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The official blog of the NALS docket, used as a timely resource for sharing content from our email newsletter. This includes Grammar Nuggets, Career Corner, chapter and members spotlights, and more! Articles are written and provided by our own members, Resource Center Staff, and our community of legal professionals. All content and articles will be published directly to our NALS.org website and linked to the NALS docket newsletter. This email venue for NALS will inform you of upcoming deadlines and monthly education product highlights from our online store. Copy + paste this link to sign up for updates: https://visitor.r20.constantcontact.com/manage/optin?v=001JH2FKM034UVKDAYd6vkCfwIybKDCjBA-5dH7wJhSTjXN-eWSgRsnK6Q_LdfewGHvnwcVoakgipMvhoKPHed-94e5siy7js7FrJp_sV9e8Aw%3D


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Finding Time for Professional Development

Posted By NALS Editorial Board, Friday, November 18, 2016
Dear Eula Mae:



I just started working in a large, very busy law firm and it is my secret desire to be an excellent legal secretary.  Everyone is so busy that I do not know whom to ask or what to say to improve my skills.  This is a great job for me because I am shy and do not mind reading a lot to learn more.  There is not much spare time at all on the job, but I can squeeze in about 15 minutes of reading time at lunch.  I belong to a professional organization, NALS, but our meetings are only once a month.  What can I do to get better at my job?


Shy in Kansas



Dear Shy in Kansas:


The fact that you desire to be great at your job will bring you greatness!  Even if you only have 15 minutes a day, that is a great place to start!  That makes an hour and 15 minutes a week of education and skill-polishing!  That is 60 hours a year of knowledge.  A good place to start your educational journey is with your boss.  Set up an appointment to visit with the boss about your current skills and ask what skills you could develop further.  If you are too shy to talk with your boss just yet, start on your own.  Watch for the Basic Legal Training Course offered through NALS.  Becoming certified as a legal professional is a big deal and demonstrates your commitment to professionalism.  Another way to gain skills is to look for online resources.  One skill always needed is the ability to find information fast, especially if you are proofreading.  English grammar needs steady attention.  You can develop that skill through websites like http://proofthatblog.com/ and http://www.quickanddirtytips.com/grammar-girl.  For general office skills, you could subscribe to newsletters such as http://www.adminprotoday.com/ and http://paralegalmentor.com/.  The Paralegal Mentor, Vicki Voisin, has a fantastic resource titled 151 Tips for Your Career Success.  (Yours truly still reads this every six months to recharge.)  This is your journey and you will do a great job because you want it.  Enjoy!


Eula Mae

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Bullying in the Workplace: Identifying the Types—Have You Met One?

Posted By Charlene Sabini, CLP, ALP, Friday, November 18, 2016

Bullying in the WorkplaceIs there currently a U.S. law against workplace bullying?

The United States is last among the industrialized western democracies. The U.S. completely ignores workplace bullying in its vast collection of laws.

Is there a law in my state?

No state has an anti-bullying law for the workplace. Remember, there is a big difference between having a bill or bills introduced (potential laws), compared to laws that have been passed by both houses in the state legislature and signed into law by the governor.[1]

These are questions and answers we do not want to see. But we do.

So, don’t we already have federal employment discrimination laws that might also cover bullying? In only 20% of cases do our anti-discrimination laws actually apply. This is difficult to understand. In order to claim sexual harassment, racial discrimination, or hostile work environment, the recipient of the mistreatment must be a member of a protected status group (based on gender, race, disability, ethnicity, religion, etc.). For example, a white female bullied by a white female (or a man of color bullied by another man of color) are not protected. “Technically, bullying is a form of violence—certainly verbal, but non-physical. One of our preferred synonyms for workplace bullying is ‘psychological violence.’ However, violence policies and laws always focus on the acts and threats of physical violence—striking someone (battery), or threatening someone so that they fear being physically hurt (assault). The one exception is the inclusion of verbal abuse in violence policies. So bullying that is verbal, but not physical, is completely legal.”[2]

Let’s further define this kind of bullying:  workplace bullying is a repeated, health-harming mistreatment of one or more persons by one or more aggressors. It is clearly abusive conduct that is threatening, intimidating, or humiliating. It can also be interference with one’s work or sabotaging of one’s work, as well as various kinds of verbal abuse.[3]

