Skip to main content

May 28, 2023

Volume XIII, Number 148

National Law Review
  • Login
  • Mdn
  • FB
  • twt
  • link
  • home
  • rss
Advertisement
  • logo
  • Publish / Advertise with Us
    • Publish
    • Advertise
    • Publishing Firms
    • E Newsbulletins
    • Law Student Writing Contest
    • Contact Us
    • Terms of Use
    • Privacy Policy
    • Join Our Team
    • Search
  • Trending Legal News
    • Most Recent
    • Legal News Podcast
    • What's Trending
    • Type of Law
      • Antitrust Law
      • Bankruptcy & Restructuring
      • Biotech, Food & Drug
      • Business of Law
      • Construction & Real Estate
      • Cybersecurity Media & FCC
      • Election & Legislative
      • Environmental & Energy
      • Family, Estates & Trusts
      • Financial, Securities & Banking
      • Global
      • Health Care Law
      • Immigration
      • Insurance
      • Intellectual Property Law
      • Labor & Employment
      • Litigation
      • Public Services, Infrastructure, Transportation
      • Tax
      • White Collar Crime & Consumer Rights
    • E Newsbulletins
    • Legal Educational Events
    • NLR Blog
    • Search
  • About Us
    • About the NLR
    • NLR Team
    • Publishing Firms
    • E Newsbulletins
    • NLR Thought Leadership Awards
      • 2018
      • 2019
      • 2020
      • 2021
      • 2022
    • NLR Blog
    • Contact Us
    • Terms of Use
    • Privacy Policy
    • Search
  • Contact Us
    • Contact Us
    • E Newsbulletins
    • Publish
    • Advertise
    • Law Student Writing Contest
    • Search
  • Quick Links
    • Legal News Podcast
    • Type of Law
      • Antitrust Law
      • Bankruptcy & Restructuring
      • Biotech, Food & Drug
      • Business of Law
      • Construction & Real Estate
      • Cybersecurity Media & FCC
      • Election & Legislative
      • Environmental & Energy
      • Family, Estates & Trusts
      • Financial, Securities & Banking
      • Global
      • Health Care Law
      • Immigration
      • Insurance
      • Intellectual Property Law
      • Labor & Employment
      • Litigation
      • Public Services, Infrastructure, Transportation
      • Tax
      • White Collar Crime & Consumer Rights
    • E Newsbulletins
    • Legal Educational Events
    • Law Student Writing Contest
    • NLR Blog
    • Contact Us
    • Search
  • ENEWSBULLETINS

9

New Articles
Bottom Row Image
Advertisement

May 27, 2023

Subscribe to Latest Legal News and Analysis
  • New Washington Law Regulates Warehouse Distribution Center Worker... by: Kathryn J. Barry and Sherry L. Talton
  • Minnesota Governor Signs Labor Funding, Noncompete Ban Bill Into Law by: Patrick R. Martin and Cynthia A. Bremer
  • The Saudi Center for Commercial Arbitration Adopts New Arbitration... by: Jonathan H. Sutcliffe and Thomas Parkin
  • Supreme Court Finds Warhol’s Commercial Licensing of “Orange Prince”... by: Theodore C. Max
  • The Government Flexes Its Summons Muscles by: Tax Practice Group McDermott Will Emery
  • SCOTUS Limits USEPA Authority to Regulate Wetlands Under Clean Water... by: Matthew J. Greenberg
  • State Department Delays Fee Increases for Nonimmigrant Visa and... by: Jennifer M. Cofer
  • Supreme Court Holds Forfeiture of Tax Sale Surplus Proceeds is a... by: Matt Abee
  • Supreme Court Issues Decision Sharply Limiting Clean Water Act... by: Bernadette M. Rappold and Kerri L. Barsh

