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如何才能最好地幫助台灣的社會生活在一個法治社會 / 陸台蘭的導師、台灣的好朋友 Robert2024/10給台灣年輕律師的一封信(Bob) 中文翻譯僅供參考

如何幫助台灣生活在一個法治社會 / Robert 親愛的同事們: 許多年前,我還是個年輕的律師。現在我是老律師了。一路走來,我經歷了各種各樣的生活經歷,有好的,有壞的,但大多數都是綜合的。從那次經驗中,許多操作原則或「道路規則」已成為我實踐的堅實組成部分。您可能對它們感興趣,也可能不感興趣,但我會與您分享,以防萬一。 將來,當您的職業生涯接近尾聲時,您應該考慮傳承您的經驗,這些經驗可能會為您的繼任者未來的職業生涯提供參考。從事某一職業的每一代至少應該盡力幫助下一代改進和維持該職業。服務目標和集體(和個人)高標準是使法律執業成為一種職業而不僅僅是另一種謀生方式的重要組成部分。 您將教授並接受許多關於如何成為「優秀律師」的課程。也許寫下您的一些建議將是傳遞您職業生涯課程的一種方式。 指導和健康習慣 法律職業是現代工商業社會的必要組成部分。如果律師不能維持相當嚴格的謹慎和誠信標準,社會,你們的社會,將會被削弱。您個人也會發現,如果您以專業水平誠實行事,晚上會更容易入睡。 我很幸運有一位導師比爾·吉本斯(Bill Gibbons),他總是走捷徑。他是我的第一位老闆,1966 年我開始工作時,他是貝克·麥堅時(Baker & McKenzie) 的合夥人。羅(Dolly Lo) 年長,當時她在貝克·麥堅時(Baker & McKenzie) 作為暑期實習生開始了她的職業生涯。 比爾從未向我講授遵守規則、走捷徑的道德責任。他只是沒有試圖偷偷溜過停車標誌,希望沒人注意。很多時候,沒人看。然而,有時,也許是在意想不到的時刻,有人在看著。 我非常悲傷地看到一些同事的職業生涯被毀,他們以為自己可以在一件小事上做一些當時看來很小的謊言而逃脫懲罰。律師不能指望「小謊言」就能逃脫懲罰。特別是當該聲明是經過宣誓並受到偽證處罰的情況下。即使在「大法」領域,職業生涯也已經結束,因為人們錯誤地認為,一個適度的謊言是值得說的,也許「就這一次」。 我總是想知道,如果我沒有從我粗暴的第一位導師比爾·吉本斯那裡學到榜樣,我可能會做什麼。也許我會有抵抗誘惑的堅強性格,也許不會。幸運的是,我很早就養成了說實話的習慣,從而避免了做出艱難的道德選擇的困難,在我職業生涯接下來的 22,000 天裡一次只說一句話。試著養成讓你遠離說「善意的」或僅僅是「可接受的」謊言的誘惑的習慣會帶來非常大的實際回報。永遠記住,你比你想像的更弱。盡量減少對自己道德力量的依賴。 我過著無可指責的生活嗎?絕對不是。但我很幸運,能夠透過減少失敗的機會來避免同樣多的誘惑。這些好運在很大程度上是由於簡單地形成了說實話、「走捷徑」的結果。這比決定作為例外說實話要容易得多。也許你與眾不同。 為什麼當律師? 我決定在馬薩諸塞州劍橋市哈佛大學的第三年和最後一年學習法律。哈佛大學有一個項目,如果你能通過不同類別的各種主題考試,你可以跳過大一。我父親擔心我如果按照正常的四年時間待下去就會成為一名專業學生,所以我必須決定在哈佛的第三年做什麼,比我計劃的提前了一年。我很少考慮法律而不是醫學或公海上的生活。 20歲時,我期望能永遠活著,並不急於用自己的兩隻腳站起來。 我對「普通法」(英語世界所遵循的司法判決制度)有些好奇。我想知道它是否可以擴展我在本科時開始的對柏拉圖和亞里斯多德“自然法”哲學的探究。 我沒有錢上法學院,甚至不確定法律對我來說是否是個明智的職業。因此,我安排參加海軍陸戰隊軍官候選人計畫。我們的想法是在海軍陸戰隊服役 3-4 年,然後如果還有意義的話就讀法學院。 哈佛法學院接受了我的探索性申請,甚至提供了慷慨的經濟援助。 1963 年畢業後,我決定不加入瑪麗家族,而是直接進入法學院。 當我到達哈佛法學院時,大約六週後我發現自然法哲學與法院在製定和適用「普通法」方面的務實運作目標之間沒有任何有意義的聯繫。但我對如何利用法律來維持社區中人們之間的秩序關係感到好奇。 這說明了「生活」是由計劃和意外驚喜混合而成的不言而喻的道理。披頭四應該觀察到「生活就是當你有其他計劃時發生的事情」。 我提到這一點是因為你們中的許多人可能天生就沒有透過法律實踐來管理社會的深刻而持久的承諾。