Eric Lewis practices in the areas of international litigation and arbitration, serious fraud, banking, international insolvency and complex securities litigation. He has had a central role in disputes arising out of virtually all of the major international fraud and financial collapses of the last quarter century, including serving as counsel to the liquidators of Bank of Credit and Commerce International, Laker Airways, Carlyle Capital, Madoff International, China Medical and Akai Electronics. He has served as lead counsel in numerous cases involving collateralized debt obligations and other complex asset backed securities. He served as Global Legal Coordinator in a multinational dispute arising from the largest fraud in the history of the Middle East. He has also represented clients in major class action litigation, including Enron, WorldCom, and Visa/MasterCard. He advises and litigates on behalf of international banks and their owners facing regulatory challenges in the United States, banking resolution entities in Europe, as well as hedge funds and large family-owned Middle East conglomerates. He has advised major international clients in the automobile, energy, aviation, hospitality and beverage industries. He also represents a number of sovereign governments. He has served as an expert on extradition and enforcement of judgments.
Mr. Lewis has particular expertise assisting foreign clients dealing with the complexities of U.S. civil and criminal proceedings. He obtained a $1 billion racketeering judgment against a Saudi national and worked with a multinational team to obtain the first recognition in Saudi Arabia of a non-Arab League judgment. He has represented a leading hedge fund in a Foreign Corrupt Practices Act investigation, and the Executive Director of the United Nations Oil-for-Food Program in connection with U.N. and U.S. investigations. He acts for a client who is a cooperating witness in Special Counsel Robert Mueller’s investigation into the 2016 Presidential election.
He has served as Adjunct Professor of Law at Georgetown University Law Center and has lectured on legal topics at Oxford University and Yale Law School. He is an elected member of the Council on Foreign Relations and is a door tenant of Goldsmith Chambers in London.
Mr. Lewis was selected by Washington DC Super Lawyers and by Super Lawyers Corporate Counsel Edition (2009-2020) for Business Litigation. He is also featured in Who’s Who as an expert in international insolvency and was nominated by his peers to Who's Who Legal: Asset Recovery (2018-2019) and is included in The Best Lawyers in America© for Commercial Litigation. Mr. Lewis is a regular contributor to The New York Times, The New Yorker, Esquire and other publications. He is a Director of Independent Digital News and Media Limited.
Pro Bono and Community Service
Mr. Lewis has been a leading figure in international human rights. He has represented Guantánamo detainees for more than a dozen years in civil litigation, administrative hearings and habeas corpus petitions. He has also acted on behalf of Afghan prisoners held by the U.S. military in Afghanistan. He was lead counsel in litigation involving the treatment of hunger striking prisoners at Guantanamo and on behalf of a released Guantanamo detainee imprisoned in Morocco in breach of intergovernmental assurances. He worked to obtain the release of a dual U.S. Egyptian national sentenced to life in prison for blogging against the coup. He has acted on behalf of capital defendants both at the trial and appellate level, including the individual accused in the death of the U.S. Ambassador to Libya and others in Benghazi. He serves as Chairman of Reprieve US, a charity that actively litigates death penalty, indefinite detention and other human rights cases around the world. He serves on the board of the International Senior Lawyers Project.
- Elected Member, Council on Foreign Relations
- Adjunct Professor of Law at Georgetown University Law Center
- Door Tenant, Goldsmith Chambers. London
- Honorary Overseas Member of the Commercial Bar Association of England and Wales
- Elected Member of the American Law Institute
- Chairman, Reprieve US
- Observer with Special Consultative Status, 61st Meeting of United Nations High Commission on Human Rights, Geneva
- Fellow, American Bar Foundation
- Represented the Liquidators of BCCI in what was the largest bank collapse, largest multinational fraud and largest restitution in history.
- Represented Australian hedge fund in a series of cases against major NY investment banks in fraud claims relating to Collateralized Debt Obligations.
- Represented owner of Argentine airports in ICC arbitration regarding purchase of duty free stores.
- Expert on behalf of senior FIFA official involving extradition proceedings.
- Represents large Saudi merchant family in litigation against banks and others in $10 billion fraud.
- Represents two global charities in 9/11 litigation.
- Represents majority shareholders of European Bank in litigation against US Government for wrongful closure under USA Patriot Act.
- Represents largest financial institution in Yemen in U.S. sanctions proceedings.
