Carole S. Rendon

Experience

In her 30-year career, Carole has been involved in nearly every type of criminal, civil and regulatory investigation, in many circumstances with experience serving as counsel on different sides. Representative matters and areas of experience include:

Criminal Litigation and False Claims Act

• Representing a manufacturer in connection with an ongoing EPA investigation being conducted by two U.S. Attorney’s Offices and the DOJ Environment and Natural Resources Division.
• Representing a client in an ongoing companion civil and criminal False Claims Act investigation being conducted by the U.S. Attorney’s Office for the Southern District of Ohio.
• Representing a leading healthcare system in connection with a Civil Investigative Demand issued by the DOJ pursuant to the False Claims Act.
• Representing a post-acute healthcare provider in connection with a Civil Investigative Demand issued by the DOJ.
• Lead counsel on the investigation and prosecution of Suarez Corporation Industries, Chief Executive Officer Benjamin Suarez and Chief Financial Officer Michael Giorgio for violations of the campaign finance laws and obstruction of justice.
• Represented the largest American manufacturer and distributor of explosives in two separate matters involving criminal investigations regarding the company’s federally mandated record keeping.
• Lead defense counsel in a case charging false statements in the context of a submission to the SEC in response to a Wells notice. Following extensive briefing and a contested hearing, the judge dismissed the indictment in its entirety on statute of limitations grounds.
• Co-counsel defending a former Cuyahoga County probation officer charged with multiple counts of kidnapping, gross sexual imposition and related offenses.

Internal Investigations

• Retained by the City of Beachwood to conduct an investigation regarding alleged sexual misconduct by the city’s mayor.
• Represent a world-renowned academic hospital in an internal investigation related to an executive’s misconduct.
• Represent a manufacturer of FDA registered products in connection with a whistleblower complaint regarding alleged OSHA and related safety violations.
• Represent a financial services company in a matter involving an employee’s fraudulent misconduct and its impact on their customers.
• Represented a global chemical manufacturer and its subsidiary in connection with a criminal embezzlement investigation involving alleged theft of trade secrets.

Commercial Litigation

• Representing a national pharmaceutical company in the opioid MDL and related litigation in multiple jurisdictions. Serve as liaison counsel for all manufacturing defendants in the opioid MDL.
• Representing a leading financial services company in connection with parallel DOJ and SEC investigations.
• Defended a major insurance company in a consumer class action involving insurance rates.

Securities Enforcement and Litigation

• Representing a multinational materials manufacturer in a shareholder derivative action in the U.S. District Court for the Northern District of Ohio.
• Representing an executive of an American retailer in a securities class action in the U.S. District Court for the Southern District of Ohio.

FCPA

• Represented an executive in the DOJ’s FCPA investigation of Rolls-Royce and its employees. Obtained an almost unheard-of sentence of probation for our client, who was prosecuted for paying significant bribes to foreign officials under the FCPA.
• In conjunction with the Fraud Section of the Criminal Division of the Department of Justice and the SEC, served as lead counsel for the U.S. Attorney’s Office on an FCPA investigation in which the target company entered into a Deferred Prosecution Agreement, paid $25 million in fines and agreed to a monitorship to resolve its FCPA violations.
• Represented the controller of a target company in an FCPA investigation.

Cybersecurity

• Oversaw the formation of the Northeast Ohio Cyber Security Consortium, a unique, regional cross-sector information-sharing organization that combines leading private sector institutions, public entities and federal law enforcement in a joint effort to identify and mitigate ongoing cyber threats. Planned the kickoff conference to announce the consortium’s creation, at which the FBI Director was a keynote speaker.
• Oversaw nearly a dozen national and international cyber prosecutions.

