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Early Public Disclosure of Suspected Drug Safety
Issues Begins
In September, the U.S. Food and Drug Administration (FDA) published the first of its planned quarterly reports listing the drugs that are under evaluation by the agency for potential safety problems. The new reporting system was imposed on the FDA by legislation signed into law a year ago as part of the Food and Drug Administration Amendments Act of 2007. Under the law, the FDA is required to inform the public each quarter of new safety information or potential signals of serious risk, based on the agency's review of adverse event reports contained in the FDA's Adverse Event Reporting System (AERS).
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.
This article discusses the practical and policy reasons for the use of DPAs and NPAs in white-collar criminal investigations, and considers the NDAA's new reporting provision and its relationship with other efforts to enhance transparency in DOJ decision-making.
There is no efficient market for the sale of bankruptcy assets. Inefficient markets yield a transactional drag, potentially dampening the ability of debtors and trustees to maximize value for creditors. This article identifies ways in which investors may more easily discover bankruptcy asset sales.
Active reading comprises many daily tasks lawyers engage in, including highlighting, annotating, note taking, comparing and searching texts. It demands more than flipping or turning pages.