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Practical Tips to Reduce FCPA Risk in Mergers and Acquisitions
document IMAGES-007-HOUSE_OVERSIGHT_022531.txt House Oversight Committee — Epstein Estate Records (Nov 2025)

…se 08-02. That case involved special circumstances, namely, severely limited pre-acquisition due diligence available to the potential acquiring company, and, because it was an opinion release (i.e., providing certain assurances by DOJ concerning prospective conduct), it necessari...

scrutiny than modest and routine gifts and entertainment
document IMAGES-007-HOUSE_OVERSIGHT_022561.txt House Oversight Committee — Epstein Estate Records (Nov 2025)

…f risk factors, is often counter- productive, diverting attention and resources away from those third parties that pose the most significant risks. DOJ and SEC will give meaningful credit to a company that implements in good faith a comprehensive, risk-based compliance program, e...

has taken steps to make certain that the code of conduct
document IMAGES-007-HOUSE_OVERSIGHT_022560.txt House Oversight Committee — Epstein Estate Records (Nov 2025)

has taken steps to make certain that the code of conduct remains current and effective and whether a company has periodically reviewed and updated its code. Whether a company has policies and procedures that outline responsibilities for compliance within the company, detail prop...

In May of 2011, SEC entered into its first deferred
document IMAGES-007-HOUSE_OVERSIGHT_022579.txt House Oversight Committee — Epstein Estate Records (Nov 2025)

77 In May of 2011, SEC entered into its first deferred prosecution agreement against a company for violating the FCPA.*® In that case, a global manufacturer of steel pipe products violated the FCPA by bribing Uzbekistan govern- ment officials during a bidding process to supply p...

Jeffrey Epstein: 1953-1969
document TEXT-001-HOUSE_OVERSIGHT_022058.txt House Oversight Committee — Epstein Estate Records (Nov 2025)

CHAPTER 20 Jeffrey Epstein: 1953-1969 Jeffrey Epstein's mother, Paula, was the daughter of Max and Lena Stolofsky, who arrived in the United States as Lithua- nian refugees. Relatives on that side of the family who remained in the old country would all perish in the course of Ad...

company. No enforcement action was taken against the suc
document IMAGES-007-HOUSE_OVERSIGHT_022532.txt House Oversight Committee — Epstein Estate Records (Nov 2025)

company. No enforcement action was taken against the suc- cessor, but the predecessor company pleaded guilty to one count of violating the FCPA and agreed to pay a $2 million fine.'” Later, four executives from the predecessor company were convicted of FCPA violations, three of w...

COLLABORATIVE INSIGHTS February 25, 2019
document IMAGES-008-HOUSE_OVERSIGHT_024918.txt Feb 25, 2019 House Oversight Committee — Epstein Estate Records (Nov 2025)

…h Price Targets: Cowen and Company, LLC assigns price targets on all companies covered in equity research unless noted otherwise. The equity research price target for an issuer's stock represents the value that the analyst reasonably expects the stock to reach over a performance...

You should rely only on the information contained in this Private Placement Memorandum (this
document IMAGES-007-HOUSE_OVERSIGHT_024434.txt House Oversight Committee — Epstein Estate Records (Nov 2025)

You should rely only on the information contained in this Private Placement Memorandum (this “Memorandum”) or to which we have referred you. We have not authorized anyone to provide you with information that is different. This Memorandum may only be used where it is legal to sell...

Ernest Garcia IT 2018) = = —_ _ —
document IMAGES-007-HOUSE_OVERSIGHT_024343.txt House Oversight Committee — Epstein Estate Records (Nov 2025)

…,250 386 17,451 2016 = — 11,250 — 11,250 G) Represents discretionary matching contributions under our 401(k) Plan (i) The 2016 and 2017 amounts for Mr. Garcia is the incremental cost to Carvana of flights relating to a personal event on the private aircraft operated by Bridgecr...

Breaking Down Democracy
document TEXT-001-HOUSE_OVERSIGHT_019233.txt House Oversight Committee — Epstein Estate Records (Nov 2025)

…ive Summary 1 Introduction: Modern Authoritarians: Origins, Anatomy, Outlook 5 Chapters 1. Validating Autocracy through the Ballot 10 2. Propaganda at Home and Abroad 15 3. The Enemy Within: Civil Society at Bay 22 4. The Ministry of Truth in Peace and War 29 5. The Rise of ‘Illi...

November 21, 2011
document TEXT-001-HOUSE_OVERSIGHT_030814.txt Nov 21, 2011 House Oversight Committee — Epstein Estate Records (Nov 2025)

November 21, 2011 Topic: The quixotic search for energy solutions Another Don Quixote Thanksgiving. Every year at Thanksgiving 1 , we look in-depth at an issue that affects markets and portfolios. Last year, we examined the unraveling situation in Europe. Unfortunately, most con...

EBITDA, Adjusted EBITDA and Adjusted EBITDAR (including pro forma presentations thereof) and the
document IMAGES-007-HOUSE_OVERSIGHT_024448.txt House Oversight Committee — Epstein Estate Records (Nov 2025)

NON-GAAP FINANCIAL MEASURES EBITDA, Adjusted EBITDA and Adjusted EBITDAR (including pro forma presentations thereof) and the related ratios presented in this Memorandum are supplemental measures of our performance that are not required by, or presented in accordance with, genera...