Jeffrey A.Berman
Senior Counsel
Labor & Employment
jberman@seyfarth.com
Jeffrey offers wise counsel and ardent defense of his clients in almost every aspect of labor and employment law.
More About Jeffrey
Jeffrey represents management in a variety of industries, including major medical centers, universities, religious organizations, manufacturers, and restaurants. Jeffrey has represented employers in nearly all of the National Labor Relations Board’s (NLRB) regional offices in the Western United States. His successful representation of employers before the NLRB and the Ninth and DC Circuit Courts of Appeals changed bargaining unit determinations involving hospitals and religious schools. In 2006, Jeffrey was involved in an NLRB trial that caused the federal agency to change its security procedures when a gunman, having nothing to do with the trial, entered the hearing room and held Jeffrey and the other trial participants at gunpoint for more than six hours.
Over his career, Jeffrey has frequently been involved in advising and defending employers with respect to wage and hour issues. He also spends a significant portion of his time defending employer-clients in wrongful termination, employment discrimination, and sexual harassment cases.
Jeffrey has represented clients before state and federal trial and appellate courts in a number of cases involving the constitutional and statutory rights of autonomy guaranteed to religious institutions.
For more than two decades, Jeffrey served as the Amicus Chair of the Employers Group Legal Committee. In this capacity, Jeffrey played a significant role in the shaping of California employment law.
Jeffrey was recognized by Chambers USA: America’s Leading Lawyers for Business as a leading Labor and Employment lawyer (2007-2021) and a "Senior Statesperson (2022). He has consistently been listed in The Best Lawyers in America since 1995, most recently for Employment Law - Management, Health Care Law, Labor Law - Management, and Litigation - Labor and Employment (2017-2024) (Woodward/White Inc.), and has been mentioned in Who’s Who Legal: The International Who’s Who of Business Lawyers (Law Business Research Ltd.) (2007, 2009, 2011-2012, 2014-2015). Jeffrey is a Fellow of The College of Labor & Employment Lawyers.
Over his career, Jeffrey has frequently been involved in advising and defending employers with respect to wage and hour issues. He also spends a significant portion of his time defending employer-clients in wrongful termination, employment discrimination, and sexual harassment cases.
Jeffrey has represented clients before state and federal trial and appellate courts in a number of cases involving the constitutional and statutory rights of autonomy guaranteed to religious institutions.
For more than two decades, Jeffrey served as the Amicus Chair of the Employers Group Legal Committee. In this capacity, Jeffrey played a significant role in the shaping of California employment law.
Jeffrey was recognized by Chambers USA: America’s Leading Lawyers for Business as a leading Labor and Employment lawyer (2007-2021) and a "Senior Statesperson (2022). He has consistently been listed in The Best Lawyers in America since 1995, most recently for Employment Law - Management, Health Care Law, Labor Law - Management, and Litigation - Labor and Employment (2017-2024) (Woodward/White Inc.), and has been mentioned in Who’s Who Legal: The International Who’s Who of Business Lawyers (Law Business Research Ltd.) (2007, 2009, 2011-2012, 2014-2015). Jeffrey is a Fellow of The College of Labor & Employment Lawyers.
