Legal Research Working Outline

Legal Research Working Outline

The lay of the land: The importance of legal research, legal authorities, and research media

Importance of Legal Research I. Professional Conduct

a. Competent representation to a client.i. Legal knowledge

ii. Skilliii. Thoroughnessiv. Preparationv. Central to ethical obligation

b. Good legal researchi. Correct – leading to law governing client’s situation

ii. Comprehensive – Addressing various issues raised by client’s situation and finding appropriate authorities

iii. Credible – Focusing on authorities that carry weight because of nature and quality

iv. Cost effective – It’s expensive. Do it the fastest/best way possible.

Legal Authorities HierarchicalI. Law

a. Examplesi. Case law

ii. Legislationiii. Admin decisionsiv. Rules of Procedure and ethics

b. Comes from 3 branchesi. First – federal/state judiciaries – creates precedent

ii. Second – legislative bodies fed/state create constitutions/statutes | local = charters and ordinances

1. Constitutions and charters: create government and define rights of citizens

2. Statutes and ordinances regulate behavior of individuals, corporations, and gov.

iii. Third – Administrative agencies1. Generate through issuing decisions and promulgating regulations

c. Always a combination of what will applyi. Find the mandatory authority and then the persuasive to fill gaps

II. Commentary

a. Examplesi. Encyclopedias

ii. Treatisesiii. Periodicalsiv. ALRv. Restatements

b. Created by individuals, non-governmental agencies, or governmental agencies not acting in a lawmaking capacity

c. Describes the law and explains how it came to be and gives a critiquei. Can influence law makers

III. Finding toolsa. Examples

i. Library catalogsii. Internet search engine

iii. Periodical indexesiv. Case digestsv. Statutory annotations

b. Not authority – helps you searchIV. Research media

a. Oldi. Microform, cds, now replaced by lexis/west and sometimes public websites

From Curiosity to Closure: 8 Cognitive TasksI. General

a. 4 phases done in 8 stepsi. Phases: Curiosity, content and context, consultation, and closure

ii. Steps: 1. Consider clients situation (1+2)2. Proceed to determining which authorities and resources to use (3+4)3. Spend time working with sources (5, 6,+ 7)4. Stop (8)

b. Process called cognition – more aware of it, the betteri. Won’t lose track

c. Not a linear processII. Curiosity

a. Learn and react to client’s situationi. Construct a narrative of situation

1. Write out a cast of characters and ID the roles2. Create a timeline of key events3. Discern what each of the main characters would say4. Develop a short statement about client’s goal

ii. Process: Weighing the equities

1. What is appealing?2. What is not appealing?3. What is fair and just?4. If I were a lawmaker, what would I think?5. Possible solutions

b. Develop Research Terms and Research Issuesi. Understand legal language

1. Look at language of rule and research legal implicationii. Generating research terms

1. Generala. Research term: Expression of a concept you plan to researchb. Research Issue: Combination of terms in question

2. Step 1: Who, what, when, where, why?3. Step 2: Consider legal dimensions

a. Shat legal theory is applicableb. What relief do you seek?c. What stage in the game are you in?

4. Step 1+2 = 8 questions to form a pie5. Step 3: To get a list of words conveying your research terms, 3 tasks:

a. Spinning off additional wordsb. Analyzing the rootsc. Analyzing the phrasing

i. Step 3 generally1. First: synonyms/antonyms + broad and narrow

a. Hub and spoke (p. 33)b. Ladder (P. 33)

2. Second: Does a word have a root shared with pertinent words? Employ, employee, er, men ting, etc.

3. Consider phrases you have generatediii. Dictionaries and Thesauri

1. Developing terms: Use these sources to help understand and identify additional terms

iv. Formulating legal issues1. Determine legal significance of actions

III. Content and Contexta. List and Rank Potential Authorities

i. Know 2 things: location and timing of event1. Location: Potential jurisdictions2. Timing: Know what period to look for – state of law

ii. Start in commentaryb. Assess Available sources

i. Choose either print/online1. Scope of coverage: Does the source have as full a range of the authority

you need?2. Time period: Retrospective and recent: Does the source go back enough

to encompass what you need?3. Credibility: Is it sufficiently credible that you would cite to a court?4. Ease and efficacy of access: Limited time and energy, can you

reasonably quickly id both the source and pertinent passages?5. Reading and Retention: Can you read quickly to find what you need?6. Updating: How are will it be to update research after you research?7. Cost

IV. Consultation a. Use your terms and issues to locate pertinent passages

i. Success measured by 2 things1. Recall – id of pertinent passages2. Precision – avoid nonpertient

a. Double-square on p. 43ii. Paper options

1. Index: Alphabetical list of covered subjects with reference to where subject is discussed.

a. Encyclopedias have their own indexes. b. Long, complex, with multiple minor subjects and cross-

references to other subjectsi. Look for major and minor subjects that correspond to or

are similar to your research terms; then move to specified part of the source.

