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On the issue of what is a bill the judgment is spot on.
I might sit inmy office and start drafting one. I might type something on the draft, correct it, check the file and see what we had agreed about fees,correct it again (and if I had a colleague send the draft to them). None of that is a bill at all. Even if I proceeded to give it its unique bill number in my systems it is still a draft bill until I have sent it to the client and said here is your bill (I never in my own practice send clients draft bills but even in some cases people do that as a draft and that is still not a bill).

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