May 26, 2023

Subscribe to Latest Legal News and Analysis
  • AI and Antitrust: When Does an Algorithm Become an Agreement? Part II by: Jennifer M. Driscoll
  • ECHA Publishes Annual Report on Helpdesk Activities by: Lynn L. Bergeson and Carla N. Hutton
  • Online Studies Policy to Resume for Foreign Students as COVID-19... by: Michael Bergman
  • Part I: With New DAO Law on the Books, Utah Joins Race with Wyoming... by: Jason H. Finger and Peter Cramer
  • Supreme Court Limits the Use of Federal Administrative Law Judges;... by: Kurt L. Krieger and Kevin W. Hivick Jr.
  • COVID-19 Vaccination Mandate Revoked for Covered Contractors by: Erin L. Toomey and Frank S. Murray
  • Rhode Island PFAS Lawsuit The Latest State Action by: John Gardella
  • Job Hazard Analysis: Pre-Test Planning, Communication, and... by: Frank D. Davis and John Surma
  • China Proposes to Amend GB 4806.1 General Safety Standard for Food-... by: David J. Ettinger and Eric Gu
  • SCOTUS Redefines the Bounds of the Clean Water Act with Its Decision... by: Armando Benincasa and Allyn G. Turner
  • Legal Invoice Management and Tracking for Law Firms by: Bill4Time
  • TNFD Publishes Final Draft Disclosure Framework by: Duncan Grieve and Jayshree Balakrishnan
  • NLRB General Counsel Jennifer Abruzzo Issues New Suggested Manual... by: Henry Morris, Jr.
  • NGOs Call on EPA to Remove PFAS from Plastic Containers by: Lynn L. Bergeson and Carla N. Hutton
  • Illinois increases Medicaid asset limit to $17,500 or did it? by: Bryan M. Montana
  • EEOC Issues Guidance on Use of AI in Employment Decisions by: Scott M. Nelson and Michael Reed
  • How Many Offices Must A California LLC Have? by: Keith Paul Bishop
  • Patchwork of State Data Privacy Laws Adds Three New Patches by: Alaap B. Shah and Audrey Davis
  • TCPAWORLD AFTERDARK: is this malpractice? by: Eric J. Troutman
  • 10,000 Lakes and . . . No Noncompetes? Minnesota Passes Law Banning... by: David J. Clark and Erik W. Weibust
  • Colorado Approves DIDMCA Opt-Out, Raising Concerns for Consumer... by: Moorari Shah and A.J. S. Dhaliwal
  • Challenging OSHA Violations at Occupational Safety and Health Review... by: Melanie L. Paul and Kristina H. Vaquera
  • South Carolina Fetal Heartbeat and Protection from Abortion Act... by: Konnor Owens Marlar
  • NLRB General Counsel Seeks Quicker Compliance with Board Orders by: C. Thomas Davis and Zachary V. Zagger
  • Health Apps and Consumer Privacy Update: Federal Trade Commission... by: Alaap B. Shah and Alexander J. Franchilli
  • Another Vulnerability for Cybersecurity of Retirement Plan Data: Auto... by: Michelle Capezza
  • Surgeon To Pay Up to $43 Million for FCA Fraud by: D. Jacques Smith and Randall A. Brater
  • The Philippines Consults on Draft Consent and Private Identification... by: Charmian Aw and Scott A. Warren
  • Florida Expands Ban on Vaccination, Testing and Masking Mandates by: Jurate Schwartz and Evandro C Gigante
  • EPA Proposes to Eliminate TSCA Exemptions for PFAS and PBTs; Proposes... by: Ryan J. Carra and Mark N. Duvall
  • Texas Legislature Passes Bill Creating Specialized Business Trial... by: David G. Cabrales and Rebecca L. Jordan
  • Analogous Art Must Be Compared to Challenged Patent by: Paul Devinsky and Amol Parikh
  • PTO Proposes Trademark Fee Increases by: Paul Devinsky and Amol Parikh
  • Mcdermottplus Check-Up: May 26, 2023 by: McDermott + Consulting
  • Michigan PFAS Drinking Water Challenge Briefing Complete by: John Gardella
  • A Big Day for the Little Guy – SCOTUS Today by: Stuart M. Gerson