- Represented dissident shareholder in dispute over management of international bank.
- Represented two Kuwaiti detainees in Periodic Review Board hearings at Guantánamo and obtained their clearance for release and repatriation.
- Represented Chinese company in liquidation in dispute regarding internal investigation undertaken prior to collapse.
- Represented prominent Venezuelan businessman in litigation surrounding collapse of investment fund.
- Represented former British detainees in civil claims for torture and religious abuse at Guantanamo.
- Represented Egyptian conglomerate in construction arbitration against US Army Corps of Engineers.
- Advised South American governments with respect to ICSID liability.
Publications & Events
- To understand why Trump and his AG make such a terrifying team, you have to delve into the psychology of Bill Barr
The combination of the President’s ego and Barr’s hardline Christian beliefs is uniquely dangerousSeptember 25, 2020
Eric Lewis is interviewed extensively in The Andorra Hustle, a documentary by Eric Merola about FinCEN's use of the USA PATRIOT Act to shut down Banca Privada d'Andorra.September 4, 2020
- A discussion of 'Liu v. SEC,' where the Supreme Court clarified the scope of the disgorgement remedy, and limited the SEC's discretion in making restitution to victims of securities fraud.New York Law Journal, August 13, 2020
The coronavirus pandemic has not only caused untold misery, it has forced the virtual shutdown of the global economy. Everyone hopes that this crisis will pass, but events have shown there is a false choice between mitigation and resumption of economic activity. Mitigation, with testing and social distancing, must be done to avoid wave after wave of disease, which will only lead to rolling cessations of economic activity. Given the economic dislocation occasioned by this global crisis and that it is likely to continue for at least a few more months, we can anticipate that many businesses will fail, and others will require time and help to restore financial health and operations. There is little doubt that innumerable global businesses will need the protection of an organized and coordinated insolvency and reorganization process as soon as this crisis is over. The time for them to begin planning is now.April 24, 2020
In recent weeks, the world has been engulfed by the spread of COVID-19 as governments scramble to protect their citizens and avoid the collapse of public health systems and long-term damage to their economies. The wide-ranging efforts to flatten the curve of COVID-19 has created a tidal wave of ramifications for an international business community that is today more interconnected than ever, and led to high levels of uncertainty surrounding current and future contractual obligations. At a time when government policies fluctuate daily and courts and arbitration centers are becoming increasingly inaccessible to resolve active disputes, it is difficult for a party to seek or obtain interim measures or relief. From country to country and company to company, the responses have not been uniform: some commercial parties have continued to perform their obligations, while others have argued for wholesale abdication of their responsibilities, and still others are somewhere in between. Certain trends of government action and commercial response are emerging worldwide, no less so in the hyper-connected global businesses that are found in the Middle East.April 20, 2020
In these tough times, when clients are looking to protect assets and increase revenue, it is more important than ever to ensure that their arbitral awards are collectible. A truly successful outcome requires the ability to enforce and monetize the award that was won in the arbitration. When faced with a recalcitrant award debtor, it is imperative to think strategically and work closely with counsel and experts to enforce and identify recoverable assets.April 2, 2020
Eric Lewis focuses on three key areas: (1) the widening of the net from sanctioned individuals to their families; (2) the application of the evasion provisions to foreign persons; (3) the bringing of new classes within existing sanctions.The New York Law Journal, December 8, 2017
- For global transparency and financial integrity, the US must ensure that the dollar remains dominanthttp://www.independent.co.uk, October 31, 2017
- New York Law Journal; Law Firm Management Supplement Section page 8, May 8, 2017
- Statement on OFAC’S Removal of IIROSA Philippines and Indonesia from OFAC Specially Designated Nationals ListAugust 18, 2016
- December 10, 2015
- May 30, 2015
- "Eli Lilly Settlement Reinforces the Need for Active Anti-Corruption Controls"January 2, 2013
- November 29, 2012
- August 24, 2012
- August 16, 2012