你和我一樣,可能已經成為一名律師,因為沒有其他明顯更好的方式來完成你一生的工作。但一旦進入其中,你就必須以正確的方式去做,否則就出去。律師執業是一種職業,而不僅僅是一種謀生方式。其他人依賴你。如果你承擔起這個負擔,你就不能因為你對客戶的問題不感興趣或你有其他更好的時間利用方式而草率地完成工作。一旦你解決了客戶的問題,問題就不再是你的了。 有些人可能決定從事法律工作是為了賺很多錢。壞主意。如果你做得正確,你不太可能有很多時間來花你賺到的錢。而且你不太可能賺到足夠的錢來保護你的家人免於工作等。銀行家。 我的一些法學院同學已經成為億萬富翁,成為私募股權投資者和基金經理人。他們在嘗試了5-10年的「大法」後,做出了轉行的正確選擇。這對他們有好處,對客戶也有好處,如果他們無法全心全意地關注客戶的問題,他們可能會受到傷害。 處理狀況 不要把時間浪費在一廂情願或藉口上 避免使用“would a,can a,shoulder”(註1)。永不放棄。 (註1:如果我“能夠”擁有其他人的所有特權,那麼我“本來”會成功,並且一個公平的社會“應該” 為我做了更多。所以我不會用自己的方式解決這種情況,因為我的情況不是我的錯。) 盡量安排好你的事務,留一些容錯空間。並為生活給你的一切感到高興。你的一生只有一次旅程,如果你把它浪費在想知道如果你更加努力,或者成為一個更好的學生,或者更高,或者其他什麼的話會發生什麼,那將是一種極大的恥辱。 羅多莉(Dolly Lo)就是一個擁有豐富天賦的人的例子,但她也必須透過自己的努力來克服許多困難。她並不享受不間斷的成功生活。她和我們其他人一樣,也經歷過起起落落,在「低潮」的艱難處境中,包括她上次生病時,她從未放棄。她從來沒有習慣盯著自己的肚臍眼。她問上帝為什麼她要面對這樣的逆境。但她問這個問題的時候是認真的,沒有自憐。最終,她得到了一個讓她充滿活力的答案,而不是毫無意義和浪費的痛苦。 如果你有很大一部分天賦,這顯然會更容易,但我們每個人每天都有選擇。我們可以為自己感到難過,或者我們可以嘗試處理可能可以處理的具體問題。 請記住,您的法律實務符合更大的圖景 從 1978 年開始,多莉和我討論了有關她剛開始的職業生涯的許多事情。這些討論的一個重要部分包括律師在現代已開發國家和發展中國家(尤其是台灣)的角色。 1978 年夏天,她從威爾斯利學院畢業,完成了哈佛法學院的第一年課程。她很好奇貝克麥堅時等大型國際律師事務所的律師每天到底在做什麼。她想知道他們的行為如何影響社會與美國和歐洲大企業的互動。對於成功的西方經濟體來說,似乎如此重要的「法治」的作用是什麼?這個想法該如何調整才能在台灣使用? 我們在她的餘生中繼續討論帽子。我們不是坐在柏拉圖洞穴裡辯論不同可能的政府形式的哲學家國王。相反,我們是兩個人,針對一家大型律師事務所中反覆出現的情況制定應對措施,處理重大商業問題,這些問題對特定客戶很重要,而且對我們賴以生存的社會也很重要。我們看起來截然不同,男性、女性、亞洲人、白人,但我們的看法卻驚人地相似。 多莉當然對自己作為律師的成功感興趣,但她也熱衷於幫助加強台灣作為一個可行和充滿活力的社會的發展。她可能發現與我交談有助於測試她對自己作為一名在中國執業的受過西方教育的律師角色的看法。台灣只有對其他國家的經濟福祉變得重要,才能繼續維持自身。這反過來又需要穩定的商業環境。她對發展由外國監督者為外國人經營的殖民地經濟沒有興趣。資金和創意的外國直接投資對於台灣的長遠未來至關重要,但這只是路線,而不是目的地。 為了超越農產品出口(香蕉、鳳梨、蘑菇和蘆筍)的生產,台灣必須利用其唯一真正的自然資源:有才華且勤奮的人口,以及許多未充分就業的年輕人。為了讓這些有才華的年輕人留在台灣發展一個繁榮和安全的社會,經濟環境必須提供他們至少與其他地方同等的機會。 為了提供一個環境,​​讓有才華的年輕人能夠為他們、他們的家庭和他們的子孫後代看到一個合理的未來,道路規則必須相當明確。長期的辛勤工作必須有可能獲得回報。在相當長的一段時間內,人們之間的相處方式必須有一些防護措施。法治政府而非只依賴古典儒家關係。 在台北貝克麥堅時暑期實習結束後,她回到哈佛法學院完成最後兩年的學業。畢業後,她去了波士頓一家優秀的公司工作,以獲得有用的實務經驗。我幫助她選擇哪家公司可能會提供在她返回台灣後有用的工作經驗。回國後,她將參與建立和維護一個健全的現代社會,其工作規則將為未來的台灣奇蹟提供框架。 