Civil Rights

• As lead counsel for the United States Attorney’s Office, in partnership with the Civil Rights Division of the Department of Justice, engaged in an extensive investigation of the excessive use of force by the Cleveland Division of Police, and negotiated a consent decree with the City of Cleveland for comprehensive reform of the Cleveland Division of Police.
• As lead counsel for the United States Attorney’s Office, in partnership with the Voting Rights Section of the Civil Rights Division of the Department of Justice, negotiated a consent decree with the Cuyahoga County Board of Elections requiring the adoption of bilingual ballots, bringing Cuyahoga County into compliance with the Voting Rights Act. Assisted in the negotiation of a similar agreement with the Lorain County Board of Elections the following year.

Higher Education

• Advise a nationally renowned university regarding its disciplinary and Title IX practices.
• Conduct Title IX investigations for a nationally renowned university and represent the university in resulting lawsuits.
• Serve as counsel to a private university in relation to third-party criminal acts, assessing and advising the client on risks and potential exposure to liability.
• Assisting a private university in response to a series of government investigations involving a professor who is alleged to have participated in China’s Thousand Talents Plan.

Testimony

• Testimony before the Senate Committee on Homeland Security and Government Affairs Hearing titled “Examining the Impact of the Opioid Epidemic,” April 22, 2016.
• Appearance with City of Cleveland Law Director Barbara Langhenry before the Cleveland City Council on the Consent Decree for comprehensive reform of the Cleveland Division of Police, June 3, 2015.
• Testimony before the Ohio Civil Rights Commission on Human Trafficking, June 5, 2013.

Memberships

• Sixth Circuit Judicial Conference: Life Member
• Litigation Counsel of America: Senior Fellow
• Women's White Collar Defense Association
• National Association of Former United States Attorneys
• ATIXA-certified Title IX Investigator 
• Federal Bar Association: Board of Directors (2017 to 2019)
• American Bar Association (1998 to Present)
• Cleveland Metropolitan Bar Association (1998 to Present)
  • White Collar Crime Institute: Co-Chair (2018)
  • Trustee (2005 to 2008 and 2013 to 2017)
  • 3Rs Program (2006 to 2017)
  • Membership Committee (2013 to 2015)
  • Citizens’ Legal Academy: Co-Chair (2012 to 2013)
  • Minority Clerkship Committee (2007 to 2009)
  • Women in the Law Section: Chair (2007 to 2008)
  • Trustee (2005 to 2008, 2013 to 2017)
  • Criminal Law Section: Chair (2005 to 2006)
• Cleveland Metropolitan Bar Foundation: Fellow (2005 to Present)
• John M. Manos Inn of Court: Barrister (2000 to Present)
• Eighth District Judicial Conference
  • Life Member
  • Co-Chair (2018)
  • Delegate (2007 to 2010)
• Federal Public Defender Reappointment Review Committee (2019)
• Federal Magistrate Judge for the Northern District of Ohio: Selection Panel (2016)
• Toledo Women’s Bar Association (2011 to 2014)
• Cleveland Marshall College of Law: Visiting Advisory Committee (2008 to 2011)
• Litigation Associates of America (2008 to 2010)
• Federal Defender for the Northern District of Ohio: Selection Panel (2007)
• National Association of Criminal Defense Lawyers (2005 to 2009)

Community

• Orchard Elementary School: Tutor (2017 to 2020)
• Memorial Elementary School: Tutor (2012 to 2017)
• American Diabetes Association, Northeast Ohio Chapter Board of Directors (2020 to Present)
• Cuyahoga County Justice System Reform Project
  • Member (2005 to 2010)
  • Community Council: Chair (2007 to 2009)
• Park Synagogue
  • Board of Directors (2019 to Present)
  • Education Committee (2000 to 2003)
  • Mitzvah Day Committee (2000 to 2003)
  • Mitzvah Day Site Coordinator (2000 to 2019)
• Trinity Cathedral Sunday Lunch Ministry: Team Captain (1999 to 2012)
• Pardes High School Board of Trustees: Vice President (1999 to 2000)
• Cleveland Municipal School System: Mock Trial Volunteer
• Case Western Reserve University School of Law: First Amendment Advisory Board

Pro Bono

• As an appointed member of the Criminal Justice Act (CJA) Panel for the Northern District of Ohio, represent indigent defendants in criminal cases in federal district court.