pability would involve grand jury proceedings-... the [DOJ] comments indicate several other possible reasonsc unrelated to culpability. Id. (citing Scott D. Hammond, Assistant Attorney General for Criminal Enforcement Antitrust Division, DOJ, Measuring the Value of Second-In Cooperation in Corporate Plea Negotia

U.S.C. § 46(d). law that is as complete, practical and effi- cient as that which equity could afford. R. Hewitt Pate, Assistant Attorney Gen- eral, Scott D. Hammond, Mahn Del shim, Deputy Assistant Attorneys General, John P. Fonte, John J. Powers, III, (Argued), United States Department of Justice, Anti- trust