2. List of topics: Overall organizational scheme3. Table of contents: Legal framework which you can place your client’s

situation4. If you know a pertinent case or statute – use table of authorities

iii. Online options1. Pro/con: Searchable database is cool – but sometimes terms too general

to yield good results2. Key-word searches don’t give you a good legal framework

a. To max advantages of key-word – skillfully employ various search-drafting options

3. When you don’t know must – natural language4. Boolean search –

Task Lexis WestSingle term ! and * root expand ! and * root expandSeveral word-phra. Space between “” around words

Mutual terms for the same concept

Or Space or OR

Exclusion of non-pertinent usage

AND NOTNOT W/#NOT W/sNOT W/p

%

Multiple-concept search

W/# or /# or PRE/#W/s or /sW/p or /pAND or &

/# +//s +/s/p +p&

5. X or Y =all of both6. X but not Y = X only7. X and Y = only shared terms8. X/p Y = instances where X and Y occur within same paragraph

iv. Sort the documents1. Once you have a list of docs, sort them efficiently

v. Hybrid means of access:1. Search by Topic or Headnote

a. Scanning successively narrower tables of contents, then adding search terms

c. Study Pertinent Passagesi. Scan your authority to answer:

1. How strong is it?2. How pertinent is it?3. How much assistance does it provide in and of itself?4. How much assistance does it provide through references to other

potentially important authorities?ii. If it is all of that, copy it.

iii. SQRRR –SQ3Ra. Uses reciting than the reviewing

2. Survey the source to see components and organization3. Pose questions that you think the source may answer4. Read the source to find answers5. Record what you have learned6. Review by looking over notes

d. Keep in mindi. Issue being researched

ii. Date of researchiii. Information needed to cite the authorityiv. The process used to get infov. Info you obtained and its implications for your position

vi. Next steps, including questions to consider and leads to pursuee. Research backward and forward from major authorities

i. Citing authority: shit currently reading. Within the authority are refs to older authorities

ii. Cited authority: one cited in the authority currently readingV. Closure

a. Stopi. Seeing the same authorities

ii. Diminishing returnsiii. Read commentary on sourceiv. Write analysis of client’s situation and look for hole.

b. Reach to clientc. Develop terms/Issuesd. List and rank authoritiese. Assess available sourcesf. Find pertinent passagesg. Study pertinent passagesh. Research back/forthi. Stop

Commentary

Encyclopedias

What is an encyclopedia, and why are they useful?I. Generally

a. Wide range of topics, alphabeticallyi. Broken down into

1. Parts2. Sections: Text along with footnotes citing to supporting authorities.

b. Two major: Both West Ownedi. 400 Topics – 150 books

1. AMJUR (on West and Lexis)2. CJS (West only)3. Updated annually

ii. Good to use at beginning of research for broad overview1. Also a finding tool.

c. Limitsi. Not written by experts

ii. Only generaliii. Not a complete authority for all pertinent cases

d. State encyclopediasi. Can be more useful than AMJUR or CJS

ii. More detailed for state

How do you research in and Cite encyclopediaI. Researching

a. Generali. Formulate an issue, select an encyclopedia

ii. Locate and read pertinent passagesiii. Get useful info and consider implicationsiv. Plan next steps

b. Paper good for beginningi. Strong internal finding tools

ii. Browsing is a good strategyc. Steps

i. Use the index or topic list to id a topicii. Look over topic’s intro material

iii. Read the topic’s outlineiv. Read the textv. Look for and read updates in the pocket part or supplementary pamphlet

