Tuesday, November 2, 2010
Student Post: U.S. District Court for the District of Columbia, Washington, DC
This past summer, I interned for a magistrate judge at the U.S. District Court for the District of Columbia, and it was a great learning experience. My judge’s calendar at first consisted of only civil cases, but then she switched to a criminal docket later in the summer. The civil cases were usually employment discrimination claims that involved requests for attorney fees. The criminal cases tended to be sentencing hearings.
Most of my time over the summer was spent doing legal research and writing, which I then submitted to the judge in the form of internal memos or “Report and Recommendation” documents. After the judge had a chance to review my documents, we would discuss my findings and talk about the strongest and weakest aspects of particular arguments. What I enjoyed most about my internship was when, just before a hearing, the judge would call me into her chambers and ask me to imagine what I thought each side would say in response to a particular question from her. I really enjoyed the opportunity to talk through these scenarios with the judge, because these exercises helped me to learn to think on my feet and to improve my oral argument skills. I also liked having the opportunity to then attend the court proceeding for each case, to see if the parties did in fact raise the arguments that I had anticipated that they would give in response to the judge’s questions.
I also really enjoyed learning more about the inner workings of a federal courthouse, and having the chance to see judges, lawyers, marshals, and law clerks in action. The internship allowed me to get a great behind-the-scenes look at how federal cases are handled, and enabled me to gain the kind of hands-on experience that one cannot get from a classroom. In particular, because I had the opportunity to attend daily court proceedings, I was able to see a lot of different lawyering styles during the course of the summer, from government attorneys, defense lawyers, lawyers working on cases pro bono, and even a few pro se clients. It was great to observe the different communication styles, writing styles, and argument styles in action, and by the end of the summer I felt that I had picked up a few good tips about how to present myself in court. These tips that I picked up from the counsel I saw over the summer have already be an asset to me in my current clinical casework, and I know they will continue to help me in my future career as a prosecutor.
A judicial internship is a great learning experience for anyone considering a career in litigation or for any student who is thinking of clerking after graduation, and the U.S. District Court for the District of Columbia was an especially exciting courthouse in which to intern, because of the many high-profile cases that are heard there each day. I'm grateful for the EJF funding that enabled me to spend my 2L summer pursuing this type of internship. I would not have been able to undertake this internship without EJF’s support.
Monday, November 9, 2009
U.S. District Court, Newark, New Jersey
This past summer, I had the opportunity to work as an intern for the U.S. District Court in the Federal District of New Jersey. My time in chambers proved to be an invaluable experience as I got the chance to work closely with Judge Stanley Chesler on drafting legal memoranda, reviewing briefs and discussing the merits of the arguments presented by the litigants at oral argument. As a culmination to this experience, I successfully completed a judicial opinion that was subsequently approved and used by the judge. The satisfaction gained from that one project alone made the experience worthwhile.
Beyond these tangible gains, I also really benefited from sitting in on oral arguments and seeing legal practitioners apply their craft in everyday real life situations. It exposed me to the different litigating styles that practitioners employ, from the calm and light-hearted approach to the aggressive and in-your-face. One of my fondest memories of this entire experience was walking into oral argument and hearing one of our very own Georgetown Law professors advocate on behalf of the defendant. To see this professor in the court room, after having been taught by him in class, really relayed to me the disconnect that we as law students who study theory and doctrine have with our colleagues in the workplace who combine these principles with real life cases and facts in one coherent and persuasive presentation.
We as law students read a lot and, hopefully, learn a lot about the law. Often times however, we forget that the legal universe extends beyond the classrooms we learn in or the law schools we attend. Being a successful lawyer goes beyond knowing the Erie Doctrine or the UCC; it involves a combination of substance and style, intellect and elegance. My time in chambers this past summer could not have illustrated this point more then it did to me. My very assignment involved drafting a memo regarding a pro se petitioner's motion to amend or revoke his felony conviction under U.S.C. Section 2255. Admittedly, this task seemed intimidating at first; I had never learned about 2255 in my criminal law class. On top of that, I was expected to present my conclusion to Judge Chesler himself and explain the reasoning behind it. Luckily, I was able to learn so much about 2255 that I was able to think critically in applying the law to the facts of the petitioner's case. But it was my ability to articulate these thoughts verbally that served both as my biggest challenge and success of the summer.