It is often about control—control of the targeted person, not unlike domestic violence. It can be an act of commission or omission (withholding vital resources from the targeted person). It can escalate to involve others, and it ultimately undermines legitimate business interests when the bully’s personal agenda supersedes the work itself.[4]

The specific types of workplace bullying are many and often terrifying. One category is Threats to Personal Standing and can include:

  • Spreading rumors, hurtful gossip, or innuendos
  • Yelling, name-calling, mocking, insulting, or ridiculing
  • Unwanted physical contact or physical gestures that intimidate or threaten
  • Invalid or baseless criticism
  • Accusatory or threatening statements
  • Faultfinding or unwarranted blaming
  • Displaying offensive photos or objects
  • Temper tantrums, mood swings, or shouting
  • Humiliation, public reprimands, or obscene language
  • Ganging up against a coworker
  • Aggressive posturing

Another category is Threats to Professional Standing and can include:

  • Denying access to resources, assignments, projects, or opportunities
  • Stealing or taking credit for another’s work
  • Interfering with someone’s work performance
  • Failing to return phone calls or messages
  • Little or no feedback on performance
  • Withholding information essential to perform one’s job
  • Toxic emails
  • Flaunting status

Yet another is Control or Manipulation Tactics:

  • Failing to invite someone to an essential meeting
  • Threatening job loss
  • Excessive monitoring or micromanagement
  • Assigning tasks that cannot be completed by deadline; setting unrealistic goals
  • Interference or sabotage
  • Ignoring a coworker with the intent to harm or control
  • Treating a worker differently than peers and coworkers
  • Ostracism, isolation, dissociation, or exclusion from others
  • Refusal to take responsibility
  • Excessive, impossible, conflicting work expectations or demands
  • Inequitable and harsh treatment
  • Other objectionable behavior designed to torment, isolate, pester, or abuse

Example:  Angela:  Fired by a Bully

“I worked for the Law School Admission Counsel, the company which administers the LSAT. My boss never liked me and why she hired me is still unclear. She bullied me extensively, yelling at me in front of my coworkers, threatening my job privately in her office, and discouraging alliances with coworkers. She treated people similarly in other departments, yelling at them in meetings. I tried to appease her until she threatened my job . . .”[5]

And it is not unusual that the company bullies are visible to other employees in the company. They are the proverbial “elephants in the room,” not unlike perpetrators of domestic violence. In their battering way, bullies minimize, deny, sidetrack, and blame their targets, hoping to avoid accountability for their actions.[6]

Anton Hout, founder of OvercomeBullying.org, identifies eight bully types:

  1. The Screaming Mimi. This is the most easily recognizable type of workplace bully. Screaming Mimis are loud and obnoxious, and their abusive behavior is meant to berate and humiliate people. They thrive on the notion that others fear them.
  2. The Two-Headed Snake. To a coworker’s face, this employee acts like a trusted friend or colleague. However, when the coworker is out of earshot, this person will destroy his colleague’s reputation, stab him in the back, and even take credit for his work.
  3. The Constant Critic. This bully’s goal is to dismantle other people’s confidence through constant—and often unwarranted—criticism. A critic will look for any possible flaw in someone’s work and labors tirelessly to kill that person’s credibility. Impeccable work? No problem:  this type of bully is not above falsifying documents or creating evidence to make others look bad.
  4. The Gatekeeper. Every office has at least one employee who gets off on wielding his or her power over others—regardless of whether that power is real or perceived. Gatekeepers deny people the tools they need—whether it is resources, time, or information—to do their jobs efficiently.
  5. The Attention Seeker. This type of bully wants to be the center of the action at all times. They will try to get on their superior’s good side through consistent flattery and even come on as kind and helpful to their peers—especially the newer employees. However, if coworkers do not provide the right amount of attention, these bullies can quickly turn on them.

    Attention seekers are often overly dramatic and relate everything to something that is going wrong in their own lives to garner sympathy and control. These bullies also have a tendency to coax personal info out of new employees—only to use it against them later.
  6. The Wannabe. This is an employee who sees himself or herself as absolutely indispensable and expects recognition for everything. But Wannabes are not usually very good at their jobs. To compensate, these bullies spend a majority of their time watching more competent workers and looking for areas of skilled workers’ performance to complain about.

