Grant R. MacQueen is an Associate at Morgan, Lewis & Bockius LLP. The views expressed in this article are the authors’ own, and are not necessarily those of Morgan, Lewis & Bockius LLP or Phillips Nizer LLP. The authors thank the Hon. Denis R. Hurley, Jennifer Hurley McGay, and Michael S. Kraut for their thoughtful and constructive input. Any errors are solely the responsibility of the authors.

Written by Grant R. MacQueen