Christopher D. Carusone

Government Law and Regulatory Affairs

• Successfully represented an international, online tobacco retailer during an investigation conducted by the Pennsylvania Attorney General’s Office into alleged violations of the Unfair Trade Practices and Consumer Protection Law (UTCPL), convincing the government to drop the investigation.
• Represented a national medical data company as local Pennsylvania counsel during an investigation conducted by numerous state attorneys general into a data breach, assisting the company in meeting its requirements under the Pennsylvania Breach of Personal Information Notification Act.
• Successfully represented a major health insurance company in a bid protest and lawsuit against the Pennsylvania Department of Human Services challenging rejection of the company’s Medicaid proposal, successfully convincing the Department to reissue the solicitation.
• Successfully represented a medical marijuana dispensary in an appeal with the Department of Health over the denial of its application for a grower/processor permit, resulting in the creation of one of the few vertically-integrated medical marijuana companies permitted to operate in Pennsylvania.
• Successfully represented a large landscaping company during enforcement proceedings brought by the Federal Motor Carrier Safety Administration (FMCSA), Pennsylvania Department of Transportation, and Pennsylvania State Police, convincing them to rescind an out-of-service order and restore operations to the company’s fleet of motor carriers.
• Successfully represented a construction company fined by the FMCSA for a violation of federal motor carrier safety regulations detected during an onsite compliance review, convincing the government to reduce the fine in exchange for improvements to the company’s safety program.
• Successfully represented the Association of Independent Colleges and Universities of Pennsylvania (AICUP) as amicus curiae in the Pennsylvania Supreme Court on an issue of first impression involving the duty of health care owed to injured student-athletes on intercollegiate sports teams.
• Successfully represented a non-profit corporation accused of violating the conditions of an educational grant program administered by the Pennsylvania Department of Labor and Industry and the federal Corporation for National and Community Service, convincing the government to restore funding to the organization.
• Represented a corporation operating nursing homes throughout Pennsylvania in a Pennsylvania State Police investigation into a theft allegedly committed by a former employee.
• Defended an information technology staffing company working as a subcontractor to the Pennsylvania Department of Transportation accused of breach of contract, successfully convincing the court to deny a motion for a preliminary injunction that would have severely affected the company’s business.
• Drafted legislation for a statewide housing association regarding the use of assistance animals and service animals in rental housing, which was subsequently enacted into law.
• Successfully represented a Pennsylvania executive agency as outside counsel during an investigation conducted by the United States Department of Justice, Civil Rights Division, which later declined to take legal enforcement action.
• Successfully represented a Pennsylvania agency as outside counsel in an investigation conducted by the Philadelphia District Attorney’s Office, convincing the District Attorney that the Department’s employees were not culpable in criminal wrongdoing.
• Represented a tobacco shop in an enforcement action brought by the Pennsylvania Department of Health alleging violations of the Clean Indoor Air Act, convincing the Department to postpone suspension of the company’s privilege to permit indoor smoking pending the outcome of its renewal application.
• Defended a highway construction company against a complaint of racial discrimination lodged by a former employee, convincing the Pennsylvania Human Relations Commission to dismiss the complaint as meritless.
• Successfully represented a Magisterial District Judge in the Court of Judicial Discipline against disciplinary charges filed by the Judicial Conduct Board, convincing them – for only the second time in Pennsylvania history – to place the client into the Judicial Diversion Program for first-time judicial offenders.
• Successfully represented a landlord during a criminal investigation conducted by the Environmental Protection Agency (EPA) and the United States Attorney’s Office into an alleged violation of lead paint regulations, convincing the government that prosecution was not warranted.
• Successfully represented an endocrinologist in proceedings before the State Board of Osteopathic Medicine, convincing the Pennsylvania Department of State, Bureau of Professional and Occupational Affairs, to dismiss the complaint.
• Successfully represented a casino operator in an investigation conducted by the Federal Bureau of Investigation and United States Attorneys Office, convincing the government that the client was innocent of any criminal wrongdoing.
• Advised the general counsel of a national laboratory regulated by the Pennsylvania Department of Environmental Protection with regard to the parameters of the Pennsylvania Public Official and Employee Ethics Act.
• Successfully represented a career gambler accused of cheating at a casino licensed by the Pennsylvania Gaming Control Board, persuading the Board to reduce the amount of time the client was required to spend on the statewide casino exclusion list.
• Successfully represented a lobbyist during a high profile criminal investigation conducted by the Dauphin County District Attorney’s Office, resulting in a Grand Jury Report that protected the lobbyist’s identity as a witness.

Internal Investigations

• Supervise an investigative team that regularly conducts Title IX investigations for public and private colleges and universities in Pennsylvania and Maryland into allegations of sexual misconduct by students and faculty, employing a unique model that utilizes former prosecutors and police officers.
• Conducted an internal investigation for an international consumer packaged goods company into hiring, promotional, and disciplinary practices in order to determine whether it was discriminating against employees on the basis of age and/or race, which included a statistical analysis and verbal presentation to senior management
• Conducted an internal investigation for a public university in New Jersey into allegations of favoritism in the bidding of construction contracts, resulting in a confidential written report.
• Conducted a large, multi-state internal investigation for a company under investigation by the United States Attorney’s Office and three state attorneys general into allegations of improper billing.
• Conducted an internal investigation of the domestic business unit of an international company into allegations of misuse of company vehicles.

Energy and Utilities

• Represented an established petroleum industry trade organization in a lawsuit against the Pennsylvania Environmental Quality Board, which was resolved by new legislation resulting in the rescission of new proposed regulations that would have drastically increased the costs of conventional oil and natural gas well development.
• Served as co-counsel with an environmental law firm in the representation of a pipeline company during an investigation by the Pennsylvania Public Utility Commission (PUC), advising the client on how to avoid criminal liability.
• Drafted proposed legislation for a large, publicly-traded natural gas company to modernize and streamline the environmental permitting process in Pennsylvania.
• Revised an internal policy for a large, regional oil and natural gas producer regarding its workplace hazard identification and incident reporting procedures required under federal regulations promulgated by the Occupational Safety and Health Administration (OSHA).
• Drafted formal comments to the EPA on behalf of a petroleum industry trade organization regarding final effluent limitations guidelines and standards for oil and natural gas extraction point sources.
• Drafted formal comments to the Pennsylvania Department of Environmental Protection (DEP) on behalf of a petroleum industry trade organization regarding changes to DEP’s advisory committee guidelines and policies for the development and review of its regulations.
• Represented a national, privately-held energy exploration company required to produce documents as part of an investigation of a state employee conducted by the Pennsylvania State Ethics Commission.
• Participated in the successful representation of a Fortune 10 energy company during a civil investigation of energy industry practices conducted by the Pennsylvania Attorney General’s Office, Bureau of Consumer Protection and Antitrust Section.
• Advised a large energy trade association on the requirements of the Pennsylvania Public Official and Employee Ethics Act enforced by the State Ethics Commission.
• Advised three mid-sized energy trade associations in the formation of a joint non-profit corporation to address issues related to the proper disposal of wastewater produced during conventional oil and natural gas production operations.
• As government counsel, represented the Attorney General in an argument before the Pennsylvania Supreme Court in a seminal environmental appeal, successfully securing reversal of an adverse decision of the Commonwealth Court and seventeen years of unfavorable precedent governing the constitutional obligation to preserve evidence.