在多莉的職業生涯中,儘管過早結束了,但她為台灣的法治做出了許多貢獻。最重要的貢獻是嘗試招募和培訓下一代,讓他們繼續並改進工作。建立一個具有公平競爭環境和已知規則的社會,人們可以在相當安全的環境中生活和工作,他們的辛勤工作可以得到回報。 這個體系當然並不完美,但它比一個你的未來受制於統治階級一時興起的社會要好得多,統治階級自信地知道什麼是最好的,不需要分享規則知識。 台積電是台灣目前對世界至關重要的一個例子。它是由才華橫溢且非常勤奮的工程師創建和建造的; TMSC 不是律師建立的。但工程師們可以在台灣建立台積電,因為法治為他們和他們的家人提供了一個可以生活和工作的社會框架。 對抗過程不是個人戰爭 好主意 vs 個人榮耀 人們往往喜歡自己的想法。在複雜的談判中。我發現,當機會出現時,讓我的對手發現我已經想到的一個想法,作為解決利益衝突的一種方式,有時很有用。如果我主張這個解決方案,談判對手可能會拒絕它,而不考慮它是否真的對他方有用。 如果你能幫助對方提出你認為自己有的好主意,那麼成功的機會就會大得多。如果你能把注意力集中在有利於你的客戶而不是你自己的事實上,那麼客戶通常會得到更好的服務。舉個例子,我記得小時候參加過一次重要審判的結案陳詞。一名工人在芝加哥的一個建築工地上從高處墜落,受了重傷。核心問題是,這名工人自己的行為魯莽到了何種程度,成為了他受傷的主要原因。當時的規則是,任何人都不能告訴陪審團保險公司將向雇主支付任何賠償金。原因是陪審團認為保險金確實不會花費任何人任何費用,儘管事實上保險只是從幸運和謹慎的人那裡拿走錢,然後將其轉移給不幸或不那麼小心的人。 辯護律師穿著一套非常昂貴的西裝。他的髮型很完美。他使用了複雜的詞語,顯示了他對語言的掌握。他作為一名非常成功的律師在陪審團面前走來走去。受傷工人的律師穿著一套廉價但不合身的西裝。他的表現並不令人印象深刻。他站在陪審團旁邊,說話非常輕聲,因此陪審團必須仔細聆聽才能聽到他的聲音。 儘管這名工人顯然沒有那麼小心,但他還是被判了極高的賠償金。昂貴的服裝和高價律師的形象,無言地傳達出某人有很多錢(可能是保險公司)才能請得起大牌律師。工人的律師很容易被遺忘。便宜的西裝。沒有複雜的言語。這只是一個關於一個窮人的故事,他受了重傷,餘生需要很多照顧。 我的結論是,有時最好的律師是隱形律師。辯護律師戴著財富標誌,像昂貴的律師一樣說話,傳達某處有很多錢。為了保護自己,他設法克服了禁止告知陪審團有可用保險金的規定。 我從未實踐過人身傷害法,但在那場審判中我學到了非常重要的教訓。這個故事的寓意是。請務必小心,不要混淆您的利益和客戶的利益。不需要公眾欽佩的律師可能會為您的委託人提供最好的服務。這通常對客戶不利。 盡量避免將自己或對手逼入沒有出口的角落 有時,贏得超出客戶最大利益所需的利益是很誘人的。為了解決爭議或合約談判,雙方往往必須放棄一些東西。在激烈的爭議中,律師有時會忽略客戶的利益,而專注於展現自己的才華。 有時,律師會認為這是一場零和遊戲,實際上可能存在一種妥協,這種妥協比經過長期鬥爭後取得的全面勝利更能滿足委託人的利益。為了避免僵局,盡量尋找機會讓對手丟一分而不感到尷尬。最明顯的例子是對手在較早的位置後提出矛盾的情況。不要強迫他承認他承認你之前的觀點更優越,而應該將這個新的、矛盾的陳述視為事實上的新想法,而且是一個非常好的想法。如果你能讓每個人都認為這是對手的主意,那就更好了。人們往往喜歡自己的想法。 為了給這些好的「新」想法留下空間,如果你能引導你的對手不要對事實或法律做出絕對的陳述來支持他的委託人的立場,那將會很有幫助。如果他創造了一個太緊的角球,如果沒有令人尷尬的讓步就無法退出,從長遠來看,你的工作將會更加困難。 如果同意客戶的立場意味著你的對手需要承認你實際上是房間裡最聰明的人,請盡量避免聲稱你是房間裡最聰明的人。客戶並沒有讓你找出誰可能是某個房間裡最聰明的人。 永遠不要相信自己的宣傳。 有才華的精英人士的一個普遍感覺是他們對自己評價過高。更糟的是,他們希望其他人承認他們確實有多棒。這可能是人性,但對執業律師來說卻是一種危險。當你沉浸在你名聲的榮耀(虛榮)之中時,你可能會忘記這一切的意義。 在我過去 30 年專注的領域——國際公司稅務中,我經常遇到類似的失敗,沒有認識到要解決的問題就是問題,而不是負責處理問題的特定問題解決者的聲譽。在辯論的時刻,一個肯定會失敗的論點是由律師陳述其公司的地位和他在公司中的地位開始的。