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Here's an obvious problem with the proposed definition. By federal law, one can represent individuals without holding a license to practice law before certain administrative bodies. Social security and the Veteran's Administration come to mind. There is also a fairly good constitutional argument under the First Amendment when it comes to representing workers who are part of a union at an NLRB or similar administrative body, including the personnel department. My reading of the definition does not carve out exceptions for this situation.
Attorney & Counselor at Law