All in all, I absolutely enjoyed my time in chambers and the mentoring I received from both Judge Chesler and his clerks. I feel that I have grown by leaps and bounds as a law student and individual as a result of this experience. For that, I am very grateful and thankful for EJF and their contributors in helping making this summer experience possible for me.
Wednesday, September 16, 2009
DC Superior Court
This summer I had the opportunity to intern at the DC Superior Court for an associate judge serving in the Court’s civil division. There I had the opportunity to gain a lot of exposure to various areas of civil litigation. My primary responsibilities were to help prepare the Judge for hearings by drafting outlines of the relevant legal issues and to write orders resolving various disputes.
I worked on a broad range of legal issues, but my largest project of the summer involved a very complex dispute over a series of contracts involving multiple plaintiffs. Getting through the case at first was challenging. It took me nearly a week to read through all the motions, memoranda, and exhibits, but once I finally understood the case and the applicable law, I felt good about giving the judge my opinion on how he should rule.
I also had the opportunity to observe hearings, bench trials, and jury trials. In addition to the in-court observations of cases of my assigned judge, I would sometimes observe the courtrooms of other judges hearing high profile cases. This was a great opportunity to see lawyers present oral argument before the court. I had the opportunity to see what were persuasive techniques and styles of presentation, and what was less effective.
I really enjoyed the assignments that I was given, and the opportunity to work closely with the judge was a huge privilege for me. I know that I have substantially improved my legal research and writing skills through my summer experience. I would like to thank all the EJF contributors for helping to fund my summer learning experience.
Thursday, August 6, 2009
Appellate Division, First Department, New York
By David Yellin
This summer I have been fortunate enough to intern for Associate Justice James Catterson of the Appellate Division, First Department in New York. The First Department is the intermediate state appellate court hearing appeals from Bronx and New York (Manhattan) Counties. The courthouse at 25th St. and Madison Ave. in Manhattan is one of the most incredible buildings I’ve worked in. The courtroom is covered in frescoes and stained glass with a massive stained glass dome, and the halls are lined with pictures of old judges (there’s a great shot of Cardozo right outside the library), historical shots of New York City, and assorted other antiquities. Unfortunately we’re only in the city about half the time, and when the judge isn’t sitting we go to his chambers in Riverhead (out east on Long Island) where we work in an unused courtroom.
We have spent most of our time drafting opinions for the judge. On the first day, the law clerk gave us a case briefs, record, and law report (bench memos produced by the court attorneys for the full panel of judges) and told us to write an opinion in two weeks or less. So far, two of the opinions I wrote have been voted on by a full panel and are on their way to editing and (hopefully) publication. I drafted two others after the judges stopped meeting for the summer. The opinions I drafted included financial issues, a statutory interpretation case, and a criminal appeal. I even wrote one dissent that ended up as the majority opinion, which was pretty cool.
We have also gotten a chance to observe several sessions of oral argument. The judge prepared us for each session by giving us a stack of bench memos to read to familiarize ourselves with several of the cases, and then grilled us on each case. It was moderately terrifying at first (who wants to get cold-called during lunch over the summer?) but has actually been tremendously educational. And, since he’s one of the more vocal judges on the bench, it gave us a chance to understand the questions he’s asking and how they fit into the way he sees the case. We have also seen various other proceedings and observed pieces of a trial in the Riverhead courthouse.
However, as interesting and educational as the work has been (and it has been extremely so), probably the best part of the internship is probably the fact that we get face time with the judge during lunch almost every day. It has given us a chance to ask questions as well as to get to know the judge we were interning for.
It’s been a pretty amazing summer. I got a lot of experience, learned a lot of law, and honed my writing skills considerably; I’m looking forward hopefully to seeing some of my work on Westlaw this fall.
Monday, July 27, 2009
United States District Court for the Western District of New York
By Michael Snodgrass
I work in Buffalo (Go Bills!) for the Honorable Richard J. Arcara, Chief Judge for United States District Court for the Western District of New York. On a side note, "Chief Judge" means the longest serving judge on the court. The main responsibility of the Chief Judge is setting the local rules. While there are minimum federal requirements which all District Courts must adhere to, District Courts can also supplement these rules. For example, Buffalo has a rule that all plaintiffs and defendants must have local counsel. Even if a person's main counsel flies in from Los Angeles or New York and his/her local counsel never appears in court, he/she must have local counsel hired. That way, if the Judge needs something (i.e. an attorney for a five minute status conference), a local counsel will be able to show up immediately.
