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Editor's Note: It is important to have an established trigger in expense reporting and reimbursement tracking systems to place a red flag on any request at any amount submitted during a crisis event such as a natural disaster or pandemic for which the company has severely restricted or halted business travel, events, or engagements.
Adapted from Corporate Practice Portfolio Series, No. 104 The U.S. Foreign Corrupt Practices Act: Enforcement and Compliance, Practice Tool 10 Sample Facilitating Payments Provision, by F. Joseph Warin, Michael S. Diamant, and Elizabeth Goergen Silver, Gibson, Dunn & Crutcher LLP
Name of Company employee seeking reimbursement: _____________________
Total amount of reimbursement* requested: _____________________
Names of all other Company employees who attended: _____________________
List all other individuals who attended and state their name, affiliation (employer) and title:
Are any of the individuals who attended employed by a government office, department or government-owned company or enterprise? If yes, list their names, affiliation (employers) and titles below (these individuals also should be listed in response to the prior question):
By signing this expense reimbursement request, I hereby certify that this is a complete and accurate record of all individuals who attended this event. I acknowledge that providing false or incomplete information may be grounds for disciplinary action, up to and including termination.
Name (please print):_______________ Title:__________
* Note that receipts are required for all expenses. No entertainment expenses will be reimbursed without a receipt.