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Fundamentally, the reason why the firm was on the hook is, after the firm got an inquiry from the FARA unit, it then went to the partner who was in charge of this matter and asked about the inquiry, and based on his representations then made a series of representations to the Justice Department that were not accurate, and when you think about the lack of due diligence that went into the work that was done before the representations were made to Justice Department, and when you think about how different Justice Department is from what you would advise your clients to do... it's really remarkable.

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