Unit 2 covers the following topics: • Which bodies of law cover ethical considerations when representing small businesses? • Who is the client? • Creating the attorney-client relationship • Accepting ownership interests in the client or client’s business • Business advice vs. Legal advice • Serving as a director of the client • How the attorney’s competence and capacity impact representation
{"title":"Unit 2: Ethics in Advising Small Businesses (Open-access book Entrepreneurship Law: Company Creation)","authors":"Samantha J. Prince","doi":"10.2139/ssrn.3836162","DOIUrl":"https://doi.org/10.2139/ssrn.3836162","url":null,"abstract":"Unit 2 covers the following topics:<br>• Which bodies of law cover ethical considerations when representing small businesses?<br>• Who is the client?<br>• Creating the attorney-client relationship<br>• Accepting ownership interests in the client or client’s business<br>• Business advice vs. Legal advice<br>• Serving as a director of the client<br>• How the attorney’s competence and capacity impact representation<br>","PeriodicalId":318823,"journal":{"name":"Legal Ethics & Professional Responsibility eJournal","volume":"1 1","pages":"0"},"PeriodicalIF":0.0,"publicationDate":"2021-04-28","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"130894000","PeriodicalName":null,"FirstCategoryId":null,"ListUrlMain":null,"RegionNum":0,"RegionCategory":"","ArticlePicture":[],"TitleCN":null,"AbstractTextCN":null,"PMCID":"","EPubDate":null,"PubModel":null,"JCR":null,"JCRName":null,"Score":null,"Total":0}
Under the Standards for Appellate Conduct, Texas attorneys are admonished not to attribute to opposing counsel a position not taken. See Lawyers' Duties to Lawyers, ¶9. (“Counsel will neither ascribe to another counsel or party a position that counsel or the party has not taken.”).
But what if an appellate justice does this herself? -- Imputes upon a represented appellant a position not taken, and then knocks it down and resolves the appeal against that party? Or puts her stamp of approval on her law clerk’s strawman-whacking handiwork? Is that a violation of professional standards, given that both the authoring justice and the law clerk are Texas attorneys? Is it merely a matter of setting a bad example? Or does it, perhaps, establish a new precedent for the legitimate use of strawman-type reasoning as a justificatory stratagem in the disposition of appeals, in which the higher court must render an opinion explaining the reasons for its decision?
Rather than venturing an answer at this point of the appellate game, this commentator urges by way of amicus letter brief that Kem Thompson Frost, Chief Justice of the Court of Appeals for the 14th Appellate District of Texas, revisit her panel’s opinion, and reconsider the rationale belabored to affirm the judgment for American Express Bank, FSB, a federal savings bank that incidentally no longer even exists, as it has been merged into American Express National Bank.
Case cite: SAMEERA ARSHAD and ALMORFA, LLC, v. AMERICAN EXPRESS BANK, FSB, No. 14-17-00676-CV (Tex.App.-Houston [14th Dist.] July 25, 2019, no pet. h.).
