignments with constructive feedback, work-related activities outside the office and enjoyable social events.

Summer program components:
The growth and development of each Duane Morris attorney furthers the central goals of the firm to provide the best legal services possible, to develop and build client relationships, and to ensure the stature and reputation of the firm with its clients. Duane Morris’s Attorney Professional Development Program provides its summer associates and associates with comprehensive training and mentoring to support development of individual knowledge, skills and abilities in three broad categories: legal skills and substantive law, best business practices for the firm and practice development. Aside from these specific responsibilities, the mentors help introduce the summer associates to other lawyers in the firm and provide general guidance on any matter, whether or not related to particular work assignments.