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April 2008 the published BofA Outside Counsel Procedures. Obstructionist conduct by outside counsel is strictly prohibited. Outside Counsel is not allowed to appear unless authorized by BAC office of the General Counsel, and Outside Counsel is required to report per Sarbanes Oxley Act (2002) section 307. Bryan Cave, LLP, and the former CFC Legal Department, headed by Sandor Samuels were exempted from all such procedures starting December 11, 2008, under Bryan Moynihan. Therefore, the published Outside Couns
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