Most days, I start off the morning by observing court proceedings. The most interesting and distinctive proceedings are oral arguments, which have ranged so far this summer from a products liability suit over tree stands (the seats that hunters strap to trees and sit in all day), two companies fighting about R+D in a navy contract for new scuba gear, supervised release for the leader of a biker gang, criminal charges for the recipients of a crate shipped from LA to Buffalo with 377 pounds of marijuana, and a man who ran a Ponzi scheme (i.e. paying off old investors with the money from new investors) for thirty years by advertising in the bulletins at Catholic Churches. Most days, I will spend an hour or two observing court and the rest of the day working on judicial decisions. I am working on Social Security Disability cases all summer. When a person claims to be too disabled to work, he applies for Social Security Disability. If denied, he can request a hearing in front of an Administrative Law Judge. If the ALJ denies his claim, he appeals to a review council. If the Appeals Council denies the claim, he can bring a civil suit in US District Court, alleging that the Commissioner of Social Security did not have substantial evidence for his decision or committed a legal error. I review the cases (usually containing 500-1000 page medical files and multiple briefs from both sides) and write the decision, either denying benefits, granting benefits, or remanding the case to the Administrative Law Judge for further proceedings. As long as my decision is fairly logical, based on hard evidence and precedents, and well-written, my law clerk and Judge will defer to my judgment on the case and my decision will get signed by the Judge.
Working in US District Court has been an amazing opportunity to observe court proceedings of all different shapes and sizes, meet interesting people from the US Attorney's office and local counsel, and see Civil Procedure in action (Professor Abernathy would be so proud). If you are interested in US District Court, be prepared to be very formal in dress and etiquette, and be prepared to learn as much as you can from the smart, friendly, hard-working law clerks (thanks Monica and Joe!), observe important and intriguing oral arguments, and see the American ideal of equal justice for all play out at the trial court level of the Federal Judiciary.
Tuesday, July 7, 2009
Magistrate Judge, Southern District of Florida, Miami, FL
By Eric Gonzalez
I am working as an intern for Federal Magistrate Judge Andrea M. Simonton of the Southern District of Florida. I work in the Atkins federal courthouse in downtown Miami from Monday through Friday, from 9:00 A.M. until 5:00 P.M.
A federal magistrate judge handles matters that United States District Judges refer to them. While these matters are largely pretrial motions, such as motions to compel discovery and motions to suppress evidence, the parties can consent to the jurisdiction of a magistrate judge. The parties’ consent gives the magistrate judge the full powers of a district court judge with respect to their case.
My experience at the courthouse has been anything but boring. I have undertaken a variety of activities. I attended a trial, pretrial detention hearings, and suppression hearings; have toured a federal detention center; and, have attended oral arguments for the eleventh circuit court of appeals.
The projects that I participate in are also unique. I have worked on a federal habeas claim, a claim under the Fair Labor Standards Act, have written pretrial detention orders, and am currently researching arbitration agreements as they relate to motions for attorneys fees.
These varied projects represent only some of the things that I learned this summer. Working at the courthouse has shown me a lot of the administrative challenges that the judicial system faces. As a court of first review the Southern District of Florida handles several pre-trial motions, all while conducting trials, holding hearings, and reviewing warrants.
In short, I am having an interesting experience learning about nuanced legal matters as well as broad administrative concepts.
Thursday, August 7, 2008
U.S. District Court for the District of Puerto Rico
Every morning of my summer clerkship starts pretty much the same–with a stretch and a yawn on my balcony overlooking the ocean, as I contemplate yet again how hot it is for only 8:00 in the morning. On the way to the Courthouse, I stop to buy "cafĂ© con leche para llevar" ("coffee with milk to go") and maybe a quesito, a delicious cheese-filled, sugar-covered pastry. I love the Courthouse in Old San Juan, Puerto Rico, not only because it is a pretty colonial-style building that is thankfully air conditioned, but because everyone greets each other with a big smile and an enthusiastic "Buenos dias!"Then the day’s work begins. I typically have between two and three assignments at any given time, in addition to the summaries of First Circuit cases that I prepare for the Judge weekly. I have drafted opinions on several types of motions, probably the most juicy being a motion for an order of contempt of court against an attorney in a particularly protracted piece of litigation. The most difficult opinion I worked on was a motion to dismiss involving claims under the Americans with Disabilities Act and Title VII that also raised sovereign immunity issues and involved both institutional and individual defendants. I also prepare case memoranda and other documents for pre-trial meetings between the Judge and counsel, which I attend to take notes. Following the meetings, I compose initial scheduling conference orders that define the course of discovery for each case. I was also fortunate to witness a rendition hearing and parts of a jury trial while working here. These experiences not only familiarized me with courtroom procedure, but afforded me the chance to observe differing advocacy styles.
