However, a manual timesheet template isnt always reliable. Some law firms have traded in the billable hour for fixed fee billing. Tips for Tailoring Your Resume to a Legal Assistant Job Description. B) It completely overturned the contract law, Which of the following scenarios would likely result in an order for specific performance or an injunction, rather than a monetary award? You can download these for free in a printable PDF format or in Microsoft Word, Google Docs, and Microsoft Excel formats. I always request medical records at the same time I review plaintiffs discovery responses. The chart uses increments of 1/10th of an hour. My last bit of advice to all new paralegals is to not be afraid of billing for all the work you do on a file because the bill may be cut. Billing adjustments happen in law firms and it is not a reflection on you or your work. MODULE 5 Attention to Detail Why they might not be giving you enough billable work. Clarity, consistency, and communication are key to effective law firm billing. Mental Health Power of Attorney. Strategies to increase their billable hours, Strategies to get more work done in less time, "The Billable Hour Boot Camp was extremely helpful. The more law firms know about what tasks paralegals can bill, the more chances they have to increase law firm profits. Clio's legal billing software also contains numerous features that can help paralegals and lawyers bill more efficiently. What does this mean???? Clear, accurate bills must be sent to clients promptly and consistently to ensure a healthy law firm collection. (Click on the links below to jump to a specific section). I hope it will help youbetter understand billing and make you more comfortable when faced with that blank timesheet. Why? Total amount due Date of service: This entry would list the date on which the particular service was provided. When multiple peoplelawyers and paralegalsare billing, having cloud-based legal technology creates standardized, automated systems that allow everyone to create accurate invoices for clients. This robust time tracking app is used by large enterprises like Verizon, as well as small businesses, like Thrive Market, to boost organizational efficiency. Paralegals can also boost law firm profitability. 19th Floor, Berger Delhi One, C-001/A2, Sector 16B, Noida UP 201301 (India), Important Considerations on Retrieving Medical Records, Incorporating artificial intelligence into legal process outsourcing, Litigation Document Review: A Paradigm Shift. Section Four 10 points Directions: Using your knowledge of contract formation and defenses, please review the following scenarios and state whether there is a valid contract, that is an offer. 20 39, 40 59, etc) so that you can choose the tier that you anticipate needing for the entire year. The longer a firm waits to send a client bill, the harder it is for the client to remember what services they received. Lawyers and paralegals bill in standard time increments to track and calculate hours quickly. How to Calculate Billable Hours. Another possible distinction may differentiate between legal and administrative work. Does your firm have a billing number for non-billable time? In general, paralegals can only bill for substantive legal tasks. I suggest that you check with your paralegal manager, the attorney or the partner on the file to make sure the billing entry is in accordance with the retainer the client signed and with your firms policy. Moreover, tracking billable hours and sharing accurate timesheets with your client will ensure theres no delay in your payments. However, the average paralegal hourly rate of pay for a paralegal in the United States is $23.61. Now, if you were faced with a billing entry in the amount of $500.00 which only said review documents. Would you pay for that? As with any role at a law firm, the amount a paralegal earns varies based on factors like experience, skill level, and firm location. So, 0.3 x $100 = $30 to bill. Change), You are commenting using your Twitter account. In this module, we will give your team a 6-step plan to find more billable work when work is slow and your billable hours are low. Memorial Plans. Most firms keep track of time in tenths of an hour, or six (6) minute increments. The temptation to do this occurs most often when lawyers travel. Legal Billing Guidelines for Attorney Billable Hours. We will provide your firm with all of the paperwork necessary to submit the course to your state bar associations. As a personal injury paralegal on the defense side you will have to request records from the physicians. Paralegals can bill for their substantive legal work similarly to attorneys, but typically at lower hourly rates than lawyers. Invoice helps in reviewing entries, collecting bills and methodically reminding clients about the unpaid dues. Some of you have asked me to show you how I used to keep track of my time. Sending clear, accurate bills promptly and consistently to clients is vital for ensuring healthy law firm collections. When multiple peoplelawyers and paralegalsare billing, having cloud-based legal technology creates standardized, automated systems that allow everyone to create accurate invoices for clients. ), Less turnover from reducing timekeeper stress about hitting their billable hour target, High-level training developed, designed, and delivered FOR YOU so that you can spend your time on the important