AREA OF PRACTICE

Practice Group Leader, White Collar Defense & Government Investigations

Biography

Stephen Cook is a partner and Practice Group Leader of Brown Rudnick's White Collar Defense & Government Investigation practice group. He is a former federal prosecutor and experienced trial lawyer who advises corporate and individual clients on complex civil and criminal matters, internal corporate investigations, grand jury investigations, and regulatory compliance matters. Steve has advised senior management and business owners facing civil, criminal and regulatory challenges in the health care, technology, energy, financial services, pharmaceutical, gaming, advertising, and alcoholic beverage industries, among others. He regularly represents clients in FCPA and corruption-related investigations, pre- and post-acquisition due diligence, and works with clients to evaluate, design and implement anti-corruption compliance programs.

As an Assistant US Attorney in the Southern District of California, Steve investigated and prosecuted numerous cases to verdict in federal court covering a range of issues, including cyber fraud, money laundering, human and narcotics trafficking, and national security-related offenses. Steve was also a member of the FBI's Joint Terrorism Task Force, responsible for investigating and prosecuting threats of terrorist activity and terror financing networks.

Representation

Representative Criminal, Regulatory and Anti-Corruption Work

Lead trial counsel for PCAOB inspections leader in widely-publicized PCAOB-KPMG leaks criminal jury trial in the Southern District of New York.

Successfully defended world-renowned engineer in World Bank investigation in connection with development project in India.

Obtained acquittal for US Marine charged with murdering an Iraqi soldier while serving in Fallujah, Iraq in a general court martial that received global media attention.

Currently acting as counsel for various health care practitioners charged with health care fraud in the Southern, Central and Northern Districts of California.

Conducted sensitive internal investigation into allegations of financial misconduct by senior officers and board members of publicly traded energy company.

Conducted internal investigation on behalf of global document management company into allegations of fraud at an Indian affiliate in connection with pre-acquisition due diligence.

Conducted internal investigation into potential employee manipulation of trans-border freight shipments to facilitate narcotics trafficking.

Represented management employee of global beverage manufacturer in connection with bribery investigation in India.

Represented companies and individuals in connection with corruption investigations and acquisition due diligence in countries around the world, including India, China, Mexico, Brazil, Colombia and Azerbaijan.

Represented a fund trustee of a global investment management firm in connection with an SEC investigation into the firm’s valuation of exchange traded funds; no enforcement action was taken against the client.

Achieved favorable resolution of an FDA enforcement action against a dietary supplement manufacturer alleging adulteration of nutraceuticals.

Successfully represented professional sports agent in connection with an FBI/USAO criminal investigation into allegations of forgery and bank fraud. No enforcement action was taken against the client.

Represented a national janitorial services company in connection with an HSI/USAO criminal investigation into employee hiring practices.

Represented a national medical supply company in connection with an FBI/USAO criminal investigation and a civil qui tam action alleging Medicare fraud and violations of the False Claims Act.

Favorably resolved parallel civil and criminal cases against an online affiliate marketer involving allegations of fraudulent internet marketing practices.

Representative Civil Matters

Successfully defended hedge fund CFO against allegations of fraudulent misrepresentations concerning the fund’s investment products.

Defended and obtained a favorable settlement on behalf of a business valuation and investment banking firm in a class action alleging fraudulent misrepresentations in the firm’s sales presentations.

Successfully challenged adoption and implementation of a large water rate increase by a California municipality as a violation of the California Constitution.

Managed two-year investigation on behalf of an alcoholic beverage manufacturer into suspected fraudulent activities by wholesale distributors.

Successfully defended an alcoholic beverage manufacturer against claims that its distribution agreement violated the Sherman Act by prohibiting public ownership of wholesalers.

Favorably resolved action against a multinational food company by its primary competitor alleging theft of product packaging trade secrets.

Successfully resolved attorney malpractice claims against two national law firms in connection with allegedly negligent real estate and business transactional advice.

Defeated breach of contract claim on summary judgment against an alcoholic beverage manufacturer in a dispute relating to the purchase of aluminum can-sheet.

Pro Bono

Represented foster children and at-risk youth in proceedings before California juvenile courts and school district disciplinary boards.

Supervised investigation of claims to US citizenship by prison inmates facing deportation.

Negotiated successful resolution of PTSD discrimination claim on behalf of Iraq war veteran.

Education

American University, Washington College of Law – J.D., cum laude, 1999
Brigham Young University – B.A., 1995

Bar Admissions

California
District of Columbia
Publications
Co-author, “PPP Borrowers: 5 Ways to Mitigate the Risk of an Unfavorable SBA Audit or Enforcement Action," Financial Executives International (July 2020)
Co-author, "Prosecutors Should Be Wary Of Overreach After Marinello," Law 360, March 30, 2018.
Author, "Tough Love in the District: Management Reform Under the District of Columbia Financial Responsibility and Management Assistance Act," American University Law Review Vol. 47, No. 4 (Feb. 1998)