{"title":"Straw Person Jurisprudence","authors":"Wolfgang P. Hirczy de Mino","doi":"10.2139/ssrn.3431951","DOIUrl":"https://doi.org/10.2139/ssrn.3431951","url":null,"abstract":"Under the Standards for Appellate Conduct, Texas attorneys are admonished not to attribute to opposing counsel a position not taken. See Lawyers' Duties to Lawyers, ¶9. (“Counsel will neither ascribe to another counsel or party a position that counsel or the party has not taken.”). <br><br>But what if an appellate justice does this herself? -- Imputes upon a represented appellant a position not taken, and then knocks it down and resolves the appeal against that party? Or puts her stamp of approval on her law clerk’s strawman-whacking handiwork? Is that a violation of professional standards, given that both the authoring justice and the law clerk are Texas attorneys? Is it merely a matter of setting a bad example? Or does it, perhaps, establish a new precedent for the legitimate use of strawman-type reasoning as a justificatory stratagem in the disposition of appeals, in which the higher court must render an opinion explaining the reasons for its decision? <br><br>Rather than venturing an answer at this point of the appellate game, this commentator urges by way of amicus letter brief that Kem Thompson Frost, Chief Justice of the Court of Appeals for the 14th Appellate District of Texas, revisit her panel’s opinion, and reconsider the rationale belabored to affirm the judgment for American Express Bank, FSB, a federal savings bank that incidentally no longer even exists, as it has been merged into American Express National Bank. <br><br>Case cite: SAMEERA ARSHAD and ALMORFA, LLC, v. AMERICAN EXPRESS BANK, FSB, No. 14-17-00676-CV (Tex.App.-Houston [14th Dist.] July 25, 2019, no pet. h.).","PeriodicalId":318823,"journal":{"name":"Legal Ethics & Professional Responsibility eJournal","volume":"1 1","pages":"0"},"PeriodicalIF":0.0,"publicationDate":"2019-07-28","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"116265652","PeriodicalName":null,"FirstCategoryId":null,"ListUrlMain":null,"RegionNum":0,"RegionCategory":"","ArticlePicture":[],"TitleCN":null,"AbstractTextCN":null,"PMCID":"","EPubDate":null,"PubModel":null,"JCR":null,"JCRName":null,"Score":null,"Total":0}
Drawing on experimental games and a survey conducted with university students at an elite legal academy in Ukraine, this study compares the behavioral, attitudinal, and demographic traits of students aspiring to public sector legal careers as judges, prosecutors, and investigators with their counterparts aiming to pursue private sector legal careers as defense attorneys and commercial lawyers. I find evidence that students pursuing public sector legal careers display more willingness to cheat or bribe in experimental games as well as lower levels of altruism. These findings indicate that corruption in some societies may persist in part from the self-selection into government institutions of citizens with a higher propensity to seek profit from illicit activities. Moreover, the findings suggest that such corrupt self-selection can infect a country’s judicial and law enforcement apparatus, with potentially dire implications for the rule of law.
{"title":"Self-Selection into Corrupt Judiciaries","authors":"J. Gans-Morse","doi":"10.2139/ssrn.3651425","DOIUrl":"https://doi.org/10.2139/ssrn.3651425","url":null,"abstract":"\u0000 Drawing on experimental games and a survey conducted with university students at an elite legal academy in Ukraine, this study compares the behavioral, attitudinal, and demographic traits of students aspiring to public sector legal careers as judges, prosecutors, and investigators with their counterparts aiming to pursue private sector legal careers as defense attorneys and commercial lawyers. I find evidence that students pursuing public sector legal careers display more willingness to cheat or bribe in experimental games as well as lower levels of altruism. These findings indicate that corruption in some societies may persist in part from the self-selection into government institutions of citizens with a higher propensity to seek profit from illicit activities. Moreover, the findings suggest that such corrupt self-selection can infect a country’s judicial and law enforcement apparatus, with potentially dire implications for the rule of law.","PeriodicalId":318823,"journal":{"name":"Legal Ethics & Professional Responsibility eJournal","volume":"1 1","pages":"0"},"PeriodicalIF":0.0,"publicationDate":"2019-05-30","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"130531832","PeriodicalName":null,"FirstCategoryId":null,"ListUrlMain":null,"RegionNum":0,"RegionCategory":"","ArticlePicture":[],"TitleCN":null,"AbstractTextCN":null,"PMCID":"","EPubDate":null,"PubModel":null,"JCR":null,"JCRName":null,"Score":null,"Total":0}
This article suggests a novel concept in climate change law and attorney ethics law by proposing that many states’ attorney ethics laws could be interpreted to require, or at least permit, attorneys to disclose client activity relating to greenhouse gas emissions. Every state has some form of ABA Model Rule 1.6(b), either requiring or allowing attorneys to disclose client activities that result in death or substantial bodily harm. This article asserts that prior precedent surrounding this disclosure rule indicates that it could be applicable to greenhouse gas emissions. Attorney disclosures in turn, could impact a wide swath of greenhouse gas emission activity, making it more transparent, and in certain cases requiring attorneys to counsel cessation of such activities or withdraw from representation. Because there is growing climate activism seeking to use all legal tools to slow or stop greenhouse gas emissions, this attorney ethics issue could be a strategic tool to try and control greenhouse gas emissions activities. Thus attorneys from the private sector to government should be aware of the potential ethical issues they face in handling greenhouse gas related legal work.