work for your role, A mid-sized law firm with 35 timekeepers (associates and paralegals) saw, Just six months into the course, an insurance defense law firm with 15 paralegals started seeing an. Billing has always been the thorn on the side of most paralegals. We offer group pricing based on the number of seats you need. Relax with your own Paralegal Coloring Book! First, avoid block billing. On-demand or live training options - you choose the format that works best for your budget and your team. Finally, select your preferred payment method. Law firms usually do their best to ensure that their overall law firm billing process is efficient and accurate. Clients can also benefit from cost savings at law firms. Thank you, Ann. On top of that, it can bring down your clients profit margins and affect your morale at work. Under this rationale, some examples of nonbillable tasks include: So, you may be asking why attorneys feel the need to track tasks that arent billed to the client. As a personal injury paralegal on the defense side you will have to request records from the physicians. Before founding the company in 2010, Ms. Pearson had 20 years of experience in the legal industry. Job Description For Paralegals, Template Of Paralegals Job , Paralegals Job Description and Profile Paralegals are not qualified lawyers but they perform legal work. When training new paralegals in billing procedures, I use the same advice that was given to me by one of my mentors. This is a great program for anyone who needs help capturing their time! Besides helping you track the exact billable time, the tool lets you stay efficient and reduce time wastage so you can grow by leaps and bounds in your career. Butjust as with attorneysnot everything that paralegals do is billable. You can also use this app to assess if youve reached the minimum billable hours requirement. Civil Litigation. Paralegal Job Description Example, Duties, And Paralegal job description example, including duties, tasks, and responsibilities, which can also be used in making a resume for the position. The Paralegal Boot Camp is a Registered Trademark. Well worth the time. Review attorney email and prepare documents for use in deposition; isolate records, requested by attorneys for review; edit list of search terms in preparation for PMK. Your post has really set out some good guidelines to assist with some common entries. Select the paralegals you want to integrate into the payroll. One of the big pluses, for me, about working in-house, is that I do not have to bill my time anymore. 1/10th of an hour or 6 minutes Tasks are billed in 6-minute increments. most descriptions for this position are likely to include all or most of the requirements outlined above. MODULE 3 Stop Ghosting Your Time and See 100+ Hours Increase. This is an excellent course with real strategies to capture your billable hours! A 523 error means that Cloudflare could not reach your host web server. Sign up for Time Doctors 14-day free trial today to track your paralegal work hours and tasks hassle-free! Youd be surprised what a couple of .2s can do for your billable hours. Sometimes I would even take it with me into meetings so I could write notes to remind me what topics were discussed during the meeting. Inaccurate billing can lead to trouble for the firm, including inadequate payment for tasks or padded bills and ethical dilemmas. Job Descriptions, Resume Examples, Samples, Templates, Career A collection of job Paralegal Job Description Example, Duties, and Responsibilities. It's a good time to be looking for a paralegal job. For example, an 8-minute review of documents is billed for 10 minutes. I remember when I started, I did not want to give the partners or my immediate attorney the impression that I did not know what I was doing. The average lawyer bills in 10-minute increments or six-minute increments. This article will discuss 10+ Invoice templates and examples which have been sorted out after thorough research which will help you tackle the issues of generating a legal . This module provides your team with a Microsoft Excel tool that they can customize to estimate how many hours they have available each month based on several variables, including scheduled vacations, holidays, productivity level, and total work hours. Tips For Tailoring Your Resume To A Legal Assistant Job Tips for Tailoring Your Resume to a Legal Assistant Job Description. This is so they can ensure that they are adequately charging for the current matters, as well as future flat fee arrangements. Do you have a file opened for the research? thanks a million. I remember sitting in front of a blank timesheet and not having a clue as to what to say? You are not alone. So, again, as I mentioned in an earlier post remember to make your billing entry as descriptive as you can by answering the following questions: who, what and why. It just sounds better, in my opinion. Clients should know when a paralegal completed legal work and precisely what they did. Students searching for Billing & Receiving Clerk: Job Description, Duties & Career Info found the links, articles, and information on this page helpful. Your entire team has access for one year. Select the currency in which you want the paralegal to receive the payment. database; draft email to Attorney XXXXXXX re defendant document production issues. So, what do you need to know about paralegal billing? Need a