II. Locating topics in encyclopediaa. 2 types

i. Index1. Amjur and CJS both have multi-volume indexes

a. Issued annuallyb. Shelved at end of the setc. Can also find by annual index

2. Encyclopediasa. Indexes are extensiveb. Complexc. Detailedd. Spend time looking up alternative termse. Cross references

ii. Topic list1. Amjur and CJS both provide alpha topic lists in their index volumes2. Synopsis, cross-refs to other topics, and refs to commentary

a. Topic outlines as welli. General and specific – good for an overview of big

picture3. Seek first to learn the pertinent legal rujles

a. Note implications and number of pertinent sectionsb. Look for refs to potentially pertinent authoritiesc. Reading all sections within a part of your topic = good strategy

4. Last – make sure its current

a. You will read the material in the main volume and then update that material by checking pocket part.

i. Pocket part = set of pages inserted into a pocket in the back of a bound volume; it provides additional citations and brings the bound volume up to date (no more than one year of the present)

ii. May provide additional text with supporting authorities or additional references

iii. Some don’t have pp’s – if recentiv. Others have so much updating material that they have a

separate supplementary pamphlet instead of a pocket part

5. Research efficiently when main volume updateda. Skim main volume to learn which sections are pertinent and

what the law has been and may still be.i. Then check updating material.

ii. Synthesize the main volume and updating material as you take notes

iii. Note whether a point comes from the main volume or pocket part

III. CITING ENCYCLOPEDIASa. Bluebook

i. 82 Am. Jur. 2d Wrongful Discharge §44 (2003).b. ALWD

i. 82 Am. Jur. 2d Wrongful Discharge §44 (2003).

What else?I. Tables of cited Laws and Cases

a. If you begin with Amjur or CJS with a citation to pertinent fed statute, regulation, court rule, uniform act, consult either encyc.’s Table of cited laws

i. Amjur1. Table listing statutes by names, Popular Names Table

ii. CJS1. Table of cases – permitting you to locate a discussion of a known case

II. News Topics Servicea. In addition to pp’s, Amjur has NTS

i. Looseleaf binderii. Topics too new to be located in bound valume

III. Correlation Tablesa. Topic may be reorganized to better reflect current law

i. If you want to find old law, look at correlation tableIV. Specialized Encyclopedias

a. Cover some major areas of lawi. Can be very good

Treatise

What is a treatise, and why are they useful?I. What is it?

a. Form of commentary that systematically and extensively explores a legal subjecti. Subject may be quite broad (like contracts or employment law)

ii. May be narrow (single statute protecting disabled workers)iii. Written by law profs, lawyers, and staff of legal publishing companies

b. Good onesi. Present thorough scholarly discussion

ii. 3 parts1. Text itself2. Internal finding tools like index or tables of contents and list of

authorities3. Supporting materials like appendix of statutes

iii. Explains the law, setting out rules, policies, and examples1. Few also critique the law and propose legal reforms2. Treatise text typically organize dby chapters and then by sections or

paragraphsiv. Has references and commentary sources

II. When to use it?a. Whene you know what subject your client involves, but need to learn the legal

framework and rulesb. Not the law – but can be persuasive if written by respected author

III. Draw backsa. Some are updated, many are notb. Some more credible, better researched, clearly organized, and more comprehensivec. May be a few subjects on which nothing yet written

IV. Publishinga. Most are books, either hardbound, softbound, or looseleaf

i. Loosleaf: separate pages in a binder, helps updatingb. What are they?

i. Textbooks - cases and materials on or readings inii. Study aids - Most study aids present the law in simple form and lack footnotes

(E’Es – Nutshells)iii. Manuals for legal education

1. CLE have institute in the name generallyiv. Hornbooks – Single volume treatise that explains principles of law in a field, and

written by well regarded scholar in the field

How do you research in and cite treatisesI. General

a. Formulate issue, locate good treatise, locate pertinent material, get useful shit for your client, and plan next steps

b. 2 approachesi. Paper and online

c. Paperi. How To

1. Locate through library catalog, shelf-browsing, recommendation, or reference in another source

a. Call number/reserve deski. Standard scheme of call numbers for legal subjects

created by congressb. Look in textbookc. Ask professor/librariand. Subject search on library search cataloge. Key word searchf. Coverage:

i. Pick a treatise with scope and detail you need. First single volume like hornbook, then detailed multi

