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"There is no excuse for my wrongful conduct".
A concern may arise that such a tool opens the door to over-zealous enforcement, with the SEC pursuing those control persons who had nothing to do with the wrongful conduct.
"We came in here focused on basic principles and wrongful conduct," Ms. Estrich said.
Despite the payment, Glaxo expressly denied that it had engaged in any wrongful conduct.
In that settlement, Merck expressly denied that it engaged in wrongful conduct.
The settlements usually do not require the defendants to admit any wrongful conduct.
"Mr. Gansman did not participate in any wrongful conduct whatsoever," said his attorney, Barry Bohrer.
Garfield DeMarco denied any wrongful conduct and said he expected the land sale to be upheld.
"The victim's wrongful conduct contributed significantly to provoking the offense behavior," he said.
Plaintiffs' lawyers like to argue that class actions are essential to provide compensation and deter wrongful conduct.
The administrator believes "this wrongful conduct is just the tip of the iceberg," the administrator's lawyers, David R. Gelfand and Peter Schram, wrote.
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Justyna Jupowicz-Kozak
CEO of Professional Science Editing for Scientists @ prosciediting.com