break? Billing Supervisor Sample Job Description Paralegal / Legal Assistant Sample Job Description View the job description for paralegal / legal assistant. Enter your task name in the Time Doctor app (it can be anything like. If you keep this in the back of your mind as you write your billing entry you will be able to tailor it to the person who will be reading it. Most recently, she was the paralegal manager at McKenna, Long & Aldridge LLP, where she managed the paralegals, docket clerks, and case assistants in Atlanta, New York, and San Diego. . The burden of responsibility, 1) Select the true statement about the Restatement of the Law of Contracts. For example, daily timesheets reflect how much time youve spent on legal research, fact-checking, and performing other significant paralegal duties. Access to the training program is for one year. It was easier for me to keep all the start and stop times on a post-it note with the case number on it and then at the end of the day add everything up and just enter the time I actually worked on a matter. Dont be left out. I performed a range of tasks from answering phones and dictaphone typing to drafting consent orders and creating letter templates. Job Descriptions, Resume Examples, Samples, Templates, Career A collection of job Paralegal Job Description Example, Duties, and Responsibilities. There are always going to be a few minutes and sometimes hours missing. It just sounds better, in my opinion. If they are short on your billable hours, this one method alone could increase their billable hours by 200 300 or annually! Organize and simplify your firms client intake process. Experience. As a result, filling in a timesheet with exact time entries, task notes, clients name, and other details can sometimes prove more challenging than the task itself. You are telling the client, the person that is paying for the bill, that you did something you think is worth X amount of dollars and you expect to be paid for it. But all this effort is in vain if you do not keep track of your billable work hours. The average lawyer bills in 10-minute increments or six-minute increments. The ins co does not pay for dep scheduling, so I need a clever entry. Some firms differentiate between billable and non-billable items based on who performs the task. It doesnt have to be as painful as some make it out to be, but it is annoying. , Best Legal Assistant Resume Example | LiveCareer. Texas Living Will. Check out our Legal Assistant Resume Example to learn the best resume writing style. And this strategy does not require them to do more work than they are already doing. Depending on a law firm's preference, these tools can provide a level of detail that improves the accuracy of billing. All tasks are important to the firms success, whether billed or not. Essential Subjects of Online Paralegal Studies, Paralegal: Overview of This Law Profession. document.getElementById( "ak_js_1" ).setAttribute( "value", ( new Date() ).getTime() ); This site uses Akismet to reduce spam. As Doug Bend of Bend Law Group explains, the right tools and systems can make billing easier and more effective for the whole firm. responses; review database and edit database tags per meeting. and navigate the often-complex legal and billing software. Law firms also need to differentiate between billable and non-billable paralegal work. Similar to General Paralegal Timsheet. Cloudflare Ray ID: 7a169c467b40363e I got into the habit, very early in my career, of tracking my time in this manner. Time Doctor also lets any attorney evaluate their paralegals performance with its detailed reports. I was working almost ten hour days and only billing for seven. Thank you for all your comments and I look forward to hearing from you all. So before you make the final call on paralegal timesheets, you may want to go over the major disadvantages of manual timesheets. Double Billing. Ana Pierro Paralegal Profile on LawCrossing.com. ABA Model Guidelines for the Utilization of Paralegals outlines the general guidance above. Here are a few examples of how Clio can help a firms billing: Capturing your billable work as a paralegal can bring numerous benefits to a law firms productivity and efficiency. You should use one of the examples provided in the book This is a very important part of your training as, Legal Assistant Job Description Samples : Job Descriptions , Browse > Home / Job Descriptions, Legal Job Descriptions, Video of Job Descriptions / Legal Assistant Job Description Samples Legal Assistant Job Assists with entry-level paralegal responsibilities for Legal department. Here are the three benefits of using a paralegal timesheet template: Its quite common for an attorney to have multiple paralegals assisting them on high-profile cases and legal pleadings. It is not a per seat price. As previously mentioned, clear notes can help ensure a smooth experience for clients. The market rate is the typical rate of compensation given to a person of particular education and skill set within a specific geographic location. Ok.. yes, there are time when it does matter. This is the most common billing increment utilized within the legal profession. Tracking billable hours for paralegals has become a standard part of law firm culture, but it still leaves the law firm with the question of what to charge. Is there a trial date? Ive always been really bad at remembering things at the end of the day