Law conversion outside UK? Watch

*soph*
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I've been looking into the GDL/LPC route and am prepared to start applications for corporate and commercial City and regional firms in the next academic year, but a year abroad during my BA has made me start wondering about training options outside of the UK. So, two questions:

1. Could somebody please explain to me the way the American system works? As far as I understand it, you have to get an undergrad degree before taking law in America. What do you go on to study in the USA - a JD or LLM? Are these qualifying law degrees in the States (ie like a UK LLB + LPC) or do you have to do something else afterwards? Do any of the US firms offer scholarships for them in the same way as City firms pay for the GDL and LPC? I'd love to go to law school in the States but without a scholarship it'd be financially impossible, and I don't really know how long it'd take to qualify.

2. What would be the best route to take if I wanted to work outside the UK eventually? Is it better to get a UK training contract and then try to transfer offices within an international firm, or do any other European countries offer a GDL+LPC equivalent?

I'm seeing a lot of firms offering 6 month stints abroad, but essentially I'm wondering what direction to take if I want to relocate for longer than that. Thanks!
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ICQ
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1. jd is a qualifying law degree in the US. three years long, so like a combined gdl/lpc. no firms pay for sponsorship. most people finance the course through loans.
2. you could easily work outside the UK through a GDL/LPC. you can work abroad during your 2 year qualifying period, or transfer abroad at any point afterwards..
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Aerasay
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You mention a BA so I assume you haven't got an LLB? If you have an LLB you are eligible to sit the NY Bar. Best advice if doing that is to do an LLM in the states as well to be even remotely competitive at job interviews.
You can take the NY/California bar once qualified and move over, or do the QLTT equivalent in Oz - I think it only involves a couple of modules.
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*soph*
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I'm doing a non-law degree as my undergraduate... the original plan was to take the conversion course before the LPC and qualify in the UK that way. I'm just wondering what my options are if I wanted to qualify abroad. It looks like I'd have to take an LLB for graduates and then an LLM in the US. Or maybe stick with the GDL+LPC and then look at getting transferred somewhere.
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reshma
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Ok guys so I am in a dilemma, I am a Law graduate from the UK, getting married to an American citizen and moving to US next year. So I already got accepted to do LPC in UK. I was hoping to do an LLM from US and and then take the NY bar exam. I was wondering whether there is any use in me doing the LPC considering the cost and time involved. Am i better off with just taking the LLM in US + the bar exam. any advises would be much appreciated.
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nulli tertius
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(Original post by reshma)
Ok guys so I am in a dilemma, I am a Law graduate from the UK, getting married to an American citizen and moving to US next year. So I already got accepted to do LPC in UK. I was hoping to do an LLM from US and and then take the NY bar exam. I was wondering whether there is any use in me doing the LPC considering the cost and time involved. Am i better off with just taking the LLM in US + the bar exam. any advises would be much appreciated.
Why do you need to do the LLM?

You can do the New York bar exam on the back of a three year UK law degree.

There are plenty of US training courses for the New York bar exam.

Once you are a qualified US attorney i.e. have passed the NY bar exam you can do the QLTS in England and hey presto you are a solicitor. No LPC no TC.

However, if you are not living in New York look carefully at the fine print of qualifying where you are living. Not everywhere will passport a New York attorney to another state qualification where the NY qualification was obtained without a JD.
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eua6592
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So, I am a non-Law undergraduate student and I am thinking of taking the conversion course and the LPC. Are these qualifying degrees in order for me to practice law outside UK afterwards (specifically in the EU)? Any advice would be much appreciated.
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J-SP
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(Original post by eua6592)
So, I am a non-Law undergraduate student and I am thinking of taking the conversion course and the LPC. Are these qualifying degrees in order for me to practice law outside UK afterwards (specifically in the EU)? Any advice would be much appreciated.
The GDL and LPC (+ training contract) will only allow you to practice in England and Wales.

If you wanted to work as a solicitor in Europe, you could probably do so as an English qualified lawyer in most large European cities with commercial firms. This means that you technically can only work on/sign off English legal matters.

If you wanted to qualify in that local jurisdiction you would need to take the local bar exams. The eligibility to take these exams, plus the exams themselves will vary massively from country to country.


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eua6592
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thank you for responding to my question so quickly! you' ve been really helpful!
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nulli tertius
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(Original post by J-SP)
The GDL and LPC (+ training contract) will only allow you to practice in England and Wales.

If you wanted to work as a solicitor in Europe, you could probably do so as an English qualified lawyer in most large European cities with commercial firms. This means that you technically can only work on/sign off English legal matters.

If you wanted to qualify in that local jurisdiction you would need to take the local bar exams. The eligibility to take these exams, plus the exams themselves will vary massively from country to country.

(Original post by eua6592)
thank you for responding to my question so quickly! you' ve been really helpful!
I am afraid this is not right.

An English solicitor can practice under their English qualification in any European jurisdiction provided they register as a European lawyer in the state in which they practice (called the "host state"). They can advise on host state laws. There can be certain restrictions on conveyancing and probate work in countries where that is undertaken by notaries and countries may require a local lawyer to be associated with the registered European lawyer in conducting litigation. After three years transfer to the host country legal profession is automatic (subject to no professional conduct issues) without having to satisfy any transfer exams.

http://www.lawsoc-ni.org/fs/doc/EU%2...CTIVE%2098.pdf
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J-SP
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(Original post by nulli tertius)
I am afraid this is not right.

