Robert Rose

Robert Rose

Sheppard Mullin Richter & Hampton LLP

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Latest Publications


Cybersecurity: 36 Questions Every Director Should Ask

Cyber security, data loss, hacking and schemes to steal personal information and assets electronically are all over the news daily. Companies are the primary targets of these actions since they accumulate information, store...more

8/26/2013 - Cybersecurity Data Breach Data Protection Hackers

District Court Grants Motion to Compel Against SEC, Holding that "Facts" Are Not Work Product In SEC Confidential Witness...

In a recent Securities & Exchange Commission (“SEC”) investigation, the SEC interviewed three persons who had proffer agreements with the SEC and United States Attorney. In a subsequent SEC enforcement action, a defendant...more

5/3/2013 - Confidential Witnesses Motion to Compel SEC Work Product Privilege

False Press Release Leads To Exclusion From Federal Programs

Dr. Harkonen was the CEO of InterMune, Inc, a pharmaceutical company that developed, marketed and sold drugs for lung and liver diseases, including Actimmune. In 2002, the FDA had approved Actimmune to treat only two...more

2/20/2013 - Criminal Prosecution Cruel & Unusual Punishment Double Jeopardy Eighth Amendment False Press Release FDA Fifth Amendment HHS Misbranding Pharmaceutical Industry Prescription Drugs

DoJ and SEC Issue Long-Awaited FCPA Guidance

At last! We now have official guidance in one place from the United States Department of Justice and the Securities and Exchange Commission regarding the Foreign Corrupt Practices Act (“FCPA”). A lengthy memorandum was...more

11/19/2012 - Compliance DOJ FCPA FCPA Resource Guide SEC

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