al criminal charges. See Memorandum from Craig S. Morford, Acting Deputy Att'y Gen., U.S. Dep't of Justice, to Heads of Department Components, U.S. Att'ys re: Selection and Use of Monitors in Deferred Prosecution Agreements and Non—Prosecution Agreements with Corporations 9 EFTA00211551 Case 9:08-c

of criminal charges. See Memorandum from Craig S. Morford, Acting Deputy Att'y Gen., U.S. Dep't of Justice, to Heads of Department Components, U.S. Att'ys re: Selection and Use of Monitors in Deferred Prosecution Agreements and Non-Prosecution Agreements with Corporations (Mar. 7, 2008) at note 2, ava

tead it was the norm. See Memorandum from Craig S. Morford, Acting Deputy Att'y Gen., U.S. Dept of Justice, to Heads of Department Components, U.S. Att'ys re: Selection and Use of Monitors in Deferred Prosecution Agreements and Non— Prosecution Agreements with Corporations (Mar. 7. 2008) at note 2 avail