{"title":"Disclosing the Danger: State Attorney Ethics Rules Meet Climate Change","authors":"V. Flatt","doi":"10.2139/ssrn.3340130","DOIUrl":"https://doi.org/10.2139/ssrn.3340130","url":null,"abstract":"This article suggests a novel concept in climate change law and attorney ethics law by proposing that many states’ attorney ethics laws could be interpreted to require, or at least permit, attorneys to disclose client activity relating to greenhouse gas emissions. Every state has some form of ABA Model Rule 1.6(b), either requiring or allowing attorneys to disclose client activities that result in death or substantial bodily harm. This article asserts that prior precedent surrounding this disclosure rule indicates that it could be applicable to greenhouse gas emissions. Attorney disclosures in turn, could impact a wide swath of greenhouse gas emission activity, making it more transparent, and in certain cases requiring attorneys to counsel cessation of such activities or withdraw from representation. Because there is growing climate activism seeking to use all legal tools to slow or stop greenhouse gas emissions, this attorney ethics issue could be a strategic tool to try and control greenhouse gas emissions activities. Thus attorneys from the private sector to government should be aware of the potential ethical issues they face in handling greenhouse gas related legal work.","PeriodicalId":318823,"journal":{"name":"Legal Ethics & Professional Responsibility eJournal","volume":"402 1","pages":"0"},"PeriodicalIF":0.0,"publicationDate":"2019-02-22","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"131693741","PeriodicalName":null,"FirstCategoryId":null,"ListUrlMain":null,"RegionNum":0,"RegionCategory":"","ArticlePicture":[],"TitleCN":null,"AbstractTextCN":null,"PMCID":"","EPubDate":null,"PubModel":null,"JCR":null,"JCRName":null,"Score":null,"Total":0}
Shaw Andrea Little was a licensed attorney in the State of Ohio. She specialized in personal injury litigation. Over a period of years she converted at least $364,907 of client settlement funds to her personal use and/or to cover prior thefts. Ms. Little was subject to disciplinary proceedings and was eventually disbarred. Ms. Little has NOT been prosecuted for stealing $364,907.
{"title":"Criminal Lawyers - Not the Defense Kind: The Strange Case of Shawn Andrea Little","authors":"T. Ealey","doi":"10.2139/ssrn.3126465","DOIUrl":"https://doi.org/10.2139/ssrn.3126465","url":null,"abstract":"Shaw Andrea Little was a licensed attorney in the State of Ohio. She specialized in personal injury litigation. Over a period of years she converted at least $364,907 of client settlement funds to her personal use and/or to cover prior thefts. Ms. Little was subject to disciplinary proceedings and was eventually disbarred. Ms. Little has NOT been prosecuted for stealing $364,907.","PeriodicalId":318823,"journal":{"name":"Legal Ethics & Professional Responsibility eJournal","volume":"43 1","pages":"0"},"PeriodicalIF":0.0,"publicationDate":"2018-02-19","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"114441762","PeriodicalName":null,"FirstCategoryId":null,"ListUrlMain":null,"RegionNum":0,"RegionCategory":"","ArticlePicture":[],"TitleCN":null,"AbstractTextCN":null,"PMCID":"","EPubDate":null,"PubModel":null,"JCR":null,"JCRName":null,"Score":null,"Total":0}
This policy brief discusses common issues that arise with Legal Defense Funds, examines regulatory responses to these issues by other jurisdictions, and makes a recommendation for legislation to govern LDFs under New York City laws.