- JD, University of California, Los Angeles School of Law
UCLA Law Review, associate editor
- BA, University of California, Santa Barbara
With honors
- California
- US Court of Appeals, Ninth Circuit
- US District Court, Central District of California
- US District Court, Eastern District of California
- US District Court, Northern District of California
- US District Court, Southern District of California
Related Services
Related Key Industries
Related News & Insights
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Firm News
08/15/2024
220 Seyfarth Attorneys Chosen as Leaders in Their Fields by Best Lawyers in America 2025
-
Recognition
06/06/2024
Seyfarth Again Earns Top Rankings in Chambers USA 2024
-
Legal Update
Jan 18, 2024
The California Supreme Court Pulls The Carpet Out From Underneath Employers
-
Webinar
Oct 19, 2023
Webinar Recording: A New Standard: The NLRB Resets the Table for Handbooks and Policies with Cemex and Stericycle
- Listed in Best Lawyers in America (Woodward/White Inc.) for Employment Law - Management (2011-2025); Health Care Law (2013-2025); Labor Law - Management (2011-2025); Litigation - Labor and Employment (2011-2025)
- Recognized as a "Lawyer of the Year" lawyer by Best Lawyers in America (Woodward/White Inc.) for Labor Law - Management (2024)
- Recognized as a Recommended Attorney for Labor and employment - Labor-management relations, The Legal 500 (Legalese Ltd.) (2023)
- Recognized as a "Senior Statesperson" for Labor & Employment (California) by Chambers USA (2022-2024)
- Recognized as a Leading Lawyer in Labor & Employment (California) by Chambers USA (2007-2021)
-
Recognized as a "Labor & Employment Star" by Benchmark Litigation (Euromoney Institutional Investor) (2020)
- American Health Lawyers Association
- Legal Committee of the Employers Group
- The College of Labor & Employment Lawyers (Fellow)
- Co-Author, "The California Supreme Court Pulls The Carpet Out From Underneath Employers," Legal Update, Seyfarth Shaw LLP (January 18, 2024)
- Co-Author, "Employers May Be Liable For Work-From-Home Expenses," Legal Update, Seyfarth Shaw LLP (July 19, 2023)
- Co-Author, "California Supreme Court Asked To Weigh In On 'Hours Worked' Questions," Legal Update, Seyfarth Shaw LLP (July 14, 2022)
- Co-Author, "How Much Time To Budget For Getting Through Security?," Legal Update, Seyfarth Shaw LLP (August 23, 2021)
- Co-Author, "Don’t Let the Pendulum Hit You as it Swings: NLRB General Counsel Previews a Pro-Labor Agenda," Legal Update, Seyfarth Shaw LLP (August 18, 2021)
- Co-Author, "SCOTUS Strikes Down Restriction on Excluding Organizers from Private Property," Legal Update, Seyfarth Shaw LLP (June 30, 2021)
- Co-Author, "McFerran Dissent Portends a Change in NLRB’s View of Confidentiality Provisions in Arbitration Agreements," Legal Update, Seyfarth Shaw LLP (March 26, 2021)
- Co-Author, "Working Remotely, NLRB Continues Delivering On Certain Appointed Rounds," Legal Update, Seyfarth Shaw LLP (April 6, 2020)
- Co-Author, "California State Court Agrees With Motor Carriers’ Preemption Challenge To AB 5," Legal Update, Seyfarth Shaw LLP (January 10, 2020)
- Co-Author, "AB 51 Challenge: TRO Granted," Legal Update, Seyfarth Shaw LLP (December 31, 2019)
- Co-Author, "NLRB Issues Final Rule Eliminating The Worst Of The Old Quickie Election Rules," Legal Update, Seyfarth Shaw LLP (December 16, 2019)
- Co-Author, "Student-Athletes Are Students—And Athletes—But Not Employees," Legal Update, Seyfarth Shaw LLP (August 19, 2019)
- Co-Author, "Waiting For Godot, Or, In This Case, The NLRB," Employer Labor Relations Blog, Seyfarth Shaw LLP (September 14, 2018)
- Co-Author, "NLRB General Counsel Rescinds Controversial Memo Regarding Section 7 Rights of University Faculty, Student Assistants, and Student-Athletes," Employer Labor Relations Blog, Seyfarth Shaw LLP (December 13, 2017)
- Co-Author, "Ninth Circuit Holds that Prior Salary Alone May Justify Pay Differential in Equal Pay Act Cases," Legal Update, Seyfarth Shaw LLP (May 4, 2017)
- Co-Author, "Different Approaches to Salary History and Fair Pay Claims," One Minute Memo, Seyfarth Shaw LLP (May 1, 2017)