May 25, 2023

Subscribe to Latest Legal News and Analysis
  • Report Underscores Challenges of Attracting Capital for Renewable... by: Sukhvir Basran and Timbre Shriver
  • Six Decisions, with Intellectual Property and Internet Communications... by: Stuart M. Gerson
  • (UK) Pensions – A Pot to Play for? by: Restructuring & Insolvency Practice at Squire Patton Boggs
  • NHTSA and Motor Vehicle Safety Update by: Christopher H. Grigorian and R. Nicholas Englund
  • Immigration & Compliance FAQs on the Recently Signed Florida E-... by: Kate Kalmykov and Nataliya Rymer
  • Generac to Pay $15.8 Million Civil Penalty for Failure to Immediately... by: Sheila A. Millar and Antonia Stamenova-Dancheva
  • Boston US Attorney Likely to Face Bar Probe, Ethicists Say by: Richard J. Rosensweig
  • Keeping it Real (Estate): FTC Secures First Monetary Settlement... by: Phyllis H. Marcus
  • EU’s Global Gateway: €18 billion of Financing Announced for Climate... by: Simon Walsh
  • Fit for 55 Package: EU Revises the EU Emissions Trading System and... by: Mélanie Bruneau and Giovanni Campi
  • June 2023 Visa Bulletin Brings Warning of EB-3 Final Action Date... by: Rebecka E. Reibe
  • Publications Settlement Reached After 200,000 Affected by HIPAA Breach by: Jennifer Orr Mitchell and Ashley E. Durner
  • Supreme Court Tosses NY Corruption Convictions, Signaling Skepticism... by: Tara S. Sarosiek and Virginia C. Wright
  • Florida Bans Offshoring of Certain Patient Information by: Michael D. Sutton
  • PFAS and Beyond: Restatement of Torts Will Shape Toxic Torts... by: John Gardella
  • New Jersey Significantly Expands Rights and Protections of Temporary... by: Sean J. Kirby and Maria A. Gomez
  • Remote Monitoring Services Under Review: Update on Potential Medicare... by: Caroline Reignley and Deborah R. Godes
  • The EGG Debate Heats Up: State AGs Investigating Asset Manager... by: Lance C. Dial and Anna E. L'Hommedieu
  • Supreme Court Limits Federal Jurisdiction Over Wetlands by: Lisa A. Gilbreath and Michelle N. O'Brien
  • First Circuit: Claim Preclusion Shouldn’t Apply to Bar Claims Under... by: Hannah Cohen
  • Obesity as a Disability Under the Americans With Disabilities Act by: Collin K. Brodrick
  • Supreme Court Unanimously Affirms Amgen Repatha® Antibody Patents... by: Joseph D. Rutkowski and Peter J. Cuomo
  • Salmonella Outbreak Linked to Papa Murphy’s Cookie Dough by: Food and Drug Law at Keller and Heckman
  • Intellectual Property for the Metaverse by: Frank L. Gerratana
  • SEC Off-Channel Communications Sweep by: Kate Rumsey and Christopher J. Bosch
  • This Amendment To An LLC's Articles Of Organization Is Strictly... by: Keith Paul Bishop
  • Four Ways Clean Alumni Data Can Help Your Alumni Program by: Christina R. Fritsch JD
  • The Adverse Impacts of AI in Employment Procedures Under Title VII by: Deja M. Davis and Richard W. Warren
  • NIST Releases Initial Public Draft of NIST SP 800-171, Revision 3 for... by: Townsend L. Bourne and Lauren Weiss
  • Tempur Sealy Acquisition of Mattress Firm: A Vertical Bridge Too Far... by: Jonathan Rubin
  • Minnesota Legislature Passes New Recreational Marijuana Bill by: Brent D. Kettelkamp
  • Sixth Circuit Adopts New Standard to Decide Whether to Send Notice to... by: David R. Golder and Eric R. Magnus
  • Supreme Court Pulls Back Dormant Commerce Clause in National Pork... by: Meera Gorjala and Alex Garel-Frantzen
  • Government Contracts Cost and Pricing – The Truth in Negotiations Act... by: Keith R. Szeliga and Katie A. Calogero
  • UK ICO Publishes New Guidance on Subject Access Requests by: Hunton Andrews Kurth’s Privacy and Cybersecurity
  • How Law Firms Can Build a Stronger Internal Culture by: Stefanie M. Marrone
  • EPA Will Propose Updates to New Chemicals Regulations to Improve... by: Government Regulation
  • California Supreme Court Expands Employee Whistleblower Protections by: Anthony J Oncidi and Wesley C. Shelton
  • Illinois Legislature Passes Bill that Would Allow Punitive Damages in... by: Scott Dorsett and Francis A. Citera
  • New Bipartisan Immigration Bill Introduced by: Laura Foote Reiff
  • AI, AI, Uh-Oh! Can Artificial Intelligence Programs Put You at Risk... by: Whitney J. Jackson and Anne R. Yuengert
  • ICE Announces July and August Deadlines for Employers: Preparing for... by: Greg L. Berk and Christine L. Doyle
  • Sixth Circuit Rejects Two-Step Collective Certification Process in... by: Michael B. Mattingly and Jared Buker
  • Texas is Making Moves on a Comprehensive Consumer Privacy Law by: Michael D. Sutton and Sara Helene Shanti
  • The Supreme Court Kept the Door Open to Genus Claims by: Fangli Chen and Lawrence H. Frank, Ph.D.
  • FDA Establishes Public Docket Soliciting Comments on Nitrosamine Drug... by: Christopher Shaun Polston
  • Supreme Court Affirms IRS Power to Summons Bank Information Without... by: G. Michelle Ferreira and Scott E. Fink
  • White House OSTP Extends Comment Period for RFI on NNI EHS Research... by: Lynn L. Bergeson and Carla N. Hutton
  • FTC Proposes Amendments to Health Breach Notification Rule by: Hunton Andrews Kurth’s Privacy and Cybersecurity
  • Current Whistleblower Procedures Fall Short of U.S. Strategy on... by: Stephen M. Kohn
  • Changes to Spanish Data Protection Laws by: Bartolome Martin and Claire Murphy
  • Employer Obligations to Address the Rise in Workplace Violence by: Jane H. Heidingsfelder and Jacob J. Pritt
  • NLRB GC Files Complaint Alleging USC’s Football and Basketball... by: Natale V. DiNatale
  • Time to Say Goodbye to Your Business Partner: When Subtraction Can... by: Ladd Hirsch
  • Amazon Drivers Avoid Arbitration Claiming Non-delivery of Updated TOS by: Tara Brailey