    Wannabes will demand that everything is done their way—even when there are better ways of doing things. Because they are automatically opposed to others’ ideas, they will do everything in their power to prevent changes to their work processes.
  7. The Guru. Generally, there is nothing wrong with this bully’s work performance. In fact, it is not unusual for a Guru to be considered an expert in his or her own niche area. What these bullies offer in technical skill, however, they severely lack in emotional maturity.

    Gurus see themselves as being superior to their coworkers. As a result, they do not consider how their actions will affect others, are not able to fathom the possibility that they can be wrong, and do not accept responsibility for their own actions. In addition, because these bullies feel as though they are “above it all,” they do not always feel compelled to follow the same rules as everybody else.
  8. The Sociopath. Intelligent, well-spoken, charming, and charismatic, sociopaths are the most destructive bullies of all. Reason: They have absolutely no empathy for others, yet they are experts at manipulating the emotions of others in order to get what they want.

    These bullies often rise to positions of power within the company, which makes them extremely dangerous. Sociopaths tend to surround themselves with a circle of lackeys who are willing to do their dirty work in exchange for moving up the ranks with them.

The best defense a company can have against workplace bullying is a clearly worded policy that prohibits any type of bullying behavior.[7]

Clearly, workplace bullying can take many forms and wear many guises—all unpleasant and all destructive. There is no federal law that applies to bullying specifically. In some cases, when bullying is based on race, color, national origin, sex, disability, or religion, “bullying” overlaps with harassment and schools are legally obligated to address it. Here in Oregon matters of workplace bullying overlap somewhat with bullying phenomena primarily at schools and universities:  the terms used in the Oregon anti-bullying laws include harassment, intimidation, or bullying, and this covers cyberbullying as well. The following groups are listed under Oregon educational anti-bullying law:  race, color, religion, sex, sexual orientation, national origin, marital status, familial status, disability, and source of income.

“Although a number of states have considered anti-bullying legislation, none has yet to pass such a law. That does not necessarily mean bullying is legal in every situation, however. Bullying is illegal when it violates federal or state laws prohibiting discrimination and harassment in the workplace.” (These laws protect employees from harassment based on the previously mentioned characteristics.) “If a workplace bully is targeting an employee based on a protected characteristic which could qualify as illegal harassment, the employee would have a ‘hostile work environment’ claim if the unwelcome conduct is severe or pervasive enough that a reasonable person would find it to be offensive, hostile, or abusive. To date, neither federal law nor the law of any state prohibits workplace bullying outright.”[8]


  1. http://www.healthyworkplacebill.org/faq.php, The Healthy Workplace Bill, by Gary Namie, Director, last viewed October 22, 2016

  2. Ibid.

  3. http://www.workplacebullying.org/individuals/problem/definition/

  4. Ibid.

  5. https://www.thebalance.com/types-of-bullying-2164322, Sally Kane, July 25, 2016, last viewed October 22, 2016

  6. Ibid.

  7. http://www.hrmorning.com/8-workplace-bully-personality-types/, Tim Gould, July 19, 2016;  last viewed October 22, 2016

  8. http://labor-employment-law.lawyers.com/employment-discrimination/workplace-bullying-the-meanest-of-the-mean.html, Lisa Guerin, J.D., Boalt Hall at the University of California at Berkeley, last viewed October 23, 2016

Charlene Sabini, CLP, ALP, is legal assistant for attorney David Vill in juvenile law matters in Eugene, Oregon. She is Director of Education for her local chapter, NALS of Lane County in Eugene, and has enthusiastically occupied that position for over four years. She is editor of her chapter’s bimonthly newsletter, NALS in Motion, which has been published unfailingly for nearly four years. She has earned three successive NALS CLE Awards and plans to sit for the PP exam in March 2017. She is a proofreader on the NALS Editorial Board and has contributed articles/essays for the NALS docket and @Law. Charlene is an affiliate member of the Lane County Bar Association and was responsible for initiating that level of membership with the bar for nonlawyers in 2014. She also petitioned the Oregon State Bar Association to allow guest speaking attorneys at nonlawyer education meetings to receive CLE credit (which was formerly not allowed in Oregon) and was successful. She is also a 13-year volunteer with the Lane County Sheriff’s Office in Eugene, has served as the county sheriff’s newsletter editor, and is currently serving as the county jail librarian. The Oregon State Sheriff’s Association/Jail Command Council awarded Ms. Sabini the Jail Volunteer of the Year award in 2009.