{"title":"Policy Proposal for the Regulation of Legal Defense Funds Under New York City Laws","authors":"M. Halberstam, S. Lerner, Daniel Myerson","doi":"10.2139/ssrn.3150381","DOIUrl":"https://doi.org/10.2139/ssrn.3150381","url":null,"abstract":"This policy brief discusses common issues that arise with Legal Defense Funds, examines regulatory responses to these issues by other jurisdictions, and makes a recommendation for legislation to govern LDFs under New York City laws.","PeriodicalId":318823,"journal":{"name":"Legal Ethics & Professional Responsibility eJournal","volume":"24 1","pages":"0"},"PeriodicalIF":0.0,"publicationDate":"2017-07-06","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"116762557","PeriodicalName":null,"FirstCategoryId":null,"ListUrlMain":null,"RegionNum":0,"RegionCategory":"","ArticlePicture":[],"TitleCN":null,"AbstractTextCN":null,"PMCID":"","EPubDate":null,"PubModel":null,"JCR":null,"JCRName":null,"Score":null,"Total":0}
This paper discusses the Colorado Rules of Professional Conduct as applicable to business, transactional, real estate, and title lawyers in Colorado. This paper also discusses comparable rules of professional conduct and interpretations from a number of other states and the ABA's Model Rules of Professional Conduct, including newly adopted Model Rule 8.4(g) and its potential negative impact on practicing lawyers, notwithstanding the good intentions of the rule. This paper addresses many of the 2018 and earlier interpretations, including regarding waiver of attorney-client privilege and work-product through incautious use of modern communications technologies and electronic file storage. It also discusses practical and ethical aspects of an attorney accepting cryptocurrency for legal fees or as a retainer, new developments relating to multi-party representation, and the application of recent interpretations of a prosecutor's duties under Rule 3.8 to subpoenas issued by grand juries to lawyers.
{"title":"Ethics Rules Lawyers Should Remember","authors":"Herrick K. Lidstone","doi":"10.2139/SSRN.2874398","DOIUrl":"https://doi.org/10.2139/SSRN.2874398","url":null,"abstract":"This paper discusses the Colorado Rules of Professional Conduct as applicable to business, transactional, real estate, and title lawyers in Colorado. This paper also discusses comparable rules of professional conduct and interpretations from a number of other states and the ABA's Model Rules of Professional Conduct, including newly adopted Model Rule 8.4(g) and its potential negative impact on practicing lawyers, notwithstanding the good intentions of the rule. \u0000 \u0000This paper addresses many of the 2018 and earlier interpretations, including regarding waiver of attorney-client privilege and work-product through incautious use of modern communications technologies and electronic file storage. It also discusses practical and ethical aspects of an attorney accepting cryptocurrency for legal fees or as a retainer, new developments relating to multi-party representation, and the application of recent interpretations of a prosecutor's duties under Rule 3.8 to subpoenas issued by grand juries to lawyers.","PeriodicalId":318823,"journal":{"name":"Legal Ethics & Professional Responsibility eJournal","volume":"13 1","pages":"0"},"PeriodicalIF":0.0,"publicationDate":"2017-05-25","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"117215612","PeriodicalName":null,"FirstCategoryId":null,"ListUrlMain":null,"RegionNum":0,"RegionCategory":"","ArticlePicture":[],"TitleCN":null,"AbstractTextCN":null,"PMCID":"","EPubDate":null,"PubModel":null,"JCR":null,"JCRName":null,"Score":null,"Total":0}
Large law firms in the U.S. rely heavily on lawyers-only mutual insurers to manage their malpractice risks. Yet, under classic economic theory, mutual insurers should not be able to compete with stock insurers, at least absent a market failure. Mutuals have less access to capital and thus less ability to spread risk. Also, mutuals demand much more law firm partner time. Our research into the lawyers’ professional liability (LPL) insurance market makes three contributions. First, while we find evidence consistent with the traditional explanations for mutual insurance — market failures related to moral hazard and adverse selection and a problem with long-term contracting, we also provide a new autonomy explanation. Many lawyers, and presumably other professionals, perceive that mutual insurance promotes professional independence in the face of the social control imposed by liability and insurance. Second, we crack open the windows on a secretive aspect of law firm risk management, revealing the variable, hybrid nature of LPL mutual insurance arrangements. Third, we reframe the scholarly understanding of the relationship between organizational forms. The corporate law and insurance literature typically views mutual and stock insurers solely as competitors. We show that they also play complementary roles, as all of these mutual insurers engage extensively with commercial insurers through reinsurance or excess insurance. At least in this context, mutual insurance is not an alternative to stock insurance, but rather a way to manage access to the powerful risk distributing potential of stock insurance. Indeed, the availability of mutual insurance may favorably affect the behavior of stock insurance companies even outside of their relationships with the mutual insurers. Accordingly, our research suggests that lawyers’ participation in their mutual insurers provides benefits not only to their firms, but also to the legal profession.
