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When the coronavirus pandemic first upended the American economy in March 2020, General Motors reached out to the 19 firms on its panel of "strategic legal partners." The second quarter presented an enormous, worrisome question mark, and the automaker — like so many businesses of all sizes — was looking to preserve cash.
GM general counsel Craig Glidden says the company didn't know what would happen in the auto markets, which meant asking firms for help. And those firms stepped up, agreeing to deferred billing and alternative fee arrangements to relieve some of the company's pressure.
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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.
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