聲譽對於吸引潛在客戶的注意力來說是很好的,但它不應該與解決方案混淆。 「因為我就是這麼說的」從來沒有說服力。 當我處於職業生涯中期時,我有機會與一家非常著名的律師事務所的一位非常著名的高級律師(“約翰”)就非常複雜的新金融工具的適當稅務處理問題進行了交流。我要求律師解釋他在一項交易中得出結論背後的一些推理,這將涉及大約 10 到 15 個邏輯推理步驟。他回應說,他上週在華盛頓特區,然後在一次社交招待會上會見了負責稅收政策的財政部助理部長(“弗雷德”),並且他描述了該交易我們只是在談判。然後他在電話中告訴我們所有人,「弗雷德」知道他所在的公司是一家甚麼樣的公司,也知道他是個什麼樣的律師,而且弗雷德沒有表示任何反對。這句話的目的是讓我站在我的立場上:弗雷德足夠重要,足以了解約翰和約翰的公司,弗雷德足夠重要,足以被邀請參加政府高級官員的招待會,並且足夠重要,足以引起注意那位高級官員來討論這種新的金融工具。我有點不知道下一步該怎麼做,但最後我問他:“你還有第二個自信的理由嗎?”在那次好奇的談話之後,有必要放棄交易,因為實際的法律原因,“第二個原因:我問過,是不夠的。”約翰混淆了他善於思考的名聲和實際思考問題的需要。 大約三週後,財政部發布通知,政府將對弗雷德的職位提出質疑。弗雷德懶惰地依賴自己的宣傳,這讓他和他的公司數十年努力獲得的聲譽遭受了不必要的傷害。 問題是他顯然相信自己的宣傳。約翰與這筆交易有關聯這一事實本身就足以讓交易順利完成。這種想法是一種危險的自我放縱。您的聲譽可能會幫助您說服其他人,但很少會以犧牲處理真實事實和適用法律的合理推理為代價。 換句話說,不要欺騙自己。你仍然需要站起來,一次把褲子穿在一條腿上。你不能違反萬有引力定律,在空中跳躍並同時穿上兩者。其他人可能會認為你有特殊的技能、品質和判斷力。如果對結案有幫助那就太好了,永遠不要相信。永遠不要欺騙自己 (註2.我試著回想起很多年後,當我接受任命,擔任與弗雷德在公司類似的職位時。 財政部。人們總是很容易相信自己的宣傳,即使你意識到自己的弱點其他的。) 嘗試理解複雜的立法或法規的要點。 作為一名國際稅務律師。我的職責經常是解釋影響大量資本或智慧財產權分配的冗長複雜的條款。通常,新的立法是由不太熟悉金融交易的人起草的。法規可能是由稅務官員起草的,他們本身對所監管的交易的性質並沒有豐富的經驗。我們人類是容易犯錯的。 在嘗試理解和應用複雜且經常不明確的法律法規時,首先要嘗試弄清楚某人試圖解決的問題非常重要。至少在美國,可以透過研究國會有關委員會發布的各種委員會報告來回顧立法的歷史。通常也可以確定稅務機關認為其試圖解決的問題是什麼。 當我開始我的職業生涯時,我沒有參與美國的國際貿易和投資稅收工作。我很快就發現,如果不考慮稅收的影響,就無法理解國際貿易和投資,因為有許多不同的國家可能涉及交易或投資。每個國家都希望對供應鏈的某些部分行使徵稅管轄權。 當我開始在這個領域工作時,我的導師(方角的比爾吉本斯)給了我一本書來讀。他說:「迪爾沃斯,如果你不理解F 子部分,你將永遠一事無成。」他給我的這本書是他大約10 年前寫的書。頒布了F 子部分。 該書列出了美國跨國公司組織對外貿易和投資的多種方式。經過大量研究和多次聽證會後,國會的最終意見中的一些選項是「問題」。我的導師明白,除非我先了解國會認為要解決的問題是什麼,否則我不會理解立法解決方案「F 子部分」。當時,F 子部分被認為是有史以來頒布的稅法中最複雜的部分。光靠背單字是無法理解的。 因此,在嘗試理解可能適用於您的客戶的法定語言或監管語言之前,必須先真正理解問題。試著弄清楚國會、議會、歐盟委員會或經合組織認為自己正在處理的問題到底是什麼。感知到的問題對你來說可能不是問題,但是,如果政府認為這是一個問題,你就必須把它當作一個問題來處理。 換句話說,你無法透過記住所有居民的電話號碼來了解台北這座城市。 法律教育常常包括記憶規則。從某種程度上來說,記憶背離了規則,教育不夠。至此,幫助委託人乃至整個社會使複雜的現代法律體系發揮作用就成為執業律師的職責。 這封信已經太長了。也許你們中任何一個覺得這本書值得一讀的人都可以用自己的觀察來結束這本書,看看你們這一代人和下一代人如何才能最好地幫助你們的社會生活在一個法治社會,而不是只照顧朋友的人所統治的社會。 多莉盡了最大的努力。我們都應該如此。 謹致問候 鮑伯