{"title":"Mutually Assured Protection Among Large U.S. Law Firms","authors":"T. Baker, Rick Swedloff","doi":"10.2139/ssrn.2820654","DOIUrl":"https://doi.org/10.2139/ssrn.2820654","url":null,"abstract":"Large law firms in the U.S. rely heavily on lawyers-only mutual insurers to manage their malpractice risks. Yet, under classic economic theory, mutual insurers should not be able to compete with stock insurers, at least absent a market failure. Mutuals have less access to capital and thus less ability to spread risk. Also, mutuals demand much more law firm partner time. Our research into the lawyers’ professional liability (LPL) insurance market makes three contributions. First, while we find evidence consistent with the traditional explanations for mutual insurance — market failures related to moral hazard and adverse selection and a problem with long-term contracting, we also provide a new autonomy explanation. Many lawyers, and presumably other professionals, perceive that mutual insurance promotes professional independence in the face of the social control imposed by liability and insurance. Second, we crack open the windows on a secretive aspect of law firm risk management, revealing the variable, hybrid nature of LPL mutual insurance arrangements. Third, we reframe the scholarly understanding of the relationship between organizational forms. The corporate law and insurance literature typically views mutual and stock insurers solely as competitors. We show that they also play complementary roles, as all of these mutual insurers engage extensively with commercial insurers through reinsurance or excess insurance. At least in this context, mutual insurance is not an alternative to stock insurance, but rather a way to manage access to the powerful risk distributing potential of stock insurance. Indeed, the availability of mutual insurance may favorably affect the behavior of stock insurance companies even outside of their relationships with the mutual insurers. Accordingly, our research suggests that lawyers’ participation in their mutual insurers provides benefits not only to their firms, but also to the legal profession.","PeriodicalId":318823,"journal":{"name":"Legal Ethics & Professional Responsibility eJournal","volume":"28 1","pages":"0"},"PeriodicalIF":0.0,"publicationDate":"2017-02-19","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"134237330","PeriodicalName":null,"FirstCategoryId":null,"ListUrlMain":null,"RegionNum":0,"RegionCategory":"","ArticlePicture":[],"TitleCN":null,"AbstractTextCN":null,"PMCID":"","EPubDate":null,"PubModel":null,"JCR":null,"JCRName":null,"Score":null,"Total":0}
(Revised May 2009) The relationship between law firms and banks has a long history. Bankers and lawyers constantly work together on transactions so that their relationships are deep and enduring. Through the use of ethnography and interviews this paper examines this relationship and that of the lawyer and client. Because of the unusually tight relationship between bankers and lawyers, the lawyer-client relationship needs to be reconstituted. It is not possible to perceive it as merely a dyadic relationship; it is now multi-polar. Even though clients may be sophisticated repeat players, clients are caught up in a relationship where they will always be secondary to the primary relationship of banker and lawyer.