- "Supreme Court Action Reinforces the Difficulty in Piercing Sovereign Immunities"June 26, 2012
- "U.S. Cracks Down on Foreign Evaders of Iran-Syria Sanctions"May 24, 2012
- "Regulators Turn Their Attention to FCPA Violations by Investment Advisers"May 23, 2012
- Annual Review - Financier WorldwideApril 2012
- "U.S. Appeals Court Bolsters U.S. Discovery In Aid Of Foreign Proceedings"March 19, 2012
- "Petrobras Wins Immunity in U.S. Bond Case"March 14, 2012
- House Financial Services Subcommittee on "Oversight and Investigations Hearing on Current and Evolving Trends in Terrorist Financing"September 28, 2010
- "Judge Griesa's Ruling in NML Capital: A U.S. Judge Wades Deep Into the Argentine Political System"April 2010
- "The El Paso Ruling and its Effect on the Use of §1782 in Private International Arbitration Proceedings"September 2009
- "The Impact of the Economic Downturn on the Direct and Reinsurance Markets: CDO's, Derivatives, Madoff and Beyond"June 16, 2009
- February 2009
- "Is Argentina the Next Hub of Money Laundering and What are the Consequences for International Business?"December 2008
- "What Can Madoff Investors do to Maximize the Recovery of Their Assets?"December 2008
- "Potential Implications of the Lehman Brothers Insolvency for Latin American Financial Institutions"
Authored by Eric L. Lewis, Manuel S. Varela and Cristían Francos.October 2008
- "The Availability of U.S. Discovery in Foreign Litigation: How Foreign Parties in Foreign Litigation can Obtain the Assistance of U.S. Courts"
Authored by Eric L. Lewis, Manuel S. Varela and Cristián Francos.October 2007
- "The Expanding Reach of United States Law: Extraterritorial Enforcement and Compliance Obligations of International Business"
Presented by Eric L. Lewis, Manuel S. Varela & Cristián Francos.August 2007
- "Good Judgments Travel Fast: Avoiding Pyrrhic Victories In International Litigation"
Presentation by Eric L. Lewis & A. Katherine Toomey.June 2003
- "Anti-Terrorism Legislation and its Impact on Commercial Law"
Eric L. Lewis, address to the Commercial Bar Association of England and Wales (COMBAR).March 31, 2003
- "Lawyer's Duties of Disclosure in Response to Commercial Fraud"
Eric L. Lewis delivered address at the Commercial Bar Association of England and Wales (COMBAR)June 7, 2002
In the News
The Times of London reported on the extradition hearing of Julian Assange, quoting senior partner Eric Lewis' expert testimony.The Times of London, September 15, 2020
Bloomberg reported on the extradition hearing of Julian Assange, quoting senior partner Eric Lewis' expert testimony.Bloomberg, September 15, 2020
Senior Partner Eric Lewis was quoted in AP on the extradition hearing of WikiLeaks founder Julian Assange.AP, September 14, 2020
- State Dept. declares Egypt’s ex-prime minister immune from torture lawsuit by U.S. citizen after reported protest from CairoThe Washington Post, July 17, 2020
- Foreign Policy, July 3, 2020
- The Independent, June 26, 2020
- AP, June 11, 2020
- Reuters, June 11, 2020
- Courthouse News Service, June 1, 2020
- Mohamed Soltan, U.S. citizen held as political prisoner, files torture lawsuit against Egypt’s ex-prime ministerThe Washington Post, June 1, 2020
- Commentary: A Veteran Litigator Looks Forward and Back as COVID-19 Stands to Remake the Practice of Law
'Looking forward from this improbable ninth week of shutdown, I believe that litigation is about to enter another sea change,' writes Eric Lewis, a senior partner at litigation boutique Lewis Baach Kaufmann Middlemiss.AmLaw Litigation Daily, May 21, 2020
- New York Law Journal, April 30, 2020
Lewis Baach Kaufmann Middlemiss PLLC is pleased to announce that three of its lawyers have been named to the 2020 Washington, DC Super Lawyers list. Each year, no more than five percent of the lawyers in each state are selected by the research team at Super Lawyers to receive this honor.April 17, 2020
The business of law is personal, and the human interaction cannot be fully replaced by technology, particularly for those that practice on an international scale. Lewis Baach senior partner Eric Lewis, who usually travels the globe to meet with clients, offers his personal take on how he and his firm are coping during the pandemic.Bloomberg Law, April 13, 2020
- Opinion: With this absurd acquittal, Mitch McConnell has emerged as the greatest enemy to Constitutional democracy since the Civil WarThe Independent, February 6, 2020
This article sets out the basic process for obtaining extradition to the United States and reviews certain recent cases that suggest that the United States is trying to leverage its political power to bring defendants to the United States either to fulfill political agendas or where the United States’ interest is tangential at best in view of the demonstrable interest of other countries.New York Law Journal, February 3, 2020
