To: sharshbarger@proskauer.com
Sent: 2/8/2013 12:35:26 P.M. Central Standard Time
Subj: 2012 FSGO report- individual accountability
Dear Mr. Harshbarger,
I hope you as a member of the FSGO panel who has the qualification of previous experience of being the Massachusetts attorney general will be willing to look at these Comments for FSGO panel that I have prepared and posted.
My comments are critical of a lack of interest of FSGO Report proponents in holding accountable individual officers and employees who have played a culpable role in corporate wrongdoing, and that this lack of interest may cause the Report to lose credibility with the Justice Department and others on the governmental side of this matter.
I know the Report is done and signed off on, including by yourself. Nonetheless I wish to press on the matter.
Thank you.
Sincerely,
Rob Shattuck
Birmingham, AL
From: RDShatt@aol.com
To: paul.mcnulty@bakermckenzie.com
Sent: 2/10/2013 9:34:10 A.M. Central Standard Time
Subj: 2012 FSGO report- individual accountability
Dear Mr. McNulty,
I hope you as a member of the FSGO panel who has the qualification of previously being Deputy Attorney General in the Department of Justice will be willing to look at these Comments for FSGO panel that I have prepared and posted.
My comments are critical of a lack of interest of FSGO Report proponents in holding accountable individual officers and employees who have played a culpable role in corporate wrongdoing, and that this lack of interest may cause the Report to lose credibility with the Justice Department and others on the governmental side. Your past DOJ experience would seem to put you in a special position among the FSGO panel members to judge this criticism.
I know the Report is done and signed off on, including by yourself. Nonetheless I wish to press on the matter.
Thank you.
I hope you as a member of the FSGO panel who has the qualification of previous experience of being the Massachusetts attorney general will be willing to look at these Comments for FSGO panel that I have prepared and posted.
My comments are critical of a lack of interest of FSGO Report proponents in holding accountable individual officers and employees who have played a culpable role in corporate wrongdoing, and that this lack of interest may cause the Report to lose credibility with the Justice Department and others on the governmental side of this matter.
I know the Report is done and signed off on, including by yourself. Nonetheless I wish to press on the matter.
Thank you.
Sincerely,
Rob Shattuck
Birmingham, AL
From: RDShatt@aol.com
To: paul.mcnulty@bakermckenzie.com
Sent: 2/10/2013 9:34:10 A.M. Central Standard Time
Subj: 2012 FSGO report- individual accountability
Dear Mr. McNulty,
I hope you as a member of the FSGO panel who has the qualification of previously being Deputy Attorney General in the Department of Justice will be willing to look at these Comments for FSGO panel that I have prepared and posted.
My comments are critical of a lack of interest of FSGO Report proponents in holding accountable individual officers and employees who have played a culpable role in corporate wrongdoing, and that this lack of interest may cause the Report to lose credibility with the Justice Department and others on the governmental side. Your past DOJ experience would seem to put you in a special position among the FSGO panel members to judge this criticism.
I know the Report is done and signed off on, including by yourself. Nonetheless I wish to press on the matter.
Thank you.
Sincerely,
Rob Shattuck
Birmingham, AL
From: RDShatt@aol.com
To: fsgocomments@ethics.org
Sent: 2/10/2013 10:13:49 A.M. Central Standard Time
Subj: The Honorable Ruben Castillo
By email and U.S. mail
The Honorable Ruben Castillo
Chambers 2146
Everett McKinley Dirksen United States Courthouse
219 South Dearborn Street
Chicago, IL 60604
Re: 2012 FSGO report- private class action litigation
Dear Judge Castillo,
I hope you as a member of the FSGO panel who has the qualification of being a United States District Judge will be willing to look at these Comments for FSGO panel (URL http://robertshattuck.blogspot.com/2013/02/comments-for-fgso-panel.html) that I have prepared and posted on the Internet.
The FSGO Report makes a hard push to extend the FSGO beyond DOJ criminal cases and for other Federal agencies to recognize and give credit for ECEP's in non-criminal enforcement actions of such other agencies.
My comments urge that the Report proponents also look at the realm of private class action litigation as a further avenue for pursuing their ethics and compliance mission.
As a district judge who has likely handled class action litigation and has judicial understanding of the same, you would seem in a special position among the FSGO panel members to evaluate and judge what I say about private class action litigation.
I know the Report is done and signed off on, including by yourself. Nonetheless I wish to press on the matter.
Thank you.