Clerking for Judge Pieras has been a wonderful opportunity!
Tuesday, August 5, 2008
US District Court - Southern District of New York
It’s Monday morning in early June, 9:30-ish a.m., and the beginning of my third week as a judicial intern in the Southern District of New York. Scores of potential jurors fill Courtroom 12B, each hoping to dodge the bullet in what is expected to be a two-week-plus criminal trial. Interns from the United States Attorney’s Office line the walls and anteroom; the gallery is standing room only. On trial are four friends from the Bronx, alleged to have conspired to commit murder in furtherance of a larger narcotics conspiracy. Until earlier this spring, two of the twenty-something-year-old men faced the death penalty.
Over the next few weeks, the story of the victim’s murder played out like the television drama our professors promised we would never see: bales of marijuana and pistols passed from prosecutors to witnesses to jurors; co-conspirators and former associates flipped on one-time friends; a surprise defense witness provided graphic testimony about a purportedly related sexual assault; a defendant threatened to assault the Assistant United States Attorney prosecuting the case; and extensive forensics testimony tied the loose ends. It was truly a once-in-a-lifetime experience. After several days of deliberation, the jury convicted on all counts.
I have had the good fortune of observing not one, not two, but three criminal trials this summer. This means that along with researching and drafting memorandums on Daubert, Title VII, sovereign immunity, jurisdiction and venue, and pleading standards under the PSLRA and the federal in forma pauperis statute, I have observed nine opening statements, nine summations, the examination and cross-examination of almost 50 witnesses, and, most importantly, my Judge’s and clerks’ reactions and observations every step of the way. Forget class, I have seen criminal law, criminal procedure, evidence, and trial advocacy in the flesh.
I made a decision early during my first year to take on a summer internship that would enhance both my skill-based and substantive knowledge of the law. My judicial internship has done just that, and, in addition, has imparted a greater familiarity with litigation and trial practice. I am incredibly appreciative of the Equal Justice Foundation’s support, without which I would have been unable to accept this position. I look forward to making similar experiences possible for the Class of 2011.
Thursday, July 31, 2008
United States Magistrate Judge for the Western District of Virginia
This summer I have had the pleasure of interning in the chambers of
the Honorable Michael F. Urbanski, United States Magistrate Judge for the Western District of Virginia. It has been invaluable experience and I am indebted to Judge Urbanski and his Law Clerk, Yousri Omar, for all I have learned. As a magistrate judge, Judge Urbanski has many pretrial motions from a variety of civil cases (including the always dreadful denial of social security benefits appeals) referred to him and conducts almost of all of the pretrial hearings for criminal cases. Because magistrate judges are only allotted funds for one law clerk, my summer has been loaded with significant work.
In the first two weeks of my internship I drafted a memo to the judge on an insurance claim dispute, a memorandum opinion on a motion to quash a subpoena in an employment discrimination case, and an order on another motion to quash in an ERISA denial of benefits case. In between writing and researching these civil matters, I was able watch the judge in action at detention hearings in criminal prosecutions. These detention hearings occasionally included testimony from witnesses from both the prosecution and defense, as well as closing arguments from both sides. The judge would then determine whether the defendant should be detained, specifically, he must determine whether the defendant is a risk of flight or poses a danger to the community. In rare cases, the judge called a recess to see what the law clerk and I thought about the arguments. Although always appreciative of our thoughts, any disagreements were usually resolved with a friendly reminder from the judge that only one of our opinions mattered.