Six LBKM professionals have been selected to the 2019 New York and Washington, DC Super Lawyers lists - an honor limited to 5 percent of the lawyers in each state. In addition, one LBKM professional has been selected to the 2019 New York Rising Stars list.October 2019
Four Lewis Baach Kaufmann Middlemiss professionals have been recognized as Global Leaders in Who’s Who Legal: Asset Recovery 2019. Who’s Who Legal is one of the world’s leading directories of legal practitioners.October 2019
Bolton may be guilty of serious errors of judgment and defects of character. But he refused to play Trump's game — and now he might be the country's most valuable saviorThe Independent, October 15, 2019
Eric Lewis was quoted in The Washington Post on the allegations in the whistleblower complaint recently filed against President Trump.The Washington Post, September 23, 2019
Law360 asked Eric Lewis and other law firm leaders about the most common career blunders they see new attorneys make.Law360, August 6, 2019
Founding partner Eric Lewis was asked, as part of Law360's ongoing interview series, “What one trait is most important for a law firm partner?”Law360, July 16, 2019
- Lewis Baach Kaufmann Middlemiss Files Amended Lawsuit Against Trust Services Company Amicorp Alleging They Are Involved in a Multi-Million-Dollar Real Estate Investment Ponzi Scheme Fraud in South Florida
An amended complaint filed in Miami-Dade County alleges that Amicorp, an international trust services company, actively participated in a multi-million-dollar real estate fraud which victimized many Latin American families.www.businesswire.com, July 3, 2019
- Independent, May 28, 2019
- New York Law Journal, May 13, 2019
- Support for capital punishment is diminishing among the American public, but Trump’s Supreme Court shows no sign of abolishing executions, writes Eric LewisIndependent, May 6, 2019
Mr. Lewis reflecting on what he looks forward to each day in his job: "One of the things I like about our firm and a firm our size is the continuity and trust of the people I work with, most of whom I've worked with for a long time. I think all of us buy into the concept we have here, which is being very public spirited, very flexible, very supportive, and trying to use our skills not only on commercial matters but also trying to do some good as well.”Law360, November 28, 2018
- On a human level, it is a place of misery and despair. And on a larger level, it is a monument to the death of the rule of lawIndependent, November 2, 2018
Eric Lewis is quoted saying, “The ability to understand a case, price a case, look at a case honestly and evaluate its strengths and weaknesses becomes more important.”Law360, December 12, 2017
- Press Release: Woodsford Litigation Funding to provide international litigation boutique Lewis Baach Kaufmann Middlemiss PLLC with innovative $20m global portfolio financing facility
Woodsford Litigation Funding, one of the leading global third party funders, has announced a funding facility agreement with Lewis Baach which ensures the firm can offer clients an expedited, one-stop arrangement for the financing of high value litigation and arbitration.August 16, 2017
- The American Lawyer, August 16, 2017
"The ability to understand a case, price a case and look at a case honestly — to evaluate its strengths and weaknesses — becomes more important," said Eric Lewis of Lewis Baach Kaufmann Middlemiss PLLC. "I spend more time on strategy than I did 10 to 15 years ago. I spend more time talking to clients as cases go along."
Law360, August 15, 2017
Eric Lewis of Lewis Baach Kaufmann Middlemiss writes: Good lawyers don't get stuck in boxes. They are problem solvers who bring judgment and experience to their clients' issues, whoever those clients may be. They try to prevent economic interests from affecting their service to clients. They earn trust. Satisfaction in the law can be, and should be, measured in more than one way.New York Law Journal, May 8, 2017
- Eric Lewis Of Lewis Baach, On The Polarizing Legal Market, Internationalism, And White Collar Trends
As the market continues to pound out a separation between the niche players and the global elites, major legal consumers are increasingly turning to boutique firms for some of their more challenging work. Between their dexterity, fee flexibility, and, depending on the size of the boutique, deeper resources, we are seeing a growing interest in boutiques and niche firms in the legal market.Forbes, January 3, 2017
- Insiders 'Back on the Hook' After U.S. Supreme Court Insider Decision
For two years, stock traders and the attorneys who represent them said the law surrounding insider trading was a muddle, with no one knowing what exactly is or isn’t legal.
