Epstein Secrets

roject of expressive-overdetermination in board governance. Lyman Johnson, Faith and Faithfulness in Corporate Theory. 56 CATH. U. L. REV. 1 (2007). Johnson laments what he sees as the impoverished quality of discourse in the corporate boardroom. Pursuing a richer conception of what constitutes "good fai

cy has not yet been on the menu. See generally Stephen Bainbridge, The Creeping Federalization of Corporate Law, 26 REG. 26 (2003) (arguing that the Sarbanes-Oxley legislation was the most dramatic expansion of federal regulatory power). For internal use only CONFIDENTIAL - PURSUANT TO FED. R. CRIM. P. 6(e)

roject of expressive-overdetermination in board governance. Lyman Johnson, Faith and Faithfulness in Corporate Theory. 56 CATH. U. L. REV. 1 (2007). Johnson laments what he sees as the impoverished quality of discourse in the corporate boardroom. Pursuing a richer conception of what constitutes "good fai

cy has not yet been on the menu. See generally Stephen Bainbridge, The Creeping Federalization of Corporate Law, 26 REG. 26 (2003) (arguing that the Sarbanes-Oxley legislation was the most dramatic expansion of federal regulatory power). For internal use only CONFIDENTIAL - PURSUANT TO FED. R. CRIM. P. 6(e)

3); 15 US.C. §§ 78dd-2(a) (3), 78dd-3(a)(3). BI See, CL5 Complaint, SEC v. Johnson & Johnson, No. 11-cv-686 (D.D.C. Apr. 8, 2011) [hereinafter SEC v. Johnson & Johnson| (bribes paid through Greek and Romanian agents)), available at http: //wwwssec. gov/ litigation/ complaints/ 2011/comp21922. pdf; ; Criminal

8B2.1 & app. note 2 (2011). 311 This was underscored by then-SEC Commissioner Cynthia Glassman in 2003 ina speech on the SEC’s implementation of the Sarbanes-Oxley Act: “[T Jhe ultimate effectiveness of the new corporate governance rules will be determined by the ‘tone at the top. Adopting a code of ethics means