I also have been able to observe the mediations which the judge regularly conducts. During a mediation, both parties come to the courthouse where each side makes opening arguments and then divides into separate rooms. The judge then bounces back and forth between the rooms for the rest of the day, negotiating a settlement deal. As the skills and style necessary to securing a beneficial settlement for a client are much different in the mediation setting as opposed to winning a verdict in a courtroom setting, seeing these mediations first hand has been a highly interesting and educational experience.
I truly believe that one could not spend their summer in a more beneficial position than I have this summer as a judicial intern with Judge Urbanski. I have worked on a wide assortment of issues,including the marital communications privilege, a prisoner's claim of ineffective assistance of counsel, a criminal contempt action, and a motion for attorney's fees. The work I did on practical, real-world applications of the law greatly improved my research, writing, and
communication skills. I benefited from the assistance and editing of the three different law clerks. I have seen many different styles of argument from lawyers and how effective each is in the eyes of a federal judge.
The generous grant I received from the Equal Justice Foundation continues to be an integral part of my unpaid internship this summer and I am extremely appreciative of this assistance.
Thursday, July 10, 2008
D.C. Superior Court
I am now seven weeks in to my job as a judicial intern on the civil calendar at the D.C. Superior Court, and I can unequivocally say that this summer is flying by. I feel fortunate to be working in a small chambers—it’s only the judge, her administrative assistant, the law clerk, one other intern, and me here. This means that I have been able to interact with the judge and law clerk (both GULC alumnae!) every day on a variety of matters. They have both been great role models for me (I want to be them when I grow up!).

I was hoping to get a chance to see some trials and other matters before the court. This hope was not in vain; I have seen matters ranging from murder trials to wrongful death medical malpractice trials to Judge Judy-style bickering between neighbors who are seeking protective orders against each other. I have also witnessed quite a range of skill from lawyers. One day, I’m listening to one of the best orators I’ve ever encountered making a closing argument in defense of a doctor accused of malpractice; the next, I’m reading truly atrocious briefs (was my LRW professor fibbing when she said you had to be good at her subject to practice law?).
Before I started, I was nervous about my legal research and writing skills. However, it turned out that the many briefs and memos I have produced have increased my confidence and, I hope, refined my skills in legal writing. The subjects I have researched and written on have been as interesting and varied as the trials I talked about above. All the work I’ve done has been a great reminder of the fact that lawyers work to resolve serious problems for real people. The judge asks me to tell her how I think she should rule on each order I work on, and has actually agreed with me the majority of the time. This summer has opened my eyes to how interesting, challenging, and rewarding legal work can be. I am forever grateful to the Equal Justice Foundation for allowing me this opportunity, since without it, I’m pretty sure there’s no way I could have taken on this unpaid internship.
Tuesday, July 1, 2008
US District Court for the District of Columbia
My first month as an intern here at the US District Court for the District of Columbia is nearly over and, I have to say, working for a federal judge is a pretty great 1L gig. It's also an experience that would be virtually impossible to realize without funding from EJF.

I can't imagine being exposed to such a wide array of cases, in such varying procedural stages, in any other setting. As an intern, I get to see arraignments, hearings, sentencings and all the various proceedings that come between. Being able to speak to the law clerks and the Judge before and after these proceedings has really given me an understanding of many of the nuances of courtroom procedure that would otherwise have gone over my head.
Thus far my assignments have kept me quite busy. Probably the most amazing part of this summer has been realizing that I'm actually capable of doing real legal work. The process of researching and writing is basically like that of completing LRW assignments, except that there is that added incentive of not wanting to be completely embarrassed in front of the law clerks. (I have never spent so much time double checking my cites...)
One of the great perks thus far has been the series of speakers that have come to talk to the law clerks this summer (we interns tag along, too). So far, we have had some prominent speakers from the U.S. Attorney's Office, the Public Defender's Office, NPR and a 'BigLaw' DC firm. (Later in the summer, two Supreme Court Justices are dropping by to chat. Again, what an awesome job!) It's quite interesting to hear the anecdotes of these seasoned lawyers and Washingtonians. But it is even more interesting to hear their candid opinions about recent Supreme Court decisions, sentencing guidelines, and the legal profession in general.
This summer has really been great so far. And I can't help thinking that those folks at other law schools (who can't receive funding for judicial internships) are really missing out. Judges and law clerks are incredibly dedicated public servants. They are also wonderful resources for students who intend to one day pursue a career in government or in public interest law. I'm grateful that EJF recognizes this, and provides Georgetown Law students with the means to spend their 1L summer in such a wonderful legal setting.