- Co-Author, "Federal Legislators Tell NLRB GC Griffin to Rescind His Education Report or Step Aside," Legal Update, Seyfarth Shaw LLP (February 3, 2017)
- Co-Author, "NLRB General Counsel Issues Report on NLRA Protections For Faculty and Students," Legal Update, Seyfarth Shaw LLP (February 2, 2017)
- Co-Author, "Better Sit Down for This… or Stand and Rejoice? California Supreme Court Clarifies 'Suitable Seating' Rules," Wage & Hour Litigation Blog, Seyfarth Shaw LLP (April 12, 2016)
- Co-Author, "Better Sit Down For This: Court Clarifies 'Suitable Seating' Rules," Legal Update, Seyfarth Shaw LLP (April 6, 2016)
- Co-Author, "Graduate Students or Employees? NLRB to Weigh In (Again)," Employer Labor Relations Blog, Seyfarth Shaw LLP (October 29, 2015)
- "NLRB Receives An 'Incomplete' In School Case," Employer Labor Relations Blog, Seyfarth Shaw LLP (December 22, 2014)
- Co-Author, "NLRB 'Deletes' Employer Email Rule," Trading Secrets Blog, Seyfarth Shaw LLP (December 15, 2014)
- Co-Author, "Court Extends Protections To 'Silent Whistleblowers'," Legal Update, Seyfarth Shaw LLP (December 4, 2014)
- Co-Author, "New Decisions Support Waiver Of Class and Representative Arbitration Claims," Legal Update, Seyfarth Shaw LLP (October 22, 2014)
- Co-Author, "NLRB Rules That 'Liking' A Facebook Comment Is Protected Activity," Legal Update, Seyfarth Shaw LLP (August 27, 2014)
- Co-Author, "Education Unions Ignore NLRB’s Call For 'Timeout'," Legal Update, Seyfarth Shaw LLP (June 3, 2014)
- Co-Author, "California Supreme Court Limits Use Of Statistical Sampling In Class Actions," Consumer Class Defense Blog, Seyfarth Shaw LLP (June 3, 2014)
- Co-Author, "Cal. Supreme Court Holds That Statistical Sampling In Class Actions May Deprive Defendants Of Due Process," Legal Update, Seyfarth Shaw LLP (June 2, 2014)
- Co-Author, "NLRB Goes Long: Regional Director Finds NU Football Scholarship Athletes Employees," Legal Update, Seyfarth Shaw LLP (March 27, 2014)
- Co-Author, "California Supreme Court Will Hear Three Employment Cases Next Month," Legal Update, Seyfarth Shaw LLP (March 11, 2014)
- Co-Author, "Schools Move into Union and NLRB Spotlight," Legal Update, Seyfarth Shaw LLP (February 13, 2014)
- Co-Author, "NLRB Continues its Involvement in Cases Affecting the Academic Employer," Legal Update, Seyfarth Shaw LLP (January 14, 2014)
- Co-Author, "Micro Collective Bargaining Units In Educational Institutions," Legal Update, Seyfarth Shaw LLP (October 23, 2013)
- "Off-Duty Trip for Yoga and Yogurt Creates Tort Liability for Employer," Management Alert, Seyfarth Shaw LLP (October 2, 2013)
- Co-Author, "Court Of Appeal Holds Employer Does Not Have To Pay Employee’s Legal Fees," Legal Update, Seyfarth Shaw LLP (September 25, 2013)
- Co-Author, "Statute Of Limitations On Wage Claims Tolled While Plaintiff Pursues Labor Commissioner Remedies," Legal Update, Seyfarth Shaw LLP (September 13, 2013)
- Co-Author, "NLRB Poised To Issue Decisions That Will Impact Many Private Schools," Legal Update, Seyfarth Shaw LLP (July 9, 2013)
- Co-Author, "OFCCP Wins Major Battle Over Coverage Of Some Health Care Providers," Legal Update, Seyfarth Shaw LLP (April 5, 2013)
- "California Supreme Court Endorses Favoritism For Union Trespassers," Legal Update, Seyfarth Shaw LLP (January 4, 2013)
- Co-Author, "California Court Approves Federal Time-Rounding Practices," Legal Update, Seyfarth Shaw LLP (October 30, 2012)
- Co-Author, "California Court of Appeal Twice Confirms Difficulty In Certifying Meal And Rest Break Claims Post-Brinker," Legal Update, Seyfarth Shaw LLP (September 17, 2012)
- Co-Author, "Court of Appeal Delivers On Newspaper Carrier Misclassification Case," Management Alert, Seyfarth Shaw LLP (2012)
- Co-Author, "California Franchisor May Be Vicariously Liable For Harassment Of A Franchisee’s Employee," Legal Update, Seyfarth Shaw LLP (July 5, 2012)
- Member, Board of Editors, Wage & Hour Collective and Class Litigation, ALM Law Journal Press (2012). Definitive treatise on wage and hour litigation.
