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(American Bar Association rules go a step further and forbid lawyers from working behind the scenes unless they get a waiver.) Michael Felberbaum, an FDA spokesman, said in an email, There are nuances to the post employment rules that require careful analysis depending upon the specific factual circumstances. For example, Fraser, who defended pharmaceutical companies before joining the FDAs chief counsels office, began representing e-cigarette makers less than two years after leaving the FDA

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