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An attorney and member of the New York Bar Association became actively involved with international environmental issues. She proposed and developed a program and then presented it under the auspices of the association. She engaged in other efforts, including creating a new bar asso- ciation committee on international environmen- tal law, making presentations, and participating at the first United Nations Conference on Envi- ronment and Development. In return, the asso- ciation provided her with work space, clerical support, publicity, and reimbursement for out- of-pocket expenses. The attorney experienced harassment by a bar association official and sued. Was she a volunteer or an employee? (York v. Association of the Bar of the City of New York, 286 F.3d 122 (2d Cir. 2002))

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