Sunday, June 22, 2008
Federal Court- Southern District of New York
My first week as an intern for a federal judge in the SDNY was as interesting and capturing as reading a bestselling page-turner. When I arrived early Monday morning, I was greeted by the judge’s two law clerks, who showed me my computer and desk. Just as I sat down to admire my thirteenth-floor view that overlooked lower Manhattan, I was told we were going to court because the judge was hearing a civil trial for the next two days.
The trial was an introduction to how informative and engaging the judge would be. During each break, the judge took time to explain to us certain legal nuisances that occurred in the courtroom and to advise us on what she thought were the good (and not so good) habits of the attorneys. After trial ended, the judge treated us to lunch on Wednesday where the topics of conversation ranged from law to theater to literature. The judge was eager to share her opinions, but she was even more interested in what we had to say.
The judge’s law clerks perfectly complemented her warmness with their enthusiasm and willingness to mentor me and the two other interns. Although they were inundated with work, the law clerks took additional time to explain the issues that arose in their cases. Because they believed it was a two-way street, they gave us the responsibility to independently draft memos that they would edit and then send to the judge. However, the best part of my first week was the lunches that we ate together every day in chambers. The law clerks, the deputy clerk, the other interns, and I sat around a big table and chatted about pending cases, legal gossip, and just about our lives.
I cannot imagine a better first week and I am thankful to EJF for making this experience feasible.
Saturday, May 24, 2008
United States District Court for the District of Columbia

My first week as an intern at the United States District Court for the District of Columbia - Alicia Kelman
Life lesson #1: Learn to love the Bluebook. Contrary to what you may
think, the Bluebook is not the most poorly organized good for nothing
unnecessarily complicated piece of nonsense ever put on paper. Trust
me, once you sit down to read a petitioner's motion and none of the
citations make even a little bit of sense, and you are forced to delve
deep into the depths of Westlaw in order to figure out what the motion
is referring to, you will realize the benefits of a uniform system of
citation.
Life lesson #2: Bring the law clerks Starbucks. Coffee breaks are the
perfect time to chat with the law clerks about the cases that they're
working on. Over a deliciously refreshing iced latte, I learned all
about the difficulties in proving a Title VII discrimination claim,
the intricacies and loopholes of bankruptcy law, and the meaning of
the Latin phrase pro hac vice.
Life lesson #3: LRW was not pointless torture. Twice this week the law
clerk asked me to venture into the court library and find the
publication date of a print source. If not for all of those lovely LRW
research assignments, (ie, the ones where I wandered aimlessly around
the library muttering to myself "when will I ever need to do any
research other than on Westlaw?"), I would have been in serious
trouble.
Life lesson #4: Being a judge is harder than you think. Four interns
are sitting in what is lovingly referred to as "the pit," reading
motions for summary judgment on an immigration case. After reading the
first motion, each one of us proclaims "yes, definitely, this guy
wins, for sure, no doubt about it, he should totally get to stay in
America." Fast forward half an hour… same four interns, after reading
the other side's motion: "oh, wow, wait a second, this guy's arguments
are pretty good too, huh, maybe the judge should send the guy back to
England." True story.
Life lesson #5: I want to be Jack McCoy. "Law & Order" might not be
entirely accurate, but the reality is just as awesome. On the first
day of my internship, the law clerk printed out a schedule of
everything going on in the court for the week, and highlighted stuff
that he thought us interns would find particularly fascinating. Having
the opportunity to observe everything from arraignments to full blown
jury trials and sentencing hearings is absolutely incredible.
Life lesson #6: EJF is my savior. Five days into the summer, and
already I have received quite an education. Without the EJF funding, I
would have been unable to: 1) Buy a shiny new Bluebook so I could
decode a petitioner's motion, 2) Buy the law clerks lattes in exchange
for their wisdom, 3) Buy gifts to bribe the librarians for help with
my research, 4) Buy new reading glasses so I can tackle any assignment
the judge gives me, and 5) Buy "Law & Order" DVDs so I could compare
my experiences to that of my idol. Kidding aside, without the EJF
funding, my summer would be entirely different – not sure where I
would have chosen to intern, and not sure what life lessons I would
have learned…