Robert H Dilworth
Washington, DC

Dear colleagues: 

Many years ago, I was a young lawyer. Now I am an old lawyer. Along the way I had a wide range of life experiences, some good, some bad, but most were a combination. From that experience a number of operating principles or “rules of the road” have become firm components of my practice. They may or may not be interesting to you, but I will share them with you in case they might be. 

In the future, when you are near the end of your careers, you should think about passing on your experiences that might inform your successors in their future professional lives. Each generation in a profession should at least try to help the next generation Improve and maintain the profession. The goal of service and collective (and individual) high standards is an important part of what makes the practice of law a profession and not just another way to make a living.

You will give and receive many lessons on how to be a “good lawyer.” Maybe writing down some of your suggestions will be one way to pass on some of your professional life lessons. 

Mentorship and Healthy Habits 

The legal profession is a necessary component of a modern industrial and commercial society. If the lawyers do not maintain reasonably robust standards of care and integrity, the society, your society, will be diminished. You will personally also find it easier to sleep at night if you perform honestly at a professional level. 

I was very fortunate to have a mentor, Bill Gibbons, who always cut square corners. He was my first boss, a partner at Baker & McKenzie when I began to work in 1966. He was then about as much older than I as I, in 1978, was older than Dolly Lo when she began her career as a summer intern at Baker & McKenzie Taipei. 

Bill never lectured me on the moral duty to play by the rules, to cut square corners. He just did not try to sneak past the stop signs in the hope that no one was watching. Many times, no one is watching. Sometimes, however, and perhaps at an unexpected moment, someone is watching. 

I have watched with great sadness the destruction of careers of some colleagues who thought they could get away with what seemed at the time a small untruth in a small matter. Lawyers cannot count on getting away with “minor lies.” Particularly when the statement is on oath and under penalties of perjury. Careers have ended, even in “big law,” because of the mistaken belief that a modest lie was worth telling, perhaps “just this once.” 

I always wondered what I might have done had I not learned by example from my gruff first mentor, Bill Gibbons. Maybe I would have had the strength of character to resist temptation, maybe not. Fortunately, I formed the habit early of telling the truth, and thus being spared the difficulty of making hard moral choices, one statement at a time for the next 22,000 days of my career. There are very great practical rewards trying to form habits that keep you away from the temptation to tell “good” or merely “acceptable” lies. Always remember that you are weaker than you would like to believe. Try to minimize the need to rely on your own moral strength. 

Have I led a blameless life? Absolutely not. But I have been fortunate in having been able to avoid as much temptation by reducing the opportunities to fail. Much of that good fortune has resulted from simply forming a to tell the truth, to “cut square corners.” It is a lot easier than deciding to tell the truth as an exception. Maybe you are different. 

Why Are You a Lawyer?

I decided to study law during my third and last year at Harvard College in Cambridge, Massachusetts. Harvard had a program that permitted you to skip your freshman year if you could pass various subject matter examinations distributed across various categories. My father worried that I would become a professional student if I stayed for the normal 4 years, so I had to decide what to do in my third year at Harvard, a year earlier than I had planned. I had given little thought to law instead of medicine or instead of life on the high seas. At age 20 I expected to live forever, and there was no rush to stand on my own two feet. 

I had some curiosity about the “common law,” the system of judicial decision making followed in the English-speaking world. I wondered if it might extend the inquiry I had begun into the “natural law” philosophy of Plato and Aristotle as an undergraduate. 

I had no money for law school, nor even the certainty that law would be a sensible profession for me. So, I arranged to enlist I the Marine Corps officer candidate program. The idea was to spend 3-4 years in the Marines, then attend law school if it still made sense. 

Harvard Law School accepted my exploratory application and even provided generous financial aid. I decided not to join the Maries and to go straight to law school after graduating later in 1963. 

When I arrived at Harvard Law School, I discovered after about 6 weeks that there was no meaningful nexus between the natural law philosophy and the pragmatic operational goals of the courts in developing and applying “common law.” But I was intrigued by the way the law was used to pursue orderly relations among the people in a community. 

