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impending threat of death or serious bodily injury; that the defendant did not negligently or recklessly create a situation where he would be forced _ to engage in criminal conduct (e.g. had been making payments as part | i of an ongoing bribery scheme); that the defendant had no reasonable legal alternative to violating the law; and that there was a direct causal En d notes relationship between the criminal action and the avoidance of the threatened harm. See Eleventh Circuit Pattern Jury Instr., Special Instr. No. 16 (2003); see adso Fifth Circuit Pattern Jury Instr. No. 1.36 (2001); Sixth Circuit Pattern Jury Instr. No. 6.05 (2010); Seventh Circuit Pattern Jury Instr. No. 6.08 (1998); Ninth Circuit Pattern Jury Instr. No. 6.5 (2010); 1A Kevin F. O'Malley, Jay E. Grenig, Hon. William C. Lee, Federal Jury Practice and Instructions § 19.02 (6th ed. 2008 & Supp. (affirming criminal successor liability for Bank Secrecy Act violations); 2012). United States v. Polizzi, 500 E2d 856, 907 (9th Cir. 1974) (affirming 8. Rep. No. 95-114, at 11. criminal successor liability for conspiracy and Travel Act violations); 1 Td. at 10. United States v. Shields Rubber Corp., 732 F. Supp. 569, 571-72 (W.D. Id.at 11. Pa. 1989) (permitting criminal successor liability for customs violations); 13 United States v. Kozeny, 582 FE. Supp. 2d 535, 540 n.31 (S.D.NY. see also United States v. Mobile Materials, Inc., 776 F.2d 1476, 1477 (10th 2008). Cir. 1985) (allowing criminal post-dissolution liability for antitrust, mail "4 Kozeny, 582 F, Supp. 2d at 540 (citing S. Rep. No. 95-114, at 10-11). fraud, and false statement violations);. 5 Td, 185) Complaint, SEC v. The Titan Corp., No. 05-cv-411 (D.D.C. Mar. 1, '%6 These payments, however, must be accurately reflected in the 2005) (discovery of FCPA violations during pre-acquisition due diligence company’s books and records so that the company and its management protected potential acquiring company and led to termination o

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