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Paul Freeman

Partner
CONTACT
New York,Washington, DC
T:+1.212.634.3028
CAPABILITIES
PRACTICES
  • Governmental
  • Government Contracts
  • White Collar Defense and Investigations
  • False Claims Act
INDUSTRIES
  • Aerospace, Defense & Government Services
  • Energy and Infrastructure
  • Environmental
Paul Freeman

Overview

Paul Freeman brings nearly three decades of diverse experience advising clients across multiple sectors in strategic counseling, high-stakes enforcement actions and complex government investigations.  Paul’s focus on environmental defense, False Claims Act (FCA) driven investigations, and holistic risk management positions him as a trusted, strategic advisor to industrial corporations, manufacturers, federal contractors, and energy sector players confronting investigations by, or inquiries from, a range of regulators, primarily the U.S. Department of Justice (DOJ), U.S. Environmental Protection Agency (EPA), U.S. Department of Defense Inspector General (DODIG), and various U.S. Attorneys Offices and state attorneys general across the country.

Paul has successfully represented clients in cases driven by exposure under the Clean Water Act, Clean Air Act, CERCLA, Safe Drinking Water Act (SDWA), federal Renewable Fuel Standard (RFS) program, MARPOL Protocol, and, most recently, is leading clients through the rapidly evolving regulatory landscape and asymmetrical enforcement and litigation risks posed by per- and polyfluoroalkyl substances (PFAS). 

Extending his risk management and investigations practice across multiple industrial sectors, Paul also counsels Fortune 50 defense contractors on compliance with aspects of the Federal Acquisition Regulation (FAR), including the mandatory disclosure rule, and routinely conducts internal investigations involving supply chain risks, ethics, quality systems and quality nonconformances, contract compliance, and potential false claims.

  • PFAS Enforcement Defense: Lead counsel in multi-year negotiations with EPA and DOJ regarding alleged PFAS liabilities.
  • Novel Clean Air Act & Clean Water Act Defense: Defending a major agricultural producer in response to EPA and DOJ enforcement actions involving novel applications of the Clean Air Act and Clean Water Act.
  • FCA Investigation and Defense: Conducted internal investigation of federal whistleblower (qui tam) complaint alleging false certification of compliance with quality system controls, ultimately leading to success on the merits through a Motion for Summary Judgment. 
  • FCA Supplier Investigations: Conducted multiple investigations involving quality escapes and nonconformances originating in the aerospace supply chain, managing disclosure obligations and follow-on engagement with the DODIG, DOJ Civil Fraud Division, Defense Contract Audit Agency (DCAA), and other agencies.
  • Ballast Water & Maritime Compliance: Conducted internal investigation and managed complex reporting obligations for a fleet of oceangoing vessels regarding Ballast Water Treatment requirements promulgated by EPA and the U.S. Coast Guard.
  • Appellate RFS Victory: Challenged a precedential $70+ million EPA civil penalty involving Renewable Fuel Standard compliance, securing a pivotal stay from the U.S. Court of Appeals for the Sixth Circuit, leading to a highly favorable settlement.
  • Biodiesel Tax Credit Arbitration: Obtained a full recovery for a refined products marketer following a full arbitration hearing involving a dispute over federal biodiesel tax credit sharing.
  • MARPOL & Environmental Crimes: Defended series of ship owners and managers in civil and criminal investigations brought by the U.S. Coast Guard and the DOJ Environmental Crimes Section to enforce the MARPOL Protocol and the Act to Prevent Pollution from Ships (APPS) in federal districts across the country.
  • RFS Compliance: Represented a wide range of fuel suppliers, commodities traders, and other market participants in matters arising under the federal Renewable Fuel Standard (RFS) program, including the Quality Assurance Program (QAP), and related counterparty disputes.
  • Clean Water Act Defense: Conducted internal investigation and advised publicly traded waste disposal and treatment provider on disclosures to state permitting authority concerning employee misconduct posing civil and criminal exposure.

Clerkships
U.S. Environmental Protection Agency, Office of General Counsel, Summer Honors Clerk, 1997
Education

M.S.E.L., Vermont Law School, 2001, cum laude

J.D., Vermont Law School, 1998

B.A., St. Lawrence University, 1995, cum laude

Admissions

New York

Connecticut

District of Columbia

U.S. District Court for the Eastern District of New York

U.S. District Court for the Southern District of New York

U.S. District Court for the District of Connecticut

  • Zero-Emission Vehicle Transition For Federal Fleets: A Practical Discussion, National Law Journal, May 20, 2022
  • Achieving Biden's EJ Agenda, The Environmental Forum, May 12, 2021
  • What EPA Crackdown On Defeat Devices Means For Cos., Law360, January 26, 2021

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