Article By

Michael W. Paddock
Keeley A. McCarty

Sheppard, Mullin, Richter & Hampton LLP
Healthcare Law Blog
Sheppard, Mullin, Richter & Hampton LLP full service Global 100 law firm handling corporate law

Related Practices & Jurisdictions


  • Health Law & Managed Care
  • Litigation / Trial Practice
  • Administrative & Regulatory
  • All Federal
  • Printer-friendly
  • Email this Article
  • REPRINTS & PERMISSIONS
Tweet
Advertisement

The Granston Memo in 2019: Recent Cases Highlight the Granston Memo’s Effectiveness as a Tool to Dismiss False Claims Act Cases

Thursday, December 5, 2019

The “Granston Memo” has proven to be a boon again in 2019 for False Claims Act (“FCA”) defendants.  In a January 15, 2019 Sheppard Mullin FCA Defense Blog article, we highlighted a growing movement by the Department of Justice (“DOJ”) to utilize its dismissal power on meritless and burdensome qui tam FCA cases following an internal policy memorandum issued in early 2018, now dubbed the “Granston Memo.”  The Granston Memo encouraged DOJ attorneys to seek dismissal of such cases where it served one or more important policy objectives.  The DOJ has met with almost uniform success in its continued focus on this effort: since the Memo issued, the DOJ has sought dismissal in 36 cases and been unsuccessful only twice. 

The FCA allows DOJ to seek dismissal of FCA cases over objections by qui tam relators, even of cases in which DOJ elects not to intervene.  See 31 U.S.C. § 3730(c)(2)(A).  The FCA does not state what standard of review courts should use in deciding whether to grant dismissal, however.  This has led to a circuit split among the DC Circuit, which gives DOJ “unfettered discretion” in dismissal, and the 9th and 10th Circuits, which require a “rational relation” between dismissal and a “valid governmental purpose.”  Most courts hearing dismissal motions in 2019 declined to adopt officially either standard of review, instead opting to hold that DOJ’s motions met both standards.

Such was the case in United States ex rel. NHCA-TEV, LLC, et al. v. Teva Pharmaceutical Products Ltd., et al., where the court noted “the significant amount of deference that both standards give the Government.”  Case No. 17-02040 (E.D. Pa. Nov. 25, 2019), at 5.  In Teva, the Eastern District of Pennsylvania granted DOJ’s motion to dismiss a qui tam complaint against Teva Pharmaceuticals and related entities brought by a professional relator, NHCA-TEV, LLC.  NHCA claimed in Teva and 11 nearly identical cases brought in various district courts that drug manufacturers had provided illegal kickbacks in the form of free nursing and reimbursement assistance associated with particular drug prescriptions.  NHCA alleged that these complimentary services violated the Federal Health Care Program Anti-Kickback Statute and resulted in false claims for payment by the receiving providers.  In considering DOJ’s motion to dismiss, the court held that DOJ had identified two valid governmental purposes served by dismissal: (1) preserving government resources, and (2) protecting policy prerogatives of Medicare and Medicaid.  The court found a rational relation between dismissal and both stated reasons and noted that “[t]his is not a rigorous test.”  In April, upon motion by the DOJ, the Eastern District of Pennsylvania dismissed a similar case by NHCA against EMD Serono and Pfizer.  See United States ex rel. SMSPF, LLC, et al. v. EMD Serono, Inc., et al., Case No. 16-5594 (E.D. Pa. Apr. 3, 2019).

