It also covers responsibilities of company representatives and contractors or consultants. The guidelines cover all aspects of compliance stack testing in Louisiana, including initial notification, execution of the stack test, submittal of the stack test report, and final approval by LDEQ. Stack testing companies must also be certified by the Louisiana Environmental Laboratory Accreditation Program (LELAP). EPA test methods and procedures are followed by companies who conduct stack testing in Louisiana. It consists of the test procedures for industrial plants, oil and gas operations, and other related manufacturing facilities. The following information presents guidelines and policies of the LDEQ Emissions Testing Program. The Engineering Support Group of the Air Permits Division provides source testing guidance for the regulated facilities in Louisiana. We would be pleased to provide additional details or advice about specific situations.Engineering Notifications, Stack Testing Tools and Resources These publications are only intended to be a general discussion of the topics covered and should not be construed as legal advice. Shearman & Sterling LLP practices in Italy in association with Studio Legale Associato Shearman & Sterling.Īttorney Advertising - Prior results do not guarantee a similar outcome. Sultan Almasoud for the practice of law in Saudi Arabia. Shearman & Sterling LLP operates in association with The Law Firm of Dr. Shearman & Sterling is a partnership organized under the Hong Kong Partnership Ordinance and registered with the Law Society of Hong Kong for the practice of law in Hong Kong. Shearman & Sterling (London) LLP is a limited liability partnership organized under the laws of the State of Delaware for the practice of law in the United Kingdom. Copyright © 2024 Shearman & Sterling LLP is a limited liability partnership organized under the laws of the State of Delaware.In the Matter of Sridhar Thiruvengadam (2019) In re Cognizant Technology Solutions Corporation (2019) In the Matter of Cognizant Technologu Solutions Corporation (2019).On February 14, 2020, the court denied the defendants’ motion to dismiss the FCPA counts on the basis of multiplicity.

The DOJ claimed each email operated as a separate unit of prosecution and the court agreed.

The DOJ alleges that the contents of the emails were: (1) a request for a phone call with co-conspirators, (2) instructions to a co-conspirator to continue to withhold certain payments to the construction company, and (3) an authorization by Cognizant to pay the construction company’s change order requests. The three FCPA counts are based on three separate emails from Coburn to Schwartz and other co-conspirators between April 2014 and March 2015. On February 14, 2019, the DOJ filed a twelve-count indictment against Coburn and Schwartz, alleging one count of conspiracy to violate the FCPA, three counts of violating the FCPA, seven counts regarding false books and records, and one count of violating internal controls.To further disguise payment, a member of Cognizant’s real estate group allegedly altered certain descriptions of work in the invoice, ensuring the construction company was paid the bribe without documenting the true purpose of the reimbursement. To conceal the bribes, Coburn, Schwartz, and several unnamed co-conspirators allegedly agreed to pay its construction company for what was to be deemed a cost overrun of the campus construction in invoices and change orders issued to Cognizant. The defendants allegedly authorized the payment of approximately $2 million to secure the permit. According to the DOJ, the defendants further pressured the construction company to pay the bribes by offering reimbursements for those costs. The defendants, senior officials at Cognizant, allegedly threatened to withhold payments to the construction company until it had obtained all necessary permits. According to the indictment, Coburn and Schwartz paid bribes to unnamed government officials in India to secure a planning permit necessary for the construction of an office campus that would support approximately 17,000 Cognizant employees.Schwartz, a resident of Connecticut, was the former Chief Legal Officer for Cognizant. Coburn, a resident of Colorado, was the former president of Cognizant, a global information technology services provider, headquartered in Teaneck, New Jersey.

Steven schwartz ldeq