The U.S. Supreme Court Dec. 6 said it had ‘‘easily’’ settled the question (Salman v. United States, 2016 BL 404795, U.S., No. 15-628, 12/6/16).
‘‘Going forward, even remote tippees of inside information are at risk if the government can demonstrate that the defendant knew he was trading on inside information and the chain of disclosure is sufficiently close, even if no money changes hands.’’ Eric Lewis, Lewis Baach PLLCBloomberg BNA White Collar Crime Report, 2016
Both the speed and the unanimity of the decision sent a strong message re-affirming existing insider trading prosecutions, according to Eric Lewis, a partner at Lewis Baach, a Washington DC law firm specializing in financial crimes.
"It was somewhat surprising that the Supreme Court took this case," Lewis told ValueWalk, noting that it had been two decades since the high court took up an insider trading case.ValueWalk, December 6, 2016
Eric Lewis got a phone call from an old friend’s sister shortly after he wrote an op-ed in The New York Times in 2013 detailing his time playing under a high school football coach who was also a serial sexual predator.
That call ultimately led Lewis to take a turn this week as a journalist—a departure from his busy career as a prominent lawyer handling international fraud disputes, including representing Bernie Madoff’s investment firm in its liquidation—at his nearly 40-lawyer firm Lewis Baach in Washington, D.C.The American Lawyer, November 17, 2016
The Appellate Division, First Department, recently affirmed the dismissal of various claims brought by New Greenwich Litigation Trustee, successor to the claims of two feeder funds in the Bernard Madoff affair, against various third-party fund administrators, accountants and auditors.New York Law Journal, November 16, 2016
Mr. Lewis said that “there is no there there” on the allegations of any Saudi government role in the attacks, given the kingdom’s long history of being at war with Al Qaeda.
“The notion that senior Saudi officials or the Saudi government had an interest in supporting Sept. 11 and the attack on the World Trade Center is patently absurd,” he said.The New York Times, September 29, 2016
- Law360, May 19, 2016
- Law 360, March 30, 2016
- January 20, 2016
Fayez Al Kandari was released from Guantanamo today to the custody of the Government of Kuwait who transported him today to his home country of Kuwait.January 8, 2016
In March, the U.S. Treasury Department's Financial Crimes Enforcement Network imposed a corporate death sentence on Banca Privada d'Andorra by designating it as a foreign financial institution of primary money laundering concern under Section 311 of the USA PATRIOT Act.The FCPA Blog, December 15, 2015
- American Banker, November 18, 2015
- October 23, 2015
- Law360, October 1, 2015
- Eric Lewis says Donald Trump is giving credence to those who stigmatize America's Muslims. He says such rhetoric is hateful and dangerous.September 20, 2015
- Crime, Fear, and the Republicans: Can the GOP Interest in Criminal Justice Reform Survive Donald Trump?September 15, 2015
- Fayis al-Kandari has been held without charge for 14 years in US prison in Cuba, where he was allegedly tortured.Aljazeera, July 28, 2015
- Reuters, May 27, 2015
- New York Times, October 4, 2014
- IOL News, August 14, 2014
- Al Akhbar - English, August 14, 2014
- Une juge fédérale a ordonné un examen médical indépendant sur un détenu de Guantanamo nourri de force.RTL with AFP, August 14, 2014
- Interasksyon, August 14, 2014
- Yahoo Finance France, August 13, 2014
- Le Parisien, August 13, 2014
- Yahoo News, August 13, 2014
- Law360, August 12, 2014
- AP, July 25, 2014
- June 22, 2014
- Kathimerini, June 15, 2014
- The Litigation Daily, February 6, 2014
- January 30, 2014
- Negotiation with Mubarak regime officials accused of financial misappropriation should be viewed as being a piece of the greater asset-recovery puzzle.Al-Ahram Weekly, February 12, 2013
- September 13, 2012
- Insurance Day, April 12, 2012
- The Deal Pipeline, February 22, 2012
- The lawyer behind a $1 billion cross-border suit against Goldman Sachs following the sub-prime mortgage crisis praises the merits of bringing major commercial cases in the United States.February 3, 2012