The January 15, 2019 Sheppard Mullin FCA Defense Blog article (see above) reported on the DOJ’s efforts to dispose of Teva and the other cases brought by NHCA and its related shell companies.  Teva was the last of the 12 to be decided.  All but one of those cases were either dismissed upon motion by DOJ or voluntarily dismissed by relators, though several appeals by the relators are pending.  The one exception is the Southern District of Illinois in United States ex rel. CIMZNHCA, LLC, et al. v. UCB, Inc., et al., Case No. 17-CV-765 (S.D. Ill. Apr. 15, 2019).  The relator in UCB alleged illegal kickbacks through nursing and reimbursement services in connection with prescriptions of UCB’s drug, Cimzia.  However, the Southern District of Illinois diverged completely from the other district courts, holding that DOJ’s review of the allegations fell short of a “minimally adequate investigation” to support its dismissal request, and also noting that DOJ had not done an adequate cost-benefit analysis to support its stated purpose of conserving public resources.  The court even suggested that the DOJ’s proffered reasons for dismissal were pretext for DOJ’s apparent “animus” toward professional relators, citing the more than six pages of DOJ’s brief devoted to criticizing NHCA.  DOJ’s appeal of this decision is pending before the 7th Circuit.

DOJ previously met with a similar setback in the Northern District of California in a case related to mortgage fraud, where the court held that DOJ had not done an adequate investigation of relator’s allegations before seeking dismissal.  The DOJ appealed the court’s denial of its motion, but the 9th Circuit cast doubt on DOJ’s right to even appeal its failed motion.  See United States v. United States ex rel. Gwen Thrower, Case No. 18-16408 (9th Cir. Nov. 14, 2019).

These are minor blemishes on a near-perfect record, however.  The DOJ has been so successful at getting cases dismissed that some Congress members are taking notice.  Senator Chuck Grassley (R-Iowa) wrote a letter to the Attorney General in September of this year expressing concern that the Granston Memo could “undermine the purpose of the False Claims Act by discouraging whistleblowers and dismissing potentially serious fraud on the taxpayers.”  Regardless, if there is a lesson to be learned from the two instances in which DOJ failed to procure dismissal, it is that FCA defendants should be prepared to provide enough information to the DOJ so that, if need be when seeking dismissal, DOJ can show that it conducted more than a cursory investigation of the relator’s allegations and be able to explain the associated cost-benefit analysis to support dismissal.

Copyright © 2023, Sheppard Mullin Richter & Hampton LLP.National Law Review, Volume IX, Number 339
  • Printer-friendly
  • Email this Article
  • REPRINTS & PERMISSIONS
Advertisement

Latest Legal News & Analysis

New Washington Law Regulates Warehouse Distribution Center Worker Quotas
Jackson Lewis P.C.
Minnesota Governor Signs Labor Funding, Noncompete Ban Bill Into Law
Ogletree, Deakins, Nash, Smoak & Stewart, P.C.
The Saudi Center for Commercial Arbitration Adopts New Arbitration Rules
K&L Gates
Supreme Court Finds Warhol’s Commercial Licensing of “Orange Prince” to Vanity...
Sheppard, Mullin, Richter & Hampton LLP
The Government Flexes Its Summons Muscles
McDermott Will & Emery
Advertisement

TRENDING LEGAL ANALYSIS

Part I: With New DAO Law on the Books, Utah Joins Race with Wyoming and Tennessee...
By
Proskauer Rose LLP
Supreme Court Limits the Use of Federal Administrative Law Judges; Related FERC...
By
Steptoe & Johnson PLLC
COVID-19 Vaccination Mandate Revoked for Covered Contractors
By
Foley & Lardner LLP
Rhode Island PFAS Lawsuit The Latest State Action
By
CMBG3 Law
Job Hazard Analysis: Pre-Test Planning, Communication, and Documentation [PODCAST]
By
Ogletree, Deakins, Nash, Smoak & Stewart, P.C.
China Proposes to Amend GB 4806.1 General Safety Standard for Food-Contact Materials
By
Keller and Heckman LLP