{"title":"Corporate Lawyer-Client Relationships: Bankers, Lawyers, Clients and Enduring Relationships","authors":"J. Flood","doi":"10.2139/SSRN.962725","DOIUrl":"https://doi.org/10.2139/SSRN.962725","url":null,"abstract":"(Revised May 2009) The relationship between law firms and banks has a long history. Bankers and lawyers constantly work together on transactions so that their relationships are deep and enduring. Through the use of ethnography and interviews this paper examines this relationship and that of the lawyer and client. Because of the unusually tight relationship between bankers and lawyers, the lawyer-client relationship needs to be reconstituted. It is not possible to perceive it as merely a dyadic relationship; it is now multi-polar. Even though clients may be sophisticated repeat players, clients are caught up in a relationship where they will always be secondary to the primary relationship of banker and lawyer.","PeriodicalId":318823,"journal":{"name":"Legal Ethics & Professional Responsibility eJournal","volume":"70 1","pages":"0"},"PeriodicalIF":0.0,"publicationDate":"2016-06-04","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"130298022","PeriodicalName":null,"FirstCategoryId":null,"ListUrlMain":null,"RegionNum":0,"RegionCategory":"","ArticlePicture":[],"TitleCN":null,"AbstractTextCN":null,"PMCID":"","EPubDate":null,"PubModel":null,"JCR":null,"JCRName":null,"Score":null,"Total":0}
Do Norwegian lawyers mobilize only to enhance their privileges and prestige? Or do they also engage in collective action for more noble ends? Contrary to materialist approaches, the theory of the ‘legal complex’ predicts that the legal profession will struggle as an entity for ‘political liberalism’ – a moderate state with basic civil rights and freedoms. This presents a paradox for the Nordic countries. Lawyers are not especially visible in the public sphere yet political liberalism is more deeply entrenched than elsewhere. If correct, this suggests either a case of Nordic exceptionalism or a problematic theory. This paper focuses on Norway. Beginning with the emergence of lawyers in the 1600s, it traces the legal profession’s engagement with the development and defense of political liberalism. This is complemented by a quantitative content analysis of interventions by the Advokatforeningen (law society). The paper argues that the results should prompt us to rethink legal complex theory more generally. The legal profession will only mobilize broadly for political liberalism when: (1) committed individual lawyers are able to overcome collective action dilemmas in the profession and (2) lawyer-centric forms of mobilization are viewed as less costly or more appropriate than the alternatives.
{"title":"Norwegian Lawyers and Political Mobilization: 1623-2015","authors":"M. Langford","doi":"10.2139/ssrn.2789729","DOIUrl":"https://doi.org/10.2139/ssrn.2789729","url":null,"abstract":"Do Norwegian lawyers mobilize only to enhance their privileges and prestige? Or do they also engage in collective action for more noble ends? Contrary to materialist approaches, the theory of the ‘legal complex’ predicts that the legal profession will struggle as an entity for ‘political liberalism’ – a moderate state with basic civil rights and freedoms. This presents a paradox for the Nordic countries. Lawyers are not especially visible in the public sphere yet political liberalism is more deeply entrenched than elsewhere. If correct, this suggests either a case of Nordic exceptionalism or a problematic theory. This paper focuses on Norway. Beginning with the emergence of lawyers in the 1600s, it traces the legal profession’s engagement with the development and defense of political liberalism. This is complemented by a quantitative content analysis of interventions by the Advokatforeningen (law society). The paper argues that the results should prompt us to rethink legal complex theory more generally. The legal profession will only mobilize broadly for political liberalism when: (1) committed individual lawyers are able to overcome collective action dilemmas in the profession and (2) lawyer-centric forms of mobilization are viewed as less costly or more appropriate than the alternatives.","PeriodicalId":318823,"journal":{"name":"Legal Ethics & Professional Responsibility eJournal","volume":"37 1","pages":"0"},"PeriodicalIF":0.0,"publicationDate":"2016-06-03","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"132435659","PeriodicalName":null,"FirstCategoryId":null,"ListUrlMain":null,"RegionNum":0,"RegionCategory":"","ArticlePicture":[],"TitleCN":null,"AbstractTextCN":null,"PMCID":"","EPubDate":null,"PubModel":null,"JCR":null,"JCRName":null,"Score":null,"Total":0}
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