Many of the temp attorneys on the Citigroup case graduated from law school in the past five years, some of them from prestigious schools like NYU and Georgetown.

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The sharp reversal to a decline of 5, 600 temp jobs in July is another warning shot for the recovery.

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Manpower, America's largest temp agency, experienced flat sales in the fourth quarter of last year, down from 7% growth year-on-year in the third quarter, as demand from manufacturers plummeted.

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The case illustrates how plaintiff attorneys in securities class actions have an incentive to hire small armies of temp attorneys to justify their fees to judges.

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While 39% plan to hire full time workers in the next year, 21% expect to increase the percentage of contract or temp workers that they employ.

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The going rate for temp attorneys in Manhattan has fallen amid the legal recession, which has left thousands of experienced lawyers and recent grads scrambling for work.

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The Bank of Scotland Report on Jobs said one in three agencies reported an increase in temp staff billings.

BBC: 'Sharp rise' in temporary jobs in Scotland

Many businesses in Senegal get around the absurd labor laws by means of contracting through companies that act something like temp agencies.

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The Bank of Scotland's report on jobs suggested more people were placed into permanent and temp work in October.

BBC: Scottish jobs market 'steadily improving'