- Co-Presenter, "A New Standard: The NLRB Resets the Table for Handbooks and Policies with Cemex and Stericycle," Webinar, Seyfarth Shaw LLP (October 19, 2023)
Jeffrey offers wise counsel and ardent defense of his clients in almost every aspect of labor and employment law.
More About Jeffrey
Jeffrey represents management in a variety of industries, including major medical centers, universities, religious organizations, manufacturers, and restaurants. Jeffrey has represented employers in nearly all of the National Labor Relations Board’s (NLRB) regional offices in the Western United States. His successful representation of employers before the NLRB and the Ninth and DC Circuit Courts of Appeals changed bargaining unit determinations involving hospitals and religious schools. In 2006, Jeffrey was involved in an NLRB trial that caused the federal agency to change its security procedures when a gunman, having nothing to do with the trial, entered the hearing room and held Jeffrey and the other trial participants at gunpoint for more than six hours.
Over his career, Jeffrey has frequently been involved in advising and defending employers with respect to wage and hour issues. He also spends a significant portion of his time defending employer-clients in wrongful termination, employment discrimination, and sexual harassment cases.
Jeffrey has represented clients before state and federal trial and appellate courts in a number of cases involving the constitutional and statutory rights of autonomy guaranteed to religious institutions.
For more than two decades, Jeffrey served as the Amicus Chair of the Employers Group Legal Committee. In this capacity, Jeffrey played a significant role in the shaping of California employment law.
Jeffrey was recognized by Chambers USA: America’s Leading Lawyers for Business as a leading Labor and Employment lawyer (2007-2021) and a "Senior Statesperson (2022). He has consistently been listed in The Best Lawyers in America since 1995, most recently for Employment Law - Management, Health Care Law, Labor Law - Management, and Litigation - Labor and Employment (2017-2024) (Woodward/White Inc.), and has been mentioned in Who’s Who Legal: The International Who’s Who of Business Lawyers (Law Business Research Ltd.) (2007, 2009, 2011-2012, 2014-2015). Jeffrey is a Fellow of The College of Labor & Employment Lawyers.
Over his career, Jeffrey has frequently been involved in advising and defending employers with respect to wage and hour issues. He also spends a significant portion of his time defending employer-clients in wrongful termination, employment discrimination, and sexual harassment cases.
Jeffrey has represented clients before state and federal trial and appellate courts in a number of cases involving the constitutional and statutory rights of autonomy guaranteed to religious institutions.
For more than two decades, Jeffrey served as the Amicus Chair of the Employers Group Legal Committee. In this capacity, Jeffrey played a significant role in the shaping of California employment law.
Jeffrey was recognized by Chambers USA: America’s Leading Lawyers for Business as a leading Labor and Employment lawyer (2007-2021) and a "Senior Statesperson (2022). He has consistently been listed in The Best Lawyers in America since 1995, most recently for Employment Law - Management, Health Care Law, Labor Law - Management, and Litigation - Labor and Employment (2017-2024) (Woodward/White Inc.), and has been mentioned in Who’s Who Legal: The International Who’s Who of Business Lawyers (Law Business Research Ltd.) (2007, 2009, 2011-2012, 2014-2015). Jeffrey is a Fellow of The College of Labor & Employment Lawyers.