Tags:  legal  legal assistant  legal career  legal education  legal job skills  legal jobs  legal office  legal professional  legal professional training  nals  office procedures  paralegal  paralegal office 

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Why Join NALS?

Posted By Paula Steffey, PP, CLP-SC Civil Litigation, Thursday, November 10, 2016

Join NALSI recently hosted a rummage sale fundraiser for NALS of Greater Kalamazoo chapter.  After explaining to the customers what NALS is all about, I think I could give the speech in my sleep.  I have also been asked by members and nonmembers—why are you doing this?  It is so much work.  Well, not really.  That was one of the cheapest and easiest fundraisers to organize.  Besides, even if it was difficult, I would still do it because of everything NALS has done for me (especially my local chapter).   I am proud to say that I am a member of one of the best chapters in Michigan—NALS of Greater Kalamazoo. 


Every month we have a meeting where we can network with other legal professionals, obtain continuing legal education, and grow as individuals, both personally and professionally.  Of course, we also get to enjoy an amazing dinner and a different venue each month.  But there is more to this organization than just a dinner meeting and socializing.  


I wanted to join NALS for many years, but I could not afford the membership dues.  In 2014 I was working for a new employer who offered to pay the dues for me.  I did not take that benefit for granted.  I was determined to get involved in any way possible—from helping on various committees, attending legal education offered by our chapter and other chapters in Michigan, studying for my certification, and anything else that was available. 


In the past two years I have been mentored by many members at the local and state levels and have spoken with the staff at the national level on many occasions as I work to attain my goals within the organization.  Every level of this organization offers something valuable to its members.  


My local chapter, NALS of Greater Kalamazoo, has an excellent group of members who work hard for our organization. Because of everyone’s hard work, they have been able to provide benefits to their members that far surpass what I could have imagined when I first joined.  Currently, our chapter pays the examination fee to take the ALP, PLS/CLP, and PP exams, and it even pays for one retake.  Without the support, generosity, and hard work of the members throughout the year, I would not have been able to take the PLS/CLP exam (and the retake I needed to pass).  My chapter made it possible for me to sit for the PP exam at the end of September, which I passed! 


So what does that certification mean to an employer?  It means more than most employers will put into words.  My current employer loves the fact that his assistant wants a career and not just a job.  Since he and another attorney in our office helped me study, he sees what I am learning.  He is much more willing to share his knowledge and actually teach me.  Based on the change in my workload and the type of work I am now doing compared to when I first started, I believe he has found my certification to be very beneficial.  Even my former employers have assisted me with my studies and cheered for me.  One former employer has said numerous times how much change he has seen in me since I joined NALS. 


Okay, I have my certification, but then what?  In order to keep your certification, you need to complete 15 hours of continuing legal education every year in order to recertify when the certification expires. (To recertify every five years, the PLS/CLP and PP certifications require 75 CLE hours and 50 CLE hours are required for the ALP certification.) For any member who wants to go above and beyond, NALS now offers a Specialty Certificate so you can enhance your knowledge and skills in 21 different areas of law.  All you need is to obtain 50 CLE credit hours in one of those areas of law.  If you are going to work toward the Specialty Certificate, you might also work toward a CLE Award, which requires a minimum of 60 CLE credit hours within a three-year period.  This may sound like a lot of continuing legal education, but, trust me, it is well worth every hour.  Seeing the smile on my employer’s face when I showed him my CLE Award and Specialty Certificate was priceless. 


Maybe you want to get involved at the state or national level.  There are plenty of opportunities to do just that.  NALS of Michigan has a membership meeting every quarter and has an annual meeting and education conference.  NALS also has a national conference annually.  As a member of NALS of Greater Kalamazoo, I am able to take advantage of one more benefit—attendance at these events.  My local chapter not only makes certification possible, but they have made it possible to attend events at the state and national levels.  Thanks to our chapter, I was very excited to have attended my first national conference in October.


I could tell you so much about this organization, but this is just an article and not a book.  Every member has different goals and every member will take away something different from their experience.  That is part of what makes this organization a “must” for all legal professionals.  Come as a guest or bring a guest.  Tell your employer what this membership would mean to you and how you could give back to your employer.  Make an investment in your career and in your future.  It does make a difference!

