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2008 ABA Annual Meeting Section of Litigation, August 7-10, 2008 What Do You Mean I Can’t Spy on the Board? Strategies for Conducting Effective (and Legal) Internal Investigation Is The SEC Targeting Lawyers? Frank C. Razzano1Pepper Hamilton LLP Washington, D.C. INTRODUCTION Since the enactment of the Sarbanes-Oxley Act (“SOX”) in 2002,2 the Securities and Exchange Commission (“SEC” or the “Commission”) seems to have abandoned its traditional reluctance to bring administrative and civil actions...

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