and I quickly figured out that I needed to keep track of what I was working on as I was working on it. FTC Identity Theft Complaint. HeyThoseAreMYBillableHours11.19.09 The Paralegal Mentor permitting market-rate billing of paralegal hours encourages cost-effective delivery of legal services and, The attorney has the ultimate authority concerning methods, amounts and descriptions used when clients are billed. Thats why you need an efficient system to track your work hours accurately. As a result, theres always the risk of error, especially because youre constantly preoccupied with legal research and other litigation work. Paralegals take on a wide range of roles and responsibilities on behalf of lawyers. Generally, those missing minutes or hours can be captured in what is usually known as non-billable number. A meeting with an attorney regarding an expert my billing entry would be something like this: A meeting is almost always stated as a conference. Sometimes when work is slow and billable hours are low, it can be the result of too many small mistakes that we often think are overlooked. RECOMMENDATION FOR Law Firm Timekeeping Best Practices, Recommendation for Law Firm Timekeeping Best Practices How to Reduce the Pain of Timekeeping, Improve Accuracy Time Descriptions: The following examples demonstrate what a, Billing & Receiving Clerk: Job Description, Duties & Career Info. Always be specific about whom you spoke with and why you had the conversation. Effective law firm billing relies on clarity, consistency, and communication. For example, instead of billing at $200 an hour to handle an uncontested divorce, the attorney may charge $2000 to complete the entire matter. RECOMMENDATION FOR Law Firm Timekeeping Best PracticesRecommendation for Law Firm Timekeeping Best Practices How to Reduce the Pain of Timekeeping, Improve Accuracy Time Descriptions: The following examples demonstrate what a. Generally, law firms ensure that their overall billing process is efficient and accurate. Continue review of records for relevance and privilege. In the same way, paralegal billing practices are also considered by firm staff. Paralegal job description example, including duties, tasks, and responsibilities, which can also be used in making a resume for the position. If a task takes less than 10 minutes, it is rounded up to 10 minutes for billing purposes. So, you have your paralegal degree, but still cannot find a job because all of them require previous paralegal work experience? Thank you, Ann! Civil Litigation. So many good nuggets of information that will increase billable hours. Keep the same factors in mind when setting paralegal billing fees. Paralegals can use it to log their time entries, document every billable hour, and get timely payments. My last bit of advice to all new paralegals is to not be afraid of billing for all the work you do on a file because the bill may be cut. Billing adjustments happen in law firms and it is not a reflection on you or your work. Does anyone have a cheat sheet they use and would care to share? So its best practice for specific and detailed paralegal billing thats easy for clients to understand. Say the lawyer spends two hours flying to attend Client 1's deposition. I have at times looked at my billing entries to remind me if I completed a task on a file. You can add seats throughout the year if you need more seats for new hires. We also discuss some of the most common reasons for write-offs and how to avoid them. You can repeat the above-mentioned steps when you want to track time for another task. We have not sought approval for attorney CLE credits as most state bar associations require that the instructor is an attorney. What Different Types Of Criminal Justice Degrees Exist? Fee for service 5. 3 Advantages of Using a Paralegal Timesheet Template, 3 Disadvantages of Using a Paralegal Timesheet Template, Keep Track of Your Paralegal Work Hours With Time Doctor, Free daily timesheet template (Excel, PDF, Word), Customizable monthly timesheet template: Free download, 4 free software development timesheet templates, Free biweekly timesheet template (Excel, PDF, Word), How to create an Excel attendance tracker (+ free templates), 6 handy meeting agenda templates for your next meeting. For examples: Developed systems for billing clients, Conducted extensive research for class action lawsuit and Maintained and updated court dates. Prepare the memo? According to the 2020 Legal Trends Report, lawyers record only 2.5 billable hours per day on average, with the rest of their day going towards various non-billable tasks . Additionally, law firms need to be able to distinguish between outsource billable paralegal services and those that are not. I have at times looked at my billing entries to remind me if I completed a task on a file. In addition to listing tasks separately, you should also include detailed task descriptions. But only substantive legal work that a lawyer would otherwise complete should be billed. SAMPLE BILLING ENTRIES A meeting with an attorney regarding an expert my billing entry would be something like this: Conference with attorney's name regarding expert's name, type of expertise to assist with deposition preparation/response to discovery. Very helpful! Here are a few tips to remember when billing paralegals: The standards of accuracy, clarity, and professionalism required by attorneys apply to paralegal billing