This illustrates the truism that “Life” is comprised of a mixture of plans and unexpected surprises. The Beatles were supposed to observe that “Life is what happens when you have other plans.” 

I mention this because many of you may not have been born with a deep and abiding commitment to managing society through the practice of law. You, like me, may have become a lawyer because there was no other obviously better way to do your life’s work. But once in it, you must do it the right way or get out. The practice of law is a profession and not just a way to make a living. Other people depend on you. If you take up that burden, you are not free to do a sloppy job just because you are not interested by the client’s problem or you have another better use of your time. Once you take up a client’s problem, it is not all about you. 

Some may have decided to practice law in order to make a lot of money. Bad idea. If you do it correctly, you are unlikely to have much time to spend the money you make. And you are unlikely to make enough to protect your family from having to work, etc. In other words, if you do not find real satisfaction in solving the problems, and you want to make money, maybe you should be an investment banker instead. 

Some of my law school classmates have become billionaires as private equity investors and fund managers. They made the correct choice to change their line of work after trying “big law” for 5-10 years. Good for them and good for the clients they might have injured if they had been unable to give their undivided attention to the client’s problem.” 

Deal with the Situation 

Do Not Waste Time on Wishful Thinking or Excuses

Avoid “would a, could a, shoulder.”1 Never give up. 

1 I “would have” been successful, if I “could have” had all the privileges of the other guy, and a fair society “should have” done more for me. So I will not work my way through this situation because my situation is not my fault.

Try to arrange your affairs with some margin for error. And rejoice in what life gives you. You only have one journey through this life, and it would be a great shame to waste it on wondering what would have happened if you had just worked harder, or been a better student, or taller, or whatever. 

Dolly Lo is an example of a person who had abundant natural talents, but someone who also had to work her way through quite a few hard situations. She did not enjoy a life of uninterrupted successes. She, like the rest of us, had ups and downs, During the “downs” In tough situations, including her last illness, she never gave up. She never settled in to staring at her navel. She asked God why she had to deal with such adversity. But she asked that question earnestly and without self-pity. In the end, she received an answer that filled her with life rather than pointless and wasteful bitterness.  It is clearly easier if you have a big portion of talent, but each of us has a choice every day. We can feel sorry for ourselves or we can try to deal with the specific pieces that might be manageable. 

Remember that Your Practice of Law Fits into a Bigger Picture 

Beginning in 1978, Dolly and I discussed many things about the career she was just beginning. An important part of those discussions included the role of lawyers in modern developed and developing countries, including, in particular, Taiwan. 

By summer 1978, she had finished her first year at Harvard Law school after graduating from Wellesley College. She was curious about what lawyers in big international firms like Baker & McKenzie actually do, day in day out. She wondered how what they do affected the society in its interaction with big American and European companies. What was the role of the “rule of law” that seemed to be talked about so important to successful Western economies? How should that idea be adjusted for use in Taiwan. 

We continued hat discussion for the rest of her life. We were not philosopher kings debating the different possible forms of government while sitting in Plato's cave. We were instead two people working out responses we might each make to recurring situations in a big law firm dealing with substantial commercial issues that were important to the particular clients but also to the society in which we made our home. We looked quite different, male-female, Asian-Caucasian, but we had surprisingly common perceptions. 

Dolly was of course interested in her own success as a lawyer, but she was also keenly interested in helping to reinforce the development of Taiwan as a viable and vigorous society. She may have found talking with me to help to test her perceptions about her role as a western-educated lawyer practicing in China. Taiwan could continue to maintain itself only if it were to become important to the economic wellbeing of other countries. That in turn required a stable business environment. She had no interest in developing a colonial economy operated by foreign overseers for foreigners. Foreign direct investment of money and ideas were essential to Taiwan’s long-term future, but that was just the route, not the destination. 

In order to progress past the production of agricultural exports (bananas, pineapples, mushrooms, and asparagus) Taiwan would have to harness its only real natural resource: a talented and hard-working population with many underemployed young people. In order for those talented young people to stay in Taiwan to develop a prosperous and secure society, the economic environment would have to provide them opportunity at least equal to other available places. 

In order to provide an environment in which talented young people would see a reasonable future for them, for their families, and for their future generations, the rules of the road had to be fairly clear. There had to be a likelihood of reward for hard work over a long period of time. There had to be some guardrails on how people deal with each other over a relatively long period of time. Government by law rather than by relying only on the classical Confucian relationships. 

After the summer internship at Baker McKenzie Taipei, she returned to finish her final two years at Harvard Law school. On graduation she went to work for a good Boston firm in order to obtain useful practical experience. I helped her select which firm would likely provide the kind of work experience that would be useful upon her certain return to Taiwan. After returning she would join in the building and maintaining of a sound modern society with working rules that would provide the framework for a future Taiwan miracle. 

