Unlike the process of denouncing executive agreements, which has not in the past met with full opposition from Congress, the constitutional requirements for the termination of treaties ratified by the Senate have been the subject of occasional debate between the legislature and the executive. For example, in a 2004 case, Universal Acupuncture Pain Services commissioned the law firm Quadrino & Schwartz to represent them in litigation on the basis of a retainer agreement success fee.  In a potential fee agreement, lawyers receive a percentage of the amount earned in the lawsuit or paid for by a settlement agreement. . . .