A Restraint On Gov't 'Stream Of Payments' Theory

Law360, New York (December 12, 2013, 7:01 PM EST) -- ​Just prior to Thanksgiving, the Second Circuit issued an unusual summary order reversing the convictions of three former General Electric Co. executives a little over a week following oral argument. The three defendants were convicted after a trial in the Southern District of New York in May 2012 of conspiring to commit bid rigging in connection with the sale of municipal bond guaranteed investment contracts (“GICs”).

On Dec. 9, 2013, in a 2-1 decision, the Second Circuit confirmed the expected basis for the reversal, holding that...
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