- JD, University of California, Los Angeles School of Law
UCLA Law Review, associate editor
- BA, University of California, Santa Barbara
With honors
- California
- US Court of Appeals, Ninth Circuit
- US District Court, Central District of California
- US District Court, Eastern District of California
- US District Court, Northern District of California
- US District Court, Southern District of California
Related Services
Related Key Industries
Related News & Insights
-
Firm News
08/15/2024
220 Seyfarth Attorneys Chosen as Leaders in Their Fields by Best Lawyers in America 2025
-
Recognition
06/06/2024
Seyfarth Again Earns Top Rankings in Chambers USA 2024
-
Legal Update
Jan 18, 2024
The California Supreme Court Pulls The Carpet Out From Underneath Employers
-
Webinar
Oct 19, 2023
Webinar Recording: A New Standard: The NLRB Resets the Table for Handbooks and Policies with Cemex and Stericycle
- Listed in Best Lawyers in America (Woodward/White Inc.) for Employment Law - Management (2011-2025); Health Care Law (2013-2025); Labor Law - Management (2011-2025); Litigation - Labor and Employment (2011-2025)
- Recognized as a "Lawyer of the Year" lawyer by Best Lawyers in America (Woodward/White Inc.) for Labor Law - Management (2024)
- Recognized as a Recommended Attorney for Labor and employment - Labor-management relations, The Legal 500 (Legalese Ltd.) (2023)
- Recognized as a "Senior Statesperson" for Labor & Employment (California) by Chambers USA (2022-2024)
- Recognized as a Leading Lawyer in Labor & Employment (California) by Chambers USA (2007-2021)
-
Recognized as a "Labor & Employment Star" by Benchmark Litigation (Euromoney Institutional Investor) (2020)
- American Health Lawyers Association
- Legal Committee of the Employers Group
- The College of Labor & Employment Lawyers (Fellow)
- Co-Author, "The California Supreme Court Pulls The Carpet Out From Underneath Employers," Legal Update, Seyfarth Shaw LLP (January 18, 2024)
- Co-Author, "Employers May Be Liable For Work-From-Home Expenses," Legal Update, Seyfarth Shaw LLP (July 19, 2023)
- Co-Author, "California Supreme Court Asked To Weigh In On 'Hours Worked' Questions," Legal Update, Seyfarth Shaw LLP (July 14, 2022)
- Co-Author, "How Much Time To Budget For Getting Through Security?," Legal Update, Seyfarth Shaw LLP (August 23, 2021)
- Co-Author, "Don’t Let the Pendulum Hit You as it Swings: NLRB General Counsel Previews a Pro-Labor Agenda," Legal Update, Seyfarth Shaw LLP (August 18, 2021)
- Co-Author, "SCOTUS Strikes Down Restriction on Excluding Organizers from Private Property," Legal Update, Seyfarth Shaw LLP (June 30, 2021)
- Co-Author, "McFerran Dissent Portends a Change in NLRB’s View of Confidentiality Provisions in Arbitration Agreements," Legal Update, Seyfarth Shaw LLP (March 26, 2021)
- Co-Author, "Working Remotely, NLRB Continues Delivering On Certain Appointed Rounds," Legal Update, Seyfarth Shaw LLP (April 6, 2020)
- Co-Author, "California State Court Agrees With Motor Carriers’ Preemption Challenge To AB 5," Legal Update, Seyfarth Shaw LLP (January 10, 2020)
- Co-Author, "AB 51 Challenge: TRO Granted," Legal Update, Seyfarth Shaw LLP (December 31, 2019)
- Co-Author, "NLRB Issues Final Rule Eliminating The Worst Of The Old Quickie Election Rules," Legal Update, Seyfarth Shaw LLP (December 16, 2019)
- Co-Author, "Student-Athletes Are Students—And Athletes—But Not Employees," Legal Update, Seyfarth Shaw LLP (August 19, 2019)
- Co-Author, "Waiting For Godot, Or, In This Case, The NLRB," Employer Labor Relations Blog, Seyfarth Shaw LLP (September 14, 2018)
- Co-Author, "NLRB General Counsel Rescinds Controversial Memo Regarding Section 7 Rights of University Faculty, Student Assistants, and Student-Athletes," Employer Labor Relations Blog, Seyfarth Shaw LLP (December 13, 2017)
- Co-Author, "Ninth Circuit Holds that Prior Salary Alone May Justify Pay Differential in Equal Pay Act Cases," Legal Update, Seyfarth Shaw LLP (May 4, 2017)
- Co-Author, "Different Approaches to Salary History and Fair Pay Claims," One Minute Memo, Seyfarth Shaw LLP (May 1, 2017)