In Dolly’s career, albeit prematurely cut short, she made a number of contributions to the rule of law in Taiwan. The most important contribution was to try to recruit and train the next generation who would continue and improve the work. The building of a society in which there is a fair playing field with known rules of the road in which people can live and work in a reasonably secure environment and in which they can be rewarded for hard work. 

The system of course is not perfect but it is much better than a society in which your future is subject to the whims of a ruling class that is confident that it knows what is best and does not need to share knowledge of the rules. 

Taiwan Semiconductor is an example of Taiwan's present critical importance to the world. It was created and built by talented and very hard-working engineers; Lawyers did not build TMSC. But the engineers could build TSMC in Taiwan because the rule of law provided them a framework for a society in which they and their families could live and work. 

The Adversary Process is Not Personal Warfare 

Good ideas vs Personal Glory 

People tend to love their own ideas. In complex negotiation. I have found it occasionally useful, when the opportunity arises, to let my counterpart discover an idea that has already occurred to me as a way to resolve competing interests. If I were to advocate the solution the adversary in the negotiation might reject it without thinking through whether it was really useful for his side or not. 

If you can help the other guy on his own come up with the bright idea you think you have had, it has a much better chance of succeeding. If you can keep the focus on the facts that favor your client instead of on you, the client will usually be better served. As an example, as a very young I recall attending the closing arguments in an important trial. A workman had suffered terrible injuries falling from high in a construction site in Chicago. The core issue was the extent to which the workman’s own behavior had been reckless enough to have been the major cause of his injuries. The rule at the time was that no one could tell the jury that an insurance company would pay any awards against the employer. The reason was that juries assumed that insurance money really did not cost anyone anything, even though in fact insurance simply takes money from lucky and careful people and transfers it to unfortunate or less careful people. 

The lawyer for the defense wore a very expensive suit. His haircut was perfect. He used complicated words, demonstrating his command of the language. He walked about in front of the jury as a very successful lawyer. The lawyer for the injured workman wore an inexpensive, poorly fitting suit. He was unimpressive. He stood ear the jury and spoke very softly, so the juries had to listen carefully just to hear him. 

The workman was awarded extraordinarily high damages, even though he was clearly not as careful as he could have been. The expensive clothing and image of a high-priced lawyer conveyed without words that someone had a lot of money (probably an insurance company) in order to afford the big shot lawyer. The workman’s lawyer was very forgettable. Cheap suit. No complicated words. Just the story about a poor man who was very injured and would need a lot of care for the rest of his life. 

My takeaway was that sometimes the best lawyer is an invisible lawyer. The defense lawyer, by wearing the indicia of wealth and talking like an expensive lawyer communicated that there was plenty of money somewhere. He managed to overcome the rule, for his own protection, against informing the jury that there was insurance money available. 

I never practiced personal injury law, but I learned a really important lesson at that trial. The moral of the story is. Be very careful about confusing your interest and the client's interest. Your client may be best served by a lawyer who does not require public admiration Showing off how smart you are can shift the focus from the facts to the lawyer. That is usually not good for the client. 

Try to Avoid Painting Yourself or Your Opponent into a Corner with No Exit 

It is sometimes tempting to win more than the best interests of your client require. In order to reach a settlement of a controversy or contract negotiation, it is more often than not the case that each side must give up something. In the heat of the controversy, the lawyers can sometimes lose sight of the client’s interest and focus on demonstrating how brilliant they are. 

Sometimes lawyers see a zero-sum game when there might actually be a compromise that will better serve the client’s interest than might total victory achieved after a prolonged struggle. To avoid deadlock, try to look for opportunities for your opponent to concede a point without being embarrassed. The most obvious example is the case of a contradiction your opponent makes after an earlier position. Rather than forcing him to admit that he was conceding your superior prior argument, treat the new, contradictory, statement as in fact new and a really good idea. If you can let everyone think it was your opponent’s idea, so much the better. People tend to love their own ideas. 

In order to leave room for such good “new” ideas, it is helpful if you can steer your opponent away from making absolute statements about the facts or the law in support of his client’s position. If he creates too tight a corner, wit no exit without an embarrassing concession, your job will be harder in the long run. 

Try to avoid claiming that you are the smartest person in the room if agreeing to your client’s position means that your opponent needs to concede that you are in fact the smartest person in the room. The client did not engage you to figure out who might be the smartest person in some room. 

Never believe your own publicity.

 A common feeling among talented elitist people is that they think too highly of themselves. Worse, they want other people to acknowledge how terrific they really are. That may be human nature but it is a danger for lawyers practicing law. You may forget the point of it all, while basking in the glory (the vanity) of your reputation. 

In my area of concentration for the last 30 years, international corporate taxation, I have frequently encountered a similar failure to recognize that the problem to be solved is the problem, not the reputation of the particular problem solver who has been engaged to deal with the client’s problem. In moments of debate, an argument that is sure to lose is one that begins with a recital by the lawyer of the standing of his firm and his standing in the firm. A reputation is fine for purposes of attracting the attention of prospective clients, but it should never be confused with the solution. “Because I said so” is never persuasive. 