- Washington lawyer Eric Lewis, who is acting for hedge fund Basis Capital in its $1 billion court action against Goldman Sachs over collateralised debt obligation deals in 2007, is used to playing a long game.The Australian, February 2, 2012
- New York Times, November 21, 2011
- November 2, 2011
- Saudi Firms Continue Multi-Billion Dollar Global Legal BattleMiddle East Economic Survey, October 31, 2011
- Huffington Post, October 28, 2011
- Saudi Arabia’s most high profile legal battle indicates just how dangerous the world’s capital markets remain a decade after Sept. 11, 2001.Trends Magazine, September 11, 2011
- The National, March 13, 2011
- The Washington Post, February 13, 2011
- Insurance Day, February 11, 2011
- One of the US's top fraud investigators is warning that America's policing of money laundering is wide open to abuse.BBC News, September 28, 2010
- Could U.S. banks be unknowingly financing terrorist operations? Disussion: Eric Lewis, an attorney, and Rick Nelson, of the Center for Strategic & International StudiesCNBC airtime 2:45 PM ET, September 28, 2010
- The Australian Financial Review, June 11, 2010
- Reuters, June 10, 2010
- An Australian hedge fund has launched a billion dollar lawsuit alleging Goldman Sachs knowingly sold it dud investments.ABC News, June 10, 2010
- Huffington Post, June 9, 2010
- Goldman Faces $1 Billion SuitBasis Capital Cites 'False Representations' in Collapsed CDO; Abacus Factor?Wall Street Journal, June 9, 2010
- Simmons, Withers and Linklaters Advise on $9.2bn Saudi Fraud CaseMultibillion-pound Saudi fraud case hands roles to raft of UK firmsLegalweek.com, January 20, 2010
- Yes, It Was Torture, and IllegalNew York Times, January 3, 2010
- Huffington Post, December 29, 2009
- Huffington Post, June 8, 2009
- Huffington Post, May 21, 2009
- The Lawyer, May 18, 2009
- Judge Rules Bagram Detainees Can Appeal to U.S. CourtsThe Washington Independent, April 3, 2009
- The Big Money from Slate, March 23, 2009
- In Torture Cases, Obama Toes Bush LineLegal Stance Appears to Contradict Earlier Statements From Obama and HolderThe Washington Independent, March 16, 2009
- In These Times, March 12, 2009
- Closing GuantánamoCQ Researcher, February 27, 2009
- Tort suits provide inadequate to challenge anti-terror policiesABA Journal, February 2009
- While others heard siren call, Lebanon's bank governor steered safely past tempation.Legal Times, December 15, 2008
- Black HoleThe U.S. detention center at Bagram in Afghanistan has earned a reputation as the new Gitmo - except that big-firm American lawyers aren't lining up to represent the inmates.Fall 2008
- Lawyers Consider Implications of Supreme Court Rulings Beyond GuantanamoLaw.com, June 16, 2008
- The United States has no right to re-educate Iraqi detainees in the ways of their faith.Legal Times, November 5, 2007
- The New GitmoLegal Times, October 29, 2007
- Judge Says U.S. Must Alert Lawyer on Detainee TransferLos Angeles Times, October 4, 2007
- Ex-Detainees Base Lawsuit On ReligionChicago Tribune, September 16, 2007
- Ex-Guantanamo Prisoners Want U.S. Lawsuit to ProceedReuters, September 14, 2007
- www.Slate.com, August 16, 2007
- Legal Business, March 2007
- State Department Official Resigns after Pro Bono AttackLegal Business, March 2007
- Former Detainees Allege Torture in U.S. CustodyUSA Today, October 28, 2004
- Alternative Dispute Resolution
- Complex Financial Disputes
- Disputas Internacionales
- Financial Crimes Compliance
- Government Relations and Legislative
- Internal Investigations
- International Asset Tracing and Investigation
- International Disputes
- International Insolvency
- Latin America
- Litigation Finance
- The Middle East
- White Collar Defense
- Yale Law School (J.D. 1983), Article and Book Review Editor of the Yale Law Journal
- Cambridge University (M. Phil., Fulbright Scholar, 1980)
- Princeton University (A.B. 1979)
- District of Columbia
- New York
- U.S. Supreme Court
- U.S. Court of Appeals for the Second, Fourth, Ninth, Eleventh and D.C. Circuits
- U.S. District Courts for the District of Columbia, the Southern District of New York, and the Eastern District of New York