g. Currencyi. Published or updated recently

ii. Check copyright dates of main volume and updating materials

h. Credibilityi. Some are classics – really good

ii. Cited in text books or course syllabusiii. Credentials of author

i. Organizationi. Topically

ii. Statute or claims and defenses, or chronologically, such as by phases or stages

iii. TOCiv. Indexesv. Table of authorities

j. Locate and read pertinent passagesi. Use index or TOC to locate petinent material w/I the

treatiseii. Some have summary tables

iii. Look for an explanation of law/policy/examples – and critique

k. Check for updates

i. Pocket parts – slip into pocket in coverii. Supplemental volumes

iii. Looseleaf supplementsiv. Looseleaf page replacements

ii. Reading at length – paper betteriii. Not many online yet

d. Onlinei. Services collection of sources on subject area

ii. Assess valueiii. Locate pertinent / run key word

1. Scan major topics in TOC2. Search within treatise or index

iv. Readv. General

1. Pros – updates quick2. Cons – not many available

II. Citinga. Bluebook

i. 9 Lex K. Karson, Employment Discrimination § 155.06 (2d ed. Supp. 2007).b. ALWD

i. Lex K. Larson, Emplyoment Disccrimination vol. 9, § 155.06 (2d ed., Matthew Bender Supp. 2007).

III. What else?a. Index to legal periodicals and booksb. Keeping up to datec. Historical Legal treatises

Legal Periodicals

What is a legal periodical and why are they useful?I. What is it?

a. Form of commentaryi. Articles on a range of legal topics published on a periodic basis

1. Quarterly, monthly, etcii. Pros:

1. Depth2. Narrow3. Several references and finding tools4. Discussion about trends

iii. Cons: 1. Loses currency quickly2. No updates

3. Some analysis is stupidb. 4 types

i. Law review1. Not only current state of the law, but explore underlying policies,

critique current legal rules, and advocate law reform2. Written by professors; lawyers; lawmakers, judges; and law students

a. Staffed by upper-class students who select and edit workb. 150 generalc. 250 special d. 1 volume a year in 2 – 8 issues, each with various papers

ii. Bar journals1. Bar associations pujblish

a. ABA Journal is the biggestb. Practical and cover lawyer issues – not just the law

iii. Commercial legal newspapers1. Emerging legal issues, oriented toward practicing lawyers2. Short and appear frequently

iv. Newsletters1. Report on new court decisions, changes in the law, carry legal notices,

and present stories abot interesting people or sifnificant events in the legal profession

How do you research in and cite?I. Researching in Periodicals

I. Processi. State research issue

ii. Using an index of periodical articles or key-word search in a peridocals database to id pertinent articles

iii. Reading articlesiv. Consider implications

II. Two approaches: Indexi. Index

1. Select index2. Conduct subject search and possibly keyword search in the index3. Assess the identified articles4. Scan and read articles you have chosen

ii. Online indexes preferable because current1. Paper involves multiple books and pamplhets2. Provides ciations but abstracts and full texts3. Key word is also helpful

iii. 2 major indexes availablea. Index to Legal Peridocals and Books

i. Westlawii. 900 law reviews, journals, yearbooks, instutites, etc.

1400 monographsb. Legal Trac

i. InfoTrac division – 875 law reviews, etc. 1000 aditional business and general interest sources

2. Main advantage to indexesa. Framework of subject headings and subjeadings into which

articles are categorizedi. Use subject search, keyword search, abstract

b. Keep in mind…i. Coverage: Does the article focus on your topic and

cover it well?ii. Currency?

iii. Credibility?iv. Quality of research – do the footnotes cite sufficient

authorityv. Persuasiveness

1. If it argues something, is it logical and convincing?

c. How to approach?i. Orient yourself

1. Read the synopsis on the first page if there is one

2. Look at TOC or headings/subheadings3. Read intro and conclusion4. Read what is pertinent and skim the rest5. Read footnotes6. Find ref’s of the law from your jx7. Read what the article cited

III. Two Approaches: Key Word Searchingi. When to use

1. When the periodical uses a periodic publication pattern instead of a highly organized one

2. WL/LN have good databasesa. West: Journals and Law Reviews Database - 850b. Lex: US and Canadian Law Reviews, Combined – 700c. Hein Online: 1000 legal and law related peridoicals, all with

coverage from the first issuei. Good for researching in and finding older issues

1. Only current to volume preceeding the current volume; sometimes, current issues are available

ii. How to use key word1. Select a service and run database2. Run a key word search3. Assess articles found4. Scan and read articles you chose

iii. How to narrow the search:1. Confining search to a subject2. Searching titles only3. Date restriction4. Adding terms to narrow