Paula Steffey, PP, CLP-SC, has been a member since 2014.  She is currently the co-chair for the Programs and Reservations committees and the chairperson for the Attorney Directory project on the Ways and Means committee with NALS of Greater Kalamazoo in Michigan.  Paula is also very active at the state level and is currently serving as the Executive Secretary for NALS of Michigan and, for more excitement, is the chairperson for the Finance Committee.  In June she took over as the chairperson for the Marketing Committee.  After attending the national conference in October, she submitted her application for a secondary membership with NALS of Phoenix and hopes to be as active as possible from a distance.  She also joined the Editorial Board.  Outside of NALS she is a full-time legal assistant to attorney Garold A. Goidosik with Goidosik Morse Disability Law Group and has two other part-time jobs.  One of those part-time jobs is her own crafting company where she sells her hand-crocheted items.  Besides work and NALS, she is married with two children of her own, a stepdaughter, and two very spoiled golden retrievers who are retired show dogs. 


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Grammar Nuggets: Confused? Let's Choose to Show We Chose the Right Word

Posted By Kathy Sieckman, PP, PLS-SC, ACP, Thursday, November 10, 2016

Grammar NuggetsI keep seeing the same mistakes over and over with misusing words that are similarly spelled or are forms of other words and cause confusion. I will try to make it more clear to make it easier to choose the right word.

Accept and Except—accept is to take or receive; except is to exclude.

§  She was able to accept the package for Jim. (She was able to RECEIVE the package.)

§  Everyone was invited except Joe. (Joe was EXCLUDED from the invitation.)


Affect and Effect—affect is to influence or to change; effect is the result or impression or to bring about.

§  The habit of coming in late had an affect on Sally's raise this year. (Sally's habit of coming in late INFLUENCED her raise.)

§  The effect of the rain was a beautiful rainbow and also several accidents on the rush hour drive home. (The beautiful rainbow and the accidents were the RESULT OF the rain.)


Choose and Chose—choose means to select; chose means you have already selected.

§  She will choose her car based on its color. (She will MAKE her selection of car based on color.)

§  She chose the red car. (She already MADE the selection of the red car.)


Ensure and Insure—ensure means to make certain; insure means to protect against loss.

§  He wanted to ensure the job was done correctly. (He wanted to MAKE CERTAIN the job was done correctly.)

§  She was able to insure her sports car. (She PROTECTED her sports car.)


Gibe and Jibe—gibe means a sarcastic remark or to scoff at; jibe means to agree.

§  The gibe about her hair color was hurtful. (The SARCASTIC REMARK about her hair color was hurtful.)

§  The figures did not jibe between the checking account and the accounting system. (The figures did not AGREE between the checking account and the accounting system.)


Its and It's—its is the possessive form of it; it's is the contraction for it is or it has. This is particularly confusing because most possessive forms use the apostrophe, but just remember if you cannot replace your word with “it is,” then you use “its.”

§  The dog chewed up its collar. (The collar BELONGED to the dog.)

§  It's the third collar they had to buy the puppy. (IT IS the third collar.)


Know and No—know means to understand; no means not any.

§  I now know the correct usage of it's. (I UNDERSTAND the correct usage of it's.)

§  He has no money to go on vacation. (He does NOT HAVE ANY money to go on vacation.)


Loose and Lose—loose means not bound or to release; lose means to suffer the loss of.

§  The dog got loose from its leash and ran out of the yard. (The dog is NOT BOUND by its leash.)

§  She was afraid she would lose her dog once it got loose. (Now that the dog is loose, she may SUFFER THE LOSS OF the dog if he does not come home.)


Their and There—their means belonging to them; there means in that place.

§  Their house is the nicest on the block. (The house BELONGING TO THEM is the nicest on the block.)

§  The car is there in the driveway. (The car is IN THAT PLACE in the driveway.)


Your and You're—your means that it belongs to you; you're is the contraction for “you are.” This one is misused by most of the people I see on Facebook who are teens or preteens and even some young adults and makes me question how they are teaching this in school.

§  I thought you said my phone was in your purse? (The purse BELONGS to you.)

§  You're going to the movies tonight, aren't you? (YOU ARE going to the movies.)