Upcoming Legal Education Events

State Of The Tax Equity Market And Post-IRA Sources Of Funding
Wednesday, May 31, 2023
PE & Healthcare Summit Berlin 2023
Tuesday, June 6, 2023
Ward and Smith's 2023 Health Care Breakfast and Learns at New Bern Golf & Country Club!
Wednesday, June 7, 2023
Medicare Advantage Marketing Today: Recent Changes to CMS Rule
Wednesday, June 7, 2023
Advertisement

About this Author

Michael W. Paddock
Partner

Mr. Paddock's practice primarily involves healthcare fraud and abuse matters, particularly those relating to civil False Claims Act, physician self-referral (Stark Law), and anti-kickback issues. He often advises clients on compliance and transactional matters, the conduct of internal investigations related to potential fraud and abuse issues, and responding to and defending against government anti-fraud and abuse enforcement efforts and regulatory inquiries, including qui tam and government allegations of False Claims Act violations. He is an active member of...

[email protected]
202-747-1954
www.sheppardmullin.com
Keeley A. McCarty
Keeley A. McCarty, Sheppard Mullin, Government Investigations Lawyer, International Trade Attorney
Associate

Keeley McCarty is an associate in the Government Contracts, Investigations & International Trade Practice Group in the firm's Washington, D.C. office.

Ms. McCarty’s practice focuses on government contracts litigation and counseling, including contract termination appeals, litigation and arbitration of subcontractor disputes, and internal investigations.  Ms. McCarty has counseled clients on a broad range of legal topics, including FAR mandatory disclosure rules, title passage under government contracts, and corporate compliance with the FCPA...

[email protected]
202-747-2186
www.sheppardmullin.com
National Law Review
  • Antitrust Law
  • Bankruptcy & Restructuring
  • Biotech, Food, & Drug
  • Business of Law
  • Election & Legislative
  • Construction & Real Estate
  • Environmental & Energy
  • Family, Estates & Trusts
  • Financial, Securities & Banking
  • Global
  • Health Care Law
  • Immigration
  • Intellectual Property Law
  • Insurance
  • Labor & Employment
  • Litigation
  • Cybersecurity Media & FCC
  • Public Services, Infrastructure, Transportation
  • Tax
  • White Collar Crime & Consumer Rights
  • Coronavirus News
  • Law Student Writing Competition
  • Sign Up For NLR Bulletins
  • Terms of Use
  • Privacy Policy
  • FAQs

 

As a woman owned company, The National Law Review is a certified member of the Women's Business Enterprise National Council

Legal Disclaimer

You are responsible for reading, understanding and agreeing to the National Law Review's (NLR’s) and the National Law Forum LLC's  Terms of Use and Privacy Policy before using the National Law Review website. The National Law Review is a free to use, no-log in database of legal and business articles. The content and links on www.NatLawReview.com are intended for general information purposes only. Any legal analysis, legislative updates or other content and links should not be construed as legal or professional advice or a substitute for such advice. No attorney-client or confidential relationship is formed by the transmission of information between you and the National Law Review website or any of the law firms, attorneys or other professionals or organizations who include content on the National Law Review website. If you require legal or professional advice, kindly contact an attorney or other suitable professional advisor.  

Some states have laws and ethical rules regarding solicitation and advertisement practices by attorneys and/or other professionals. The National Law Review is not a law firm nor is www.NatLawReview.com  intended to be  a referral service for attorneys and/or other professionals. The NLR does not wish, nor does it intend, to solicit the business of anyone or to refer anyone to an attorney or other professional.  NLR does not answer legal questions nor will we refer you to an attorney or other professional if you request such information from us. 

Under certain state laws the following statements may be required on this website and we have included them in order to be in full compliance with these rules. The choice of a lawyer or other professional is an important decision and should not be based solely upon advertisements. Attorney Advertising Notice: Prior results do not guarantee a similar outcome. Statement in compliance with Texas Rules of Professional Conduct. Unless otherwise noted, attorneys are not certified by the Texas Board of Legal Specialization, nor can NLR attest to the accuracy of any notation of Legal Specialization or other Professional Credentials.

The National Law Review - National Law Forum LLC 3 Grant Square #141 Hinsdale, IL 60521  Telephone  (708) 357-3317 or toll free (877) 357-3317.  If you would ike to contact us via email please click here.

Copyright ©2023 National Law Forum, LLC