IV. Is it a good article?i. Citing authorities

1. Say you want to see if your article has been received well by the legal community

a. The article you read is the cited articleb. The most recent authorities, such as other artuckes ir cases, are

the citing authorities2. This used to be done via paper – Shephard’s law review citations

a. Now in electronic form – Lexisb. Westlaw - KeyCite

V. Citingi. Bluebook: Name (First – last), The title?, 70 Alb. L. Rev. 117 (2006).

ii. ALWD: Name (first – last), The title?, 70 Alb. L. Rev 117 (2006).VI. What else?

i. CILP – Current Index to Legal Periodicals1. Weekly current awareness pub that gives researchers cites to new

articles four to six weeks before articles indexed in major legal periodicals

a. 570 pubs organized in 100 subject headingsii. Legal Scholarship network

1. LSN – leading example of internet periodicals publication – division of SSRN

2. Search abstracts y author, title, key words and download articles from ssrn.

3. Means of locating works in progress and social science scholarship4. Received by email abstracts on new new articles as well as papers,

which will appear in law reviews or academic journals.iii. Specialized indexes:

1. Detailed indexes – fed tax articles, articles related to law, index to foreign legal periodicals

iv. Older articles

1. Pre-1981 – paper index to legal periodicals, or Legal Periodicals Retro on Wilson Web.

ALR Annotations

What are ALR Annotations, and why are they useful?I. ALR: West

a. Synopsizies various cases on a fairly narrow legal topic. Most focus on issues of controversy, in which courts in diferent jx follow diff rules or issues that are factually sensitive so that diff facts result in diff holdings

i. Staff attornies or attornies hired to write particular noteb. Typically

i. Accompanying the ALR is the leading case 1. Beginning of note or back of volume

c. Factsi. Multivol set

ii. 27,000 legal issues in 2007iii. 8 series

1. ALR 6 = Current2. ALR Fed.2 = Current

iv. 6-10 volumes issued / year for current volume1. Rarely supersede older series

v. Wide range of topicII. Why useful?

a. General overview and synopses of casesi. Organized by rule or key facts or outcomes, easily see diff approaches to the

issueii. Cited to document the pattern of cases across the country on an issue

iii. Provides ref to other commentaryiv. Timely – usually first commentary published on a new topicv. Up to date

b. Drawbacksi. Potential for no annotation on your topic

ii. Really narrow – turn to only after you have a good sense of the subjectiii. More descriptive than analytical or critical

III. Researching in ALRa. How to

i. Formulate specific research issueii. Use paper index or online search tools to locate pertinent annotation

iii. Using the finding tools to ID pertinent materialiv. Read to get a grasp of your topicv. Plan next step

b. Paper or online?i. Both equally good

c. In paperi. Consult ALR index or TOC or Laws to ID pertinent annotations

1. ALR Index = multivol set w 2nd-6th and both fed series2. It is updated, so check pocket parts and main volume3. If you already know the case – statute rule etc, locate an annotation

discussing that authority by sonsulting the appropriate TOAii. Read opening material

1. Consult outline of annotation, its index, and the list of jx representediii. Use the various finding tools to id pertinent passagesiv. Read the text of annotation

1. If in your jx, read fully, if in diff - scanv. Consult the ref section

vi. Update research1. Updated by

a. Pocket parts for additional case synopsesb. Check for more recent annotation

i. PP or annotation may be supersededc. Latest Case Service hotline – email up to the minute

d. ALR in Westlaw (Online)i. Select the ALR database

1. Ci(index) = search the index to locate a pertinent annotationii. Run a keyword search with seg restriction

1. Good way to search because its published periodically2. Natural language and Boolean is good too3. Seg restrictions b/c large database

iii. Read the annotation (updated automatically)iv. Pull in cases via links

IV. Citing ALRa. Blue: First/Last, Annotation, Right to Discharge, 33 A.L.R. 4th 120 (1984 & Supp. 2007).b. ALWD: First/last, Title, 33 A.L.R. 4th 120 (1984 & Supp. 2007).

