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To review another party's form commercial retail lease adequately and completely, one must analyze all the attached exhibits. You cannot stop your review at the signature block.
The question one needs to consider is whether the exhibits to the lease either supplement the lease or potentially modify its terms and conditions. The answer to this question will ultimately be of value during the term of the lease, when the lease terms and conditions are being administered.
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The DOJ's Criminal Division issued three declinations since the issuance of the revised CEP a year ago. Review of these cases gives insight into DOJ's implementation of the new policy in practice.
The parameters set forth in the DOJ's memorandum have implications not only for the government's evaluation of compliance programs in the context of criminal charging decisions, but also for how defense counsel structure their conference-room advocacy seeking declinations or lesser sanctions in both criminal and civil investigations.
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