Once I was in midcareer and I had occasion to deal with a very prominent senior lawyer (“John”) from a very prominent law firm on an issue of the proper tax treatment of very complicated new financial instrument. I asked the lawyer to explain some of the reasoning behind his conclusion in a transaction that would involve about 10 or 15 logical steps of reasoning. He responded by explaining that he had been in Washington DC during the prior week, that he had then met with the Assistant Secretary of the Treasury for Tax Policy (“Fred”) at a social reception, and that he had described the transaction about which we were just in negotiation. He then told all of us on the call that “Fred” knew what kind of a firm he was with, and knew what kind of a lawyer he was, and that Fred had not voiced any objection. This statement was intended to put me in my place: Fred was important enough to know John and John’s firm, that Fred was important enough to be invited to a reception with a high-ranking member of the government, and important enough to get the attention of that high ranking official to discuss this new financial instrument. I was a little unclear what to do next but I finally asked him, “Did you have a second reason for your confidence?” Following that curious conversation, it became necessary to abandon the transaction because the actual legal reasons, the “second reason: I asked about, were insufficient. John had confused his reputation for thinking with the need to actually think through the problem.

About 3 weeks later, the Treasury Department issued a notice that the government would contest Fred’s position. Fred’s laziness in relying on his own publicity cost him and his firm unnecessary injury to a reputation gained after decades of hard work. 

The problem was that he apparently believed his own publicity. The mere fact that big deal John was associated with the transaction should have bene enough to carry it over the finish line. That sort of thinking is a dangerous self-indulgence. Your reputation may help you persuade other people, but rarely will it do so at the expense of sound reasoning dealing with the real facts and the applicable law. 

In other words, don't fool yourself. You still need to get up and put your pants on one leg at a time. You cannot defy the laws of gravity and jump in the air and put both on at the same time. Other people may ascribe to you special skills, qualities, judgment. That's fine if it helps in a close case never believe it. Never kid yourself 2.

 2 I tried to remember that many years later when I accepted an appointment to a position similar to Fred’s in the Treasury Department. It is always tempting to believe your own publicity, even when you recognize the weakness in others.

Try to understand the point of complicated legislation or regulation.

 As an international tax lawyer. It has been my function often to interpret long complicated provisions affecting the allocation of large amounts of capital or intellectual property. Often there is new legislation drafted by people who do not have great familiarity with financial transactions. Regulations may be drafted by tax officials who themselves do not have extensive experience with the nature of the transactions they are regulating. We human beings are fallible.  

In trying to understand and apply complicated and frequently unclear laws and regulations, it is important to start with trying to figure the problem someone is trying to solve. In the United States, at least, it is possible to review the history of the legislation by studying various committee reports published by the concerned committees of the Congress. It is also often possible to determine what the problem was that the tax administration thought it was trying to solve. 

When I began my career, I had had no involvement with US taxation of international trade and investment. I soon discovered that international trade and investment cannot be understood without considering the effect of taxation because there are many different countries that may touch a transaction or investment. Each country will wish to assert taxing jurisdiction over some piece of the supply chain. 

When I began to work in this area my mentor (Bill Gibbons of the square corners) gave me a book to read. He said “Dilworth you will never amount to anything if you do not understand subpart F." The book he gave me was a book he had written about 10 years earlier. The Congress had enacted subpart F 5 years after he published his book.  

The book laid out a number of ways to organize foreign trade and investment by US multinational companies. Some of the options were “problems” in the final opinion of Congress, after much study and many hearings. My mentor understood that I would not understand the legislative solution, “subpart F,” unless I first understood what the problem was that the Congress thought it was solving. At the time, subpart F was considered the most complicated part of the tax code ever enacted. There was no way to understand it simply by memorizing the words.  

It is therefore essential to start with a real understanding of the problem before trying to understand the statutory language or the regulatory language that may apply to your client. Try to figure out what exactly is the problem that the Congress or the Parliament or the European Commission or the OECD thinks it is dealing with. The perceived problem may not seem to be a problem to you, but, if the government thinks it is a problem, you have to deal with it as a problem. 

In other words, you cannot understand the city of Taipei by memorizing the phone numbers of all the residents. 

Too often legal education consists of memorizing rules. To some extent that memorization is divorced from the point of the rules, the education is insufficient. At that point, it becomes the duty of the practicing lawyers to help the clients and the broader society make the complicated modern legal system work.  

This letter is already too long. Perhaps any of you who finds it worth reading might finish it with your own observations about how your generation and the next generation can best help your society live in a society ruled by law and not by men who take care of only their friends. 

Dolly gave it her best efforts. So should we all.

With kind regards 

Bob

October 20, 2024
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