Sincerely,
Rob Shattuck
Birmingham, AL
From: RDShatt@aol.com
To: moxley@bakerlaw.com
Sent: 2/12/2013 2:50:27 A.M. Central Standard Time
Subj: 2012 FSGO report- individual accountability
Dear Mr. Oxley,
I hope you as the member of the FSGO panel who has the qualification of previously being a member of Congress will be willing to look at these Comments for FSGO panel that I have prepared and posted.
My comments are critical of a lack of interest of FSGO Report proponents in holding accountable individual officers and employees who have played a culpable role in corporate wrongdoing, and that this lack of interest may cause the Report to lose credibility with the Justice Department and others on the governmental side, including lawmakers.
Your having been a member of Congress who famously has his name on a piece of legislation that significantly increased corporate officer liability for wrongdoing would seem to put you in a unique position among the FSGO panel members to comment on this criticism.
I know the Report is done and signed off on, including by yourself. Nonetheless I wish to press on the matter.
Thank you.
Sincerely,
Rob Shattuck
Birmingham, AL
From: RDShatt@aol.com
To: fsgocomments@ethics.org
Sent: 2/13/2013 4:25:01 A.M. Central Standard Time
Subj: The Honorable Diana Murphy
By email and U.S. mail
The Honorable Diana Murphy
Thomas F. Eagleton Courthouse
Room 24.329
111 South 10th Street
St. Louis, MO 63102
Re: 2012 FSGO report
Dear Judge Murphy,
I hope you as a member of the FSGO panel who has had a long career in the judiciary and who served on the Federal Sentencing Commission will be willing to look at these Comments for FSGO panel (URL http://robertshattuck.blogspot.com/2013/02/comments-for-fgso-panel.html) that I have prepared and posted on the Internet.
My comments are, among other things, critical of a lack of interest of FSGO Report proponents in holding accountable individual officers and employees who have played a culpable role in corporate wrongdoing, and that this lack of interest may cause the Report to lose credibility with the Justice Department and others on the governmental side.
Also, the FSGO Report pushes to extend the FSGO beyond DOJ criminal cases and for other Federal agencies to recognize and give credit for ECEP's, and my comments urge that the Report proponents further look at the realm of private class action litigation as a venue for application of the FSGO and for otherwise pursuing their ethics and compliance mission.
With your long judicial experience, and with your Federal Sentencing Commission involvement with the FSGO, you would seem special among the FSGO panel members to obtain a reaction from regarding my comments and criticisms about the FSGO Report.
I know the Report is done and signed off on, including by yourself. Nonetheless I wish to press on the matter.
Thank you.
Sincerely,
Rob Shattuck
Birmingham, AL
From: RDShatt@aol.com
To: savelino@CSLG.com, wswenson@CSLG.com
Sent: 2/20/2013 10:30:19 A.M. Central Standard Time
Subj: 2012 FSGO report-- consultants and FSGO Sec. 8B2.1(b)(6)
Dear Mr. Swenson, and Mr. Avelino,
I am contacting you as the members of the 2012 FSGO panel who are engaged in the compliance and ethics consulting business.
I am doing this in order to try to obtain information about the extent to which compliance and ethics programs that are marketed to corporations by your company Compliance Systems Legal Group and by other consulting companies have components that endeavor to be responsive to the FSGO Sec. 8B2.1(b)(6) provision about a corporation's program "being enforced consistently throughout the organization through . . . (B) appropriate disciplinary measures for engaging in criminal conduct and for failing to take reasonable steps to prevent or detect criminal conduct").
This information request is related to these Comments for FSGO panel that I have prepared and posted. My comments say that there is a lack of interest of FSGO Report proponents in holding accountable individual officers and employees who have played a culpable role in corporate wrongdoing. I think it is relevant to the validity of this assertion the extent to which the programs marketed by consulting companies do or do not have components that endeavor to be responsive to Sec. 8B2.1(b)(6).
If you can provide me any information about what your and other consulting companies are marketing in this regard, I will be most appreciative.
Thank you.
Sincerely,
Rob Shattuck
Rob Shattuck
Birmingham, AL
From: RDShatt@aol.com
To: fsgocomments@ethics.org
Sent: 2/10/2013 10:13:49 A.M. Central Standard Time
Subj: The Honorable Ruben Castillo
By email and U.S. mail
The Honorable Ruben Castillo
Chambers 2146
Everett McKinley Dirksen United States Courthouse
219 South Dearborn Street
Chicago, IL 60604
Re: 2012 FSGO report- private class action litigation
Dear Judge Castillo,
I hope you as a member of the FSGO panel who has the qualification of being a United States District Judge will be willing to look at these Comments for FSGO panel (URL http://robertshattuck.blogspot.com/2013/02/comments-for-fgso-panel.html) that I have prepared and posted on the Internet.