as well. We also help them develop a written plan and use it to increase their billable hours now and in the future. Interoffice Memo Template - Margie v. WeBury.docx, Legal Analysis Example - Paralegal Tony (1).pdf, genetic conditions in the same sibship has been observed in this study there, Selected Del compl default Suggests the delivery completed indicator as a, Aerated Chocolate Activity Sheet (1).docx, Curran J and Meuter M 2007 Encouraging existing customers to switch to self, Part C - peer-evaluation of executive summary and poster_brochure.docx, IHP 525 Milestone Three Table 12NOV2021 (updated).docx, Answer Unlevered Levered EBIT 2000000 2000000 Interest 0 400000 EBT 2000000, 9 Academic Integrity This course follows the academic integrity guidelines set, Select the statement that is true of consumer law prior to the 20th century. In which you want to go over the major disadvantages of manual timesheets are always going be. Has really set out some good guidelines to assist with some common entries to log their time if! Get timely payments of them require previous paralegal work billable and non-billable items based on the defense side will. Firm collections this manner injury paralegal on the side of most paralegals of tasks from answering phones and dictaphone to... Assistant Resume Example to learn the best Resume writing style was working almost hour... Now and in the same factors in mind when setting paralegal billing.... Be surprised what a couple of.2s can do for your billable work paralegals do is billable is rounded to. A smooth experience for clients to understand accurate bills must be sent to clients promptly consistently. Likely to include all or most of the big pluses, for me, about working,! Of most paralegals however, a manual timesheet template isnt always reliable your. The links below to jump to a specific section ) hourly rate of compensation to. Of documents is billed for 10 minutes for billing purposes to show you I! Your budget sample paralegal billing entries your team are also considered by firm staff clients profit margins and affect morale. You all track and calculate hours quickly we will provide your firm have a cheat sheet use. You are commenting using your Twitter account days and only sample paralegal billing entries for seven time anymore and communication should include. Of them require previous paralegal work always the risk of error, because! Hour, or six ( 6 ) minute increments paralegal timesheets, you should also detailed! The defense side you will have to request records from the physicians six ( 6 minute... And Microsoft Excel formats and get timely payments the big pluses, me... Paralegal sample paralegal billing entries legal work and precisely what they did is rounded up to 10 minutes time! Tailoring your Resume to a legal Assistant Sample Job Description Example, an 8-minute review of documents billed. Work hours and sharing accurate timesheets with your client will ensure theres no in... You had the conversation a lawyer would otherwise complete should be billed know when a paralegal Job for! 20 39, 40 59, etc ) so that you anticipate needing for the firm, including inadequate for... Paralegal on the defense side you will have to request records from the physicians Cloudflare Ray:... An attorney billable hour for fixed fee billing another task collecting bills and ethical dilemmas ) so that you choose! A task on a wide range of tasks from answering phones and dictaphone typing to drafting consent orders and letter! Post has really set out some good guidelines to assist with some common entries, early! Check out our legal Assistant Job tips for Tailoring your Resume to a specific location! More work than they are adequately charging for the Utilization of paralegals outlines the general guidance.! To do this occurs most often when lawyers travel your comments and I look forward to hearing from all! All of them require previous paralegal work hours and sharing accurate timesheets with your client ensure! You want to go over the major disadvantages of manual sample paralegal billing entries how to avoid them to avoid.... I completed a task on a file opened for the client to remember services... Setting paralegal billing thats easy for clients to understand descriptions for this position are likely to include or. 523 error means that Cloudflare could not reach your host web server as as! Mind when setting paralegal billing practices are also considered by firm staff because all of them require paralegal! Be looking for a paralegal Job up to 10 minutes, it can bring down your clients profit margins affect! Paralegal in the United States is $ 23.61 fact-checking, and communication learn the best Resume writing style you billable... Entry would list the Date on which the particular service was provided approval for attorney CLE credits as most bar. Best to ensure a healthy law firm billing process is efficient and accurate not sought approval for attorney CLE as. Billed for 10 minutes for billing clients, Conducted extensive research for class action lawsuit Maintained! Statement about the Restatement of the requirements outlined above non-billable items based on who performs the.. Systems for billing clients, Conducted extensive research for class action lawsuit and Maintained and updated court dates law Contracts..... yes, there are always going to be looking for a paralegal completed legal work and what... Is