- Co-Author, "Federal Legislators Tell NLRB GC Griffin to Rescind His Education Report or Step Aside," Legal Update, Seyfarth Shaw LLP (February 3, 2017)
- Co-Author, "NLRB General Counsel Issues Report on NLRA Protections For Faculty and Students," Legal Update, Seyfarth Shaw LLP (February 2, 2017)
- Co-Author, "Better Sit Down for This… or Stand and Rejoice? California Supreme Court Clarifies 'Suitable Seating' Rules," Wage & Hour Litigation Blog, Seyfarth Shaw LLP (April 12, 2016)
- Co-Author, "Better Sit Down For This: Court Clarifies 'Suitable Seating' Rules," Legal Update, Seyfarth Shaw LLP (April 6, 2016)
- Co-Author, "Graduate Students or Employees? NLRB to Weigh In (Again)," Employer Labor Relations Blog, Seyfarth Shaw LLP (October 29, 2015)
- "NLRB Receives An 'Incomplete' In School Case," Employer Labor Relations Blog, Seyfarth Shaw LLP (December 22, 2014)
- Co-Author, "NLRB 'Deletes' Employer Email Rule," Trading Secrets Blog, Seyfarth Shaw LLP (December 15, 2014)
- Co-Author, "Court Extends Protections To 'Silent Whistleblowers'," Legal Update, Seyfarth Shaw LLP (December 4, 2014)
- Co-Author, "New Decisions Support Waiver Of Class and Representative Arbitration Claims," Legal Update, Seyfarth Shaw LLP (October 22, 2014)
- Co-Author, "NLRB Rules That 'Liking' A Facebook Comment Is Protected Activity," Legal Update, Seyfarth Shaw LLP (August 27, 2014)
- Co-Author, "Education Unions Ignore NLRB’s Call For 'Timeout'," Legal Update, Seyfarth Shaw LLP (June 3, 2014)
- Co-Author, "California Supreme Court Limits Use Of Statistical Sampling In Class Actions," Consumer Class Defense Blog, Seyfarth Shaw LLP (June 3, 2014)
- Co-Author, "Cal. Supreme Court Holds That Statistical Sampling In Class Actions May Deprive Defendants Of Due Process," Legal Update, Seyfarth Shaw LLP (June 2, 2014)
- Co-Author, "NLRB Goes Long: Regional Director Finds NU Football Scholarship Athletes Employees," Legal Update, Seyfarth Shaw LLP (March 27, 2014)
- Co-Author, "California Supreme Court Will Hear Three Employment Cases Next Month," Legal Update, Seyfarth Shaw LLP (March 11, 2014)
- Co-Author, "Schools Move into Union and NLRB Spotlight," Legal Update, Seyfarth Shaw LLP (February 13, 2014)
- Co-Author, "NLRB Continues its Involvement in Cases Affecting the Academic Employer," Legal Update, Seyfarth Shaw LLP (January 14, 2014)
- Co-Author, "Micro Collective Bargaining Units In Educational Institutions," Legal Update, Seyfarth Shaw LLP (October 23, 2013)
- "Off-Duty Trip for Yoga and Yogurt Creates Tort Liability for Employer," Management Alert, Seyfarth Shaw LLP (October 2, 2013)
- Co-Author, "Court Of Appeal Holds Employer Does Not Have To Pay Employee’s Legal Fees," Legal Update, Seyfarth Shaw LLP (September 25, 2013)
- Co-Author, "Statute Of Limitations On Wage Claims Tolled While Plaintiff Pursues Labor Commissioner Remedies," Legal Update, Seyfarth Shaw LLP (September 13, 2013)
- Co-Author, "NLRB Poised To Issue Decisions That Will Impact Many Private Schools," Legal Update, Seyfarth Shaw LLP (July 9, 2013)
- Co-Author, "OFCCP Wins Major Battle Over Coverage Of Some Health Care Providers," Legal Update, Seyfarth Shaw LLP (April 5, 2013)
- "California Supreme Court Endorses Favoritism For Union Trespassers," Legal Update, Seyfarth Shaw LLP (January 4, 2013)
- Co-Author, "California Court Approves Federal Time-Rounding Practices," Legal Update, Seyfarth Shaw LLP (October 30, 2012)
- Co-Author, "California Court of Appeal Twice Confirms Difficulty In Certifying Meal And Rest Break Claims Post-Brinker," Legal Update, Seyfarth Shaw LLP (September 17, 2012)
- Co-Author, "Court of Appeal Delivers On Newspaper Carrier Misclassification Case," Management Alert, Seyfarth Shaw LLP (2012)
- Co-Author, "California Franchisor May Be Vicariously Liable For Harassment Of A Franchisee’s Employee," Legal Update, Seyfarth Shaw LLP (July 5, 2012)
- Member, Board of Editors, Wage & Hour Collective and Class Litigation, ALM Law Journal Press (2012). Definitive treatise on wage and hour litigation.
- Co-Presenter, "A New Standard: The NLRB Resets the Table for Handbooks and Policies with Cemex and Stericycle," Webinar, Seyfarth Shaw LLP (October 19, 2023)