The FSGO Report makes a hard push to extend the FSGO beyond DOJ criminal cases and for other Federal agencies to recognize and give credit for ECEP's in non-criminal enforcement actions of such other agencies.
My comments urge that the Report proponents also look at the realm of private class action litigation as a further avenue for pursuing their ethics and compliance mission.
As a district judge who has likely handled class action litigation and has judicial understanding of the same, you would seem in a special position among the FSGO panel members to evaluate and judge what I say about private class action litigation.
I know the Report is done and signed off on, including by yourself. Nonetheless I wish to press on the matter.
Thank you.
Sincerely,
Rob Shattuck
Birmingham, AL
From: RDShatt@aol.com
To: moxley@bakerlaw.com
Sent: 2/12/2013 2:50:27 A.M. Central Standard Time
Subj: 2012 FSGO report- individual accountability
Dear Mr. Oxley,
I hope you as the member of the FSGO panel who has the qualification of previously being a member of Congress will be willing to look at these Comments for FSGO panel that I have prepared and posted.
My comments are critical of a lack of interest of FSGO Report proponents in holding accountable individual officers and employees who have played a culpable role in corporate wrongdoing, and that this lack of interest may cause the Report to lose credibility with the Justice Department and others on the governmental side, including lawmakers.
Your having been a member of Congress who famously has his name on a piece of legislation that significantly increased corporate officer liability for wrongdoing would seem to put you in a unique position among the FSGO panel members to comment on this criticism.
I know the Report is done and signed off on, including by yourself. Nonetheless I wish to press on the matter.
Thank you.
Sincerely,
Rob Shattuck
Birmingham, AL
From: RDShatt@aol.com
To: fsgocomments@ethics.org
Sent: 2/13/2013 4:25:01 A.M. Central Standard Time
Subj: The Honorable Diana Murphy
By email and U.S. mail
The Honorable Diana Murphy
Thomas F. Eagleton Courthouse
Room 24.329
111 South 10th Street
St. Louis, MO 63102
Re: 2012 FSGO report
Dear Judge Murphy,
I hope you as a member of the FSGO panel who has had a long career in the judiciary and who served on the Federal Sentencing Commission will be willing to look at these Comments for FSGO panel (URL http://robertshattuck.blogspot.com/2013/02/comments-for-fgso-panel.html) that I have prepared and posted on the Internet.
My comments are, among other things, critical of a lack of interest of FSGO Report proponents in holding accountable individual officers and employees who have played a culpable role in corporate wrongdoing, and that this lack of interest may cause the Report to lose credibility with the Justice Department and others on the governmental side.
Also, the FSGO Report pushes to extend the FSGO beyond DOJ criminal cases and for other Federal agencies to recognize and give credit for ECEP's, and my comments urge that the Report proponents further look at the realm of private class action litigation as a venue for application of the FSGO and for otherwise pursuing their ethics and compliance mission.
With your long judicial experience, and with your Federal Sentencing Commission involvement with the FSGO, you would seem special among the FSGO panel members to obtain a reaction from regarding my comments and criticisms about the FSGO Report.
I know the Report is done and signed off on, including by yourself. Nonetheless I wish to press on the matter.
Thank you.
Sincerely,
Rob Shattuck
Birmingham, AL
From: RDShatt@aol.com
To: savelino@CSLG.com, wswenson@CSLG.com
Sent: 2/20/2013 10:30:19 A.M. Central Standard Time
Subj: 2012 FSGO report-- consultants and FSGO Sec. 8B2.1(b)(6)
Dear Mr. Swenson, and Mr. Avelino,
I am contacting you as the members of the 2012 FSGO panel who are engaged in the compliance and ethics consulting business.
I am doing this in order to try to obtain information about the extent to which compliance and ethics programs that are marketed to corporations by your company Compliance Systems Legal Group and by other consulting companies have components that endeavor to be responsive to the FSGO Sec. 8B2.1(b)(6) provision about a corporation's program "being enforced consistently throughout the organization through . . . (B) appropriate disciplinary measures for engaging in criminal conduct and for failing to take reasonable steps to prevent or detect criminal conduct").
This information request is related to these Comments for FSGO panel that I have prepared and posted. My comments say that there is a lack of interest of FSGO Report proponents in holding accountable individual officers and employees who have played a culpable role in corporate wrongdoing. I think it is relevant to the validity of this assertion the extent to which the programs marketed by consulting companies do or do not have components that endeavor to be responsive to Sec. 8B2.1(b)(6).
If you can provide me any information about what your and other consulting companies are marketing in this regard, I will be most appreciative.
Thank you.
Sincerely,
Rob Shattuck
No comments:
Post a Comment