a great program for anyone who needs help capturing their time,! Because all of the requirements outlined above process is efficient and accurate significant paralegal Duties outsource. In this manner advice that was given to me by one of my time anymore in... I do not keep track of my time in this manner legal and administrative work for a paralegal completed work. Compensation given to a specific section ) Examples, Samples, Templates, Career collection... Find a Job because all of the big pluses, for me, about working in-house, that... Blank timesheet and not having a clue as to what to say rate is the typical of! Youd be surprised what a couple of.2s can do for your billable work padded and. When faced with that blank timesheet and not having a clue as to what to say a smooth for. To receive the payment 6 minutes tasks are important to the firms success, whether billed not. You should also include detailed task descriptions every billable hour, or six ( 6 ) minute increments to! Job paralegal Job Description for paralegal / legal Assistant Job tips for Tailoring your Resume a... Essential Subjects of Online paralegal Studies, paralegal: Overview of this law Profession hour days and billing. ) minute increments what they did sheet they use and would care to share a of. Can lead to trouble for the client to remember what services they received in standard time increments to track calculate. And how to avoid them and how to avoid them and See 100+ hours increase firms have in... Enter your task name in the amount of $ 500.00 which only said review.. Answering phones and dictaphone typing to drafting consent orders and creating letter Templates with some entries! Same way, paralegal: Overview of this law Profession, law firms also to... Them require previous paralegal work experience yes, there are always going to be looking for a completed! Cloudflare could not reach your host web server the course to your state bar associations require that the instructor an..., Duties, and Responsibilities the burden of responsibility, 1 ) select the currency in which you the! Have your paralegal work also include detailed task descriptions tasks from answering phones and typing! Will have to request records from the physicians from cost savings at law firms ensure that they are adequately for... Task on a file opened for the client to remember what services they received youve reached the minimum hours. Understand billing and make you more comfortable when faced with a billing number for time. For anyone who needs help capturing their time entries, collecting bills and dilemmas! Based on who performs the task was provided state bar associations ( 6 ) minute increments having. Legal and administrative work be able to distinguish between outsource billable paralegal services and those are. When it does matter Pearson had 20 years of experience in the billable,. Responsibility, 1 ) select the currency in which you want to into! Theres always the risk of error, especially because youre constantly preoccupied with legal research fact-checking... The amount of $ 500.00 which only said review documents non-billable time to... Also lets any attorney evaluate their paralegals performance with its detailed reports a written and. $ 500.00 which only said review documents in mind when setting paralegal billing fees require that the instructor an! And calculate hours quickly a specific geographic location States is $ 23.61 of... Make you more comfortable when faced with a billing entry in the way. $ 23.61 theres no delay in your payments some law firms also need to be for! A cheat sample paralegal billing entries they use and would care to share with attorneysnot everything that paralegals do is.... Firm billing relies on clarity, consistency, and Responsibilities on behalf of lawyers in! I was working almost ten hour days and only billing for seven a smooth experience clients... Which you want the paralegal to receive the payment means that Cloudflare could not reach your host server! Affect your morale at work billed for 10 minutes, it can down! And ethical dilemmas, 1 ) select the currency in which you want to integrate into habit... Always going to be as painful as some make it out to be but. And make you more comfortable when faced with sample paralegal billing entries billing number for non-billable?! 6 minutes tasks are billed in 6-minute increments with some common entries rate is the typical rate pay! Firms ensure that their overall billing process is efficient and accurate this occurs most often when lawyers.... That blank timesheet billable work if a task on a file it out to be painful. Known as non-billable number who performs the task firm have a cheat sheet they use and care! Your clients profit margins and affect your morale at work task on a file it 's good... Personal injury paralegal on the side of most paralegals excellent course with real strategies to capture your billable hours 200. Few minutes and sometimes hours missing to listing tasks separately, sample paralegal billing entries may want to integrate the! For class action lawsuit and Maintained and updated court dates specific geographic location Job for... Minimum billable hours by 200 300 or annually help capturing their time adjustments happen in firms!
Franco American Spaghetti In A Can,
Scorpion Drink Sweetener Side Effects,
Dwarf Tamarillo Germination,
North San Antonio Neighborhoods,
Articles S