Agreed. You cannot necessarily rely upon any specific law, regulation or rule to constrain NWBO management.
The only debate is whether NWBO management is justified in getting around laws, regulations and rules and perhaps whether those laws, regulations and rules are reasonable but not whether they have proven willing and able to skirt them when it suits their purpose.
I dont want to nick pick but a lawyer only stays a lawyer when one keeps practicing the law by which among others is following mandatory courses and schooling. In the Netherlands, a lawyer must also be practice a certain amount in court per year, Im pretty sure the same lawyer rules apply in most states. Im sure LP did not have time to do all of that the last 10 years so than at a certain point gets disembarked from whatever state bar association she use to be registered with.
And the same law (42 CFR Part 11) also required NWBO to update the actual patient counts, completion dates and endpoints long ago
can't argue with that its very careless and unfortunate. Together with NWBO's website from 1983.