V. What else?a. Lawyers edition

i. SCOTUS cases on major topicsb. Quick Indexes

i. 2 single vol indexes for 3rd-6th and fed

Restatements

What is a restatement, and why is it useful?I. What is it?

a. Distinctly legal form of commentaryi. Reaist/Rationalist lawyers in 20th century

1. Realists = ALI2. ALI’s goal to promulgate on authoritative rule like source stating the CL

b. When to use?i. Already know something about your topic

a. Obtain a succinct and credible statement of the law on a settled topic

b. Discern some of the nuances in and policies underlying a rule through comments and illustrations

c. Obtain a highly credible statement of a rule, when the case law in jx has no rule on your topic or an outmoded rule that differs from Restatement rule

c. Limitsi. Not revised regularly

ii. No explanation of court variationsd. What you should do in light of limits

i. Research how courts received your Restatement ruleii. Has it been adopted, noted, rejected, or not discussed?

iii. If nothing in your jx – look to other courtsII. How to research in Restatements

a. Stepsi. Form legal issue

ii. Select pertinent Restatementiii. Id pertinent sectioniv. Read the rule and supporting materialv. Consider client

vi. Look for key cases citing Restatementb. Paper and online

i. Like treatise - Strong internal organization; suggests paperii. Like ALR because have to search for key cases; suggests online

iii. SO – hybrid approachc. Hybrid:

Paper Lexis WestRule VolumesBrowse TOCLook up terms in index

Restatement Database w/o Case SummariesBrowse or search table of ContentsFull text key word search

Restatement Database With Case SummariesBrowse or search TOCFull text keyword searching – including case summaries

Case summariesMain volumePP

Database of Case SummariesFull text key word search

Restatement database w case summariesFull text keyword searching

AppendixAppendix PPPamplhetInterim Case citations

d. RE in paper and onlinei. Select the app Restatement and Series

1. IE – what is your issueii. Use TOC or index to ID one or more pert sections

1. Look at language of rule2. Comments3. Parallel illustrations4. Refs to anything else

iii. Read rules, comments, illustrations, and reporters noteiv. Locate and review important cases citing rule and pertinent explanatory info

III. Citinga. Blue: Restatement (Second) of Contracts S 2 (1981).b. ALWD: Restatement (Second) of Contracts S 2 (1981).

IV. What else?a. Follow dev. Of pending Re through ALI pubs

i. Annual Reportsii. Proceedings,

iii. ALI reporterb. Historical materials

i. UPenn Biddle Law Library under HeinOnline or West’s RE archives to see history

Additional Types of Commentary and Strategy

Additional TypesI. Jury Instructions

a. What are they?i. Given at the end of a traila, the jury is instructed on the law applicable to the

caseii. Drawn from a set of JIGs – jury instruct guides

iii. Written by lawyers, judges, profsiv. State law of specific jx

b. Useful when?i. Looking for litigation stuff for sample instructions

ii. JIGS most citable from this chapterII. Practice Material

a. What are they?i. Models of what to use in the practice

ii. Forms

1. American Jurisprudence Trials2. Proof of facts3. Causes of Action4. American Jurisprudence bal bla – lots of types

b. Good bridge between legal analysis and what to do next in a law suitIII. CLE Materials

a. Written materials and outlines and checklists as well as important cases and statutesi. Useful b/c address practical aspects of a topic

ii. Rarely cited

Strategies for commentary research

Case Law

Case Reporters, digests, and their alternatives

What is a case?

Why would you research which cases?

How do you research cases?

How do you cite cases?

What else?

Case Citators

What are they/why use?

How do you use them

How and Why should you bolster your research with them?

Enacted Law

Constitutions and Statutes

What are they/why use?

How do you research in them?

How do you cite them?

What else?

Legislative Process Materials

Intro: Legislative Process

Legislative History

Pending litigation

Concluding Points

Administrative Materials

Regulations

What are they/Why use them?

How to research in them ?

What else?

Agency Decisions

What are they/Why use?

How to research and cite?

What else?

Looseleaf Services

What are they?

How do you research in them and cite?

What else?

Rules of Procedure and Legal Ethics

Rules of Procedure

What are they, and do we research them?

How do you research them?

What else?

Rules of Professional Responsibility

What are they, and do we research them?

How do you research them?

What else?

Conclusion

Developing an integrated research strategy

Older Person’s housing dilemma