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deed, such a swing of the pendulum can be seen in thehistory of Arthur Andersen. At the start of the twentieth century, like other accounting firms, Andersen carried out non-audit services. By the 1960s, it was possible to become an Andersen consultant without having worked as an auditor for the two prio
crime. See United States'. Root, 296 F.3d 1222, 1227-32 (j1 di Cir. 2002); United States' Sims, 428 F.3d 945, 9a9 (10th Cir. 2005); United Stalest. Helder, 452 F.3d 751 (8th Cir. 2006); United States'. Meek, 366 F.3d 705, 717-20 (9th Cir. 2004). Likewise, the Circuits have rejected void for vagueness,
ndeed, such a swing of the pendulum can be seen in thehistory of Arthur Andersen. At the start of the twentieth century, like other accounting fums, Andersen carried out non-audit services. By the 1960s, it was possible to become an Andersen consultant without having worked as an auditor for the two prio
ime. See United States v. Root, 296 F.3d 1222, 1227-32 (11th Cir. 2002); United States v. Sims, 428 F.3d 945, 959 (10th Cir. 2005); United States x Helder, 452 F.3d 751 (8th Cir. 2006); United States v. Meek, 366 F.3d 705, 717-20 (9th Cir. 2004). Likewise, the Circuits have rejected void for vagueness,
deed, such a swing of the pendulum can be seen in thehistory of Arthur Andersen. At the start of the twentieth century, like other accounting firms, Andersen carried out non-audit services. By the 1960s, it was possible to become an Andersen consultant without having worked as an auditor for the two prio
thrrime. See nited States v. Root, 296 t3d 1222, 1227-32 ( 1°' Cir. 2002). United States Sims, 428 3d 945, 959 (10° Cir. 1 005); United States I Helder, 45213d 751 (8th Cir. 2006); United States !Meek, 366 3d 705, 717-20 (9th Cir. 2004). Likewise, the Circuits have rejected void or vagueness, overb
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