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Chapter 9 Cases with Debtors Other Than Cities, Counties and Towns
Over the past several years, Chapter 9 of the United States Bankruptcy Code ' the chapter under which municipalities may seek to reorganize and adjust their debts ' has been the subject of unprecedented attention, both within the bankruptcy bar and among the public at large. This surge in interest is attributable to a number of high-profile Chapter 9 cases filed recently by cities, counties, and towns throughout the country, including the City of Detroit; Jefferson County, AL; the City of Central Falls, RI; the Cities of Vallejo, Stockton, and San Bernardino in California; and the Town of Mammoth Lakes, CA.
Chapter 9 Debtors
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The DOJ's Corporate Enforcement Policy: One Year Later
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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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.