In 1984, Cramer received a Juris Doctor degree from Harvard Law School. Cramer started investing in the stock market while he attended law school. He made enough from trading to cover tuition. Cramer began promoting his holdings by leaving stock picks on his answering machine. While at Harvard, alumnus Michael Kinsley introduced him to The New Republic owner Martin Peretz, who contacted Cramer to write a book review. After first profiting from the stock picks he heard on Cramer's answering machine, Peretz gave Cramer $500,000 to invest. In two years, Cramer made $150,000 for Peretz. During his years at Harvard Law School, Cramer worked as a minor research assistant for Alan Dershowitz. He assisted Dershowitz's campaign to acquit alleged murderer Claus von Bülow, even though Cramer believed von Bülow was "supremely guilty." Career Goldman Sachs In 1984, Cramer worked in sales and trading at New York investment bank Goldman Sachs. Cramer was admitted to the New York State Bar in 1985, but did not practice. His license to practice law was suspended on April 2, 2009, for failure to renew his registration. Hedge fund In 1987, Cramer left Goldman Sachs and started a hedge fund, Cramer & Co. (later Cramer, Berkowitz & Co.). The fund operated out of the offices of hedge fund manager Michael Steinhardt. Early investors included friend and Harvard classmate Eliot Spitzer, Steve Brill, and Martin Peretz. Cramer raised $450 million in $5 million increments and received a fee of 20% of the profits he generated. Cramer claims he sold all of his stocks on the Friday before Black Monday (1987). From 1988 to 2000, Cramer claims he had only one year of negative returns – 1998, a year when the S&P 500 Index rose 29%. The underperformance in 1998 led to significant investor withdrawals. In 1999 the fund returned 47%, and in 2000 it returned 28%, beating the S&P 500 by 38 percentage points. Cramer said he produced a 24% average annual return over 14 years and "routinely [took] home $10 million a year and more." However, his results have been disputed. In 2001, Cramer retired from managing the hedge fund. The fund was then taken over by his former partner, Jeff Berkowitz. SmartMoney Cramer was also an "editor at large" for SmartMoney magazine and was accused of unethical practices when he made a $2 million personal gain after buying stocks just before his recommendation article