An English solicitor can practice under their English qualification in any European jurisdiction provided they register as a European lawyer in the state in which they practice (called the "host state"). They can advise on host state laws. There can be certain restrictions on conveyancing and probate work in countries where that is undertaken by notaries and countries may require a local lawyer to be associated with the registered European lawyer in conducting litigation. After three years transfer to the host country legal profession is automatic (subject to no professional conduct issues) without having to satisfy any transfer exams.

http://www.lawsoc-ni.org/fs/doc/EU%2...CTIVE%2098.pdf
Thanks for the correction. I'm surprised by this as it's not the advice that's been given to qualified lawyers on a more practical level if they want to permanently move to the likes of Brussels or Paris.


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nulli tertius
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(Original post by J-SP)
Thanks for the correction. I'm surprised by this as it's not the advice that's been given to qualified lawyers on a more practical level if they want to permanently move to the likes of Brussels or Paris.
Firstly, I think this has to do with English law firms remaining outside of the clutches of continental regulators rather than the position of individual lawyers. Article 6 (1) says you have to follow the host state's professional rules which will include, for example, all of the French restrictive practices. Law firms can operate abroad under the Services Directive, only advise on English law, and basically have no engagement with the host state's legal profession.

Secondly, there is no incentive for English law firms operating abroad to signpost to their English lawyers that they are marketable to law firms in or can set up independent practice in the host state. They want to encourage an "ex pat" mentality.
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J-SP
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(Original post by nulli tertius)
Firstly, I think this has to do with English law firms remaining outside of the clutches of continental regulators rather than the position of individual lawyers. Article 6 (1) says you have to follow the host state's professional rules which will include, for example, all of the French restrictive practices. Law firms can operate abroad under the Services Directive, only advise on English law, and basically have no engagement with the host state's legal profession.

Secondly, there is no incentive for English law firms operating abroad to signpost to their English lawyers that they are marketable to law firms in or can set up independent practice in the host state. They want to encourage an "ex pat" mentality.
That might be part of the reason. I assume it's also easier to charge out a dual qualified lawyer (with no restrictions on what they can/cannot work on) to a client more.

I have known firms to put clauses into employment/secondment contracts about taking the local bar exams (and providing the necessary support for them), so there must be reasons for it.

To be fair though, most I have known just work as English qualified lawyers on English legal matters in the major cities and leave the locally qualified colleagues to work on the legal matters written in their jurisdiction.


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nulli tertius
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(Original post by J-SP)
That might be part of the reason. I assume it's also easier to charge out a dual qualified lawyer (with no restrictions on what they can/cannot work on) to a client more.

I have known firms to put clauses into employment/secondment contracts about taking the local bar exams (and providing the necessary support for them), so there must be reasons for it.

To be fair though, most I have known just work as English qualified lawyers on English legal matters in the major cities and leave the locally qualified colleagues to work on the legal matters written in their jurisdiction.


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There is some comment from 2010 on the position in France here.

http://www.fbe.org/en/newsletter/arc...an-art822.html
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christianlaw
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(Original post by reshma)
Ok guys so I am in a dilemma, I am a Law graduate from the UK, getting married to an American citizen and moving to US next year. So I already got accepted to do LPC in UK. I was hoping to do an LLM from US and and then take the NY bar exam. I was wondering whether there is any use in me doing the LPC considering the cost and time involved. Am i better off with just taking the LLM in US + the bar exam. any advises would be much appreciated.
Hello Reshma,
If you hold a British LLB (3 years at least, no distance learning) you can qualify to sit the NYC bar without having to take a U.S. based LL.M.

This said I would strongly recommend to do an LL.M in U.S. law before attempting the New York Bar exam. Not only the LL.M in U.S. law would give you some preparation for the exam but it will also normalise your profile if you wish to pursue a career as a lawyer in the U.S.

If you are moving to the U.S. you can find several good programmes for foreign law graduates that will be well worth the effort.

If you are moving to the U.S. next year and plan to establish yourself there the LPC wouldn't be useful unless you find a way to complete your training contract too. The LPC will not be very useful if you plan to live and work in the U.S. but an LL.M will be a good preparation to sit the Bar exam and would make you much more marketable in the job market.
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nulli tertius
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(Original post by christianlaw)
Hello Reshma,
If you hold a British LLB (3 years at least, no distance learning) you can qualify to sit the NYC bar without having to take a U.S. based LL.M.

This said I would strongly recommend to do an LL.M in U.S. law before attempting the New York Bar exam. Not only the LL.M in U.S. law would give you some preparation for the exam but it will also normalise your profile if you wish to pursue a career as a lawyer in the U.S.

If you are moving to the U.S. you can find several good programmes for foreign law graduates that will be well worth the effort.

If you are moving to the U.S. next year and plan to establish yourself there the LPC wouldn't be useful unless you find a way to complete your training contract too. The LPC will not be very useful if you plan to live and work in the U.S. but an LL.M will be a good preparation to sit the Bar exam and would make you much more marketable in the job market.
The post to which you are replying was made in 2011.
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