I hope some of the confusion is cleared up. If you would like a little extra reinforcement, take this quick quiz:

  1. He agreed to (accept, except) the award on behalf of his boss.
  2. Doing homework and studying hard had the (affect, effect) of getting an A in that class.
  3. He was ready to (choose, chose) the costume for the Halloween party.
  4. She worked hard to (ensure, insure) that the party would be a success.
  5. He was excited that the amount in his checkbook (gibed, jibed) with his bank statement.
  6. (It’s, Its) hard to be tolerant of mistakes in grammar.
  7. I (know, no) that if people would slow down, there would be fewer accidents.
  8. One person is required to (loose, lose) so another can win.
  9.  She sat (their, there) to be near her friends.
  10. (Your, You’re) car is a very nice ride.

Answers: 1. Accept, 2. Effect, 3. Choose, 4. Ensure, 5. Jibed, 6It’s, 7. Know, 8. Lose, 9. There, 10. Your

Kathy Sieckman, PP, PLS-SC, ACP, has been a member of NALS for over 30 years, is the current President of NALS of Phoenix, and is the Vice Chair of the NALS Editorial Board. Kathy is currently the Administrator-Arizona for Sacks, Ricketts & Case in Phoenix, Arizona. Kathy earned her Associate of Applied Science degree in Legal Assisting (with distinction) from Phoenix College. In her spare time, when she is not spending time with her husband, two kids, and seven grandchildren or celebrating something with friends, Kathy writes a blog on proofreading tips at http://proofthatblog.com

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Ask Eula Mae: Work v. Law School Decision

Posted By NALS Editorial Board, Wednesday, November 9, 2016

Ask Eula MaeDear Eula Mae:

I have an ALP certificate and work part time for an attorney as an office clerk but lack the hours needed for a four-year law study program in lieu of going to law school.  Most of my duties are as a personal assistant and I do not have much to do.  I am taking the Multi-State Professional Exam (MPRE) this week “just for fun.”  How do I get my foot in the door without much legal experience?  Should I bite the bullet and go to law school or stay on my current path and hope to find work in a more robust office?

New Hampshire Newbie


Dear New Hampshire Newbie:

Well, you have a lot going on and a lot of questions!  This is good!  There are several things in your letter to consider:  (1) you need hours for a four-year law study program, (2) you need more to do in your job, (3) it sounds like you really want to work in a law office, and (4) you are trying to decide whether or not to go to law school.  Let’s take these one at a time.  

  1. You need hours for a four-year law study program.  Are you in college or looking for certification hours?  Either way, if you love the law, you can find classes to attend through professional organizations such as NALS, technical schools, or online classes at your local university.  

  2. In your current job, start with the boss.  The boss needs to know you need more to do and you are willing to learn.  Bosses are a great resource for legal professionals for career ideas and maybe as a mentor.  You could interview the boss about his experience in law school.

  3. If your goal is to work in a law office, there is much to learn right where you are.  If you have exhausted the resources there (after talking with the boss, of course), then it might be time to move on to a busier office.  Legal work can take place in many areas.  You can work directly for an attorney at hospitals, corporate offices, title companies, insurance companies, utility companies, etc.  As your own research project to help you decide your next step, it might be good to look at other areas that have legal assistants.

  4. A big decision such as whether or not to go to law school is not one to make quickly.  There are many reasons for this and the main one is to absolutely know why you want to go to law school.  It is a big commitment.  First, you will have to finish your undergraduate degree and then secure the funding to pay for law school.  This is a job in itself.  Then you will need to take the Law School Admission Test (LSAT).  All of this could take some time, but that is really not a problem because you can go to school any time in your life.


What makes your main question difficult is the fact that there are so many options!  Now, how to make a big decision:  make a comparison chart with a list of what you could do (law school v. legal assistant, paralegal certification, etc.).  For each item, make columns of time involved, resources available and needed, costs, and list the positives and negatives of each.  You have plenty of time to decide.  You can always go to law school and working as a legal assistant until you are ready will better prepare you for law school.  The real answer to your question is for you to follow your heart.  You will be fine whatever you choose to do.


Eula Mae Jett


Submit Your Questions To Ask Eula Mae By Clicking Here.



Tags:  ask eula mae  legal  legal education  legal job skills  legal jobs  legal professional  paralegal 

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Amylyn Riedling PP PLS-SC2019 NALS Board of Directors
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