About the Author
Michael Rogoff is a partner in and co-chair of Kaye Scholer’s Complex Commercial Litigation Department and Head of the firm’s White Collar Litigation & Internal Investigations Practice. Based in New York, he is an experienced trial and appellate lawyer whose practice is concentrated in the areas of white collar and civil litigation. He can be reached at firstname.lastname@example.org.
Since Caronia was decided, the government has not been dissuaded from pursuing off-label cases in either the civil or criminal contexts and views its holding as limited.
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