Your law firm has been recently been retained by Emory Holdings, Inc. ("Emory"), a manufacturing conglomerate that is incorporated in the state of Delaware but has its principal place of business in Columbus, Ohio. As part of your recent work, you helped Emory acquire Jackson & Carter LLC ("J&C"). J&C is a Georgia limited liability company with its principal place of business in Atlanta, GA. J&C manufactures kegs that are sold to craft breweries around the state of Georgia as well as around the country.

Today, you received this email from the regional vice president of Emory who oversees operations and performance of J&C, among other manufacturing companies across the southeast states:

The second letter was from Peachtree Brewing - the fastest growing independent craft beer company in the state of Georgia. Peachtree Brewing claims that J&C, through its sales representative, promised a shipment of fifty kegs to be delivered and installed at its brewery to compensate for the growing demands of the company. Peachtree has paid $10,000 to J&C with the expectation that the kegs would have been delivered ten days ago. As a result, Peachtree claims that they have lost $20,000 in potential profits. They also claim that they have had to throw out $25,000 worth of their new peach IPA beer because they do not have enough kegs to keep it. Peachtree claims that they do not receive a refund as well as compensation for their loss, they will sue J&C for breach of contract.

Beyond these concerns, Mr. McIntosh just let me know (he claims it "slipped his mind" when we acquired J&C) that the company is in the midst of an active investigation by the Environmental Protection Agency regarding toxic emissions and waste dumping that may result in civil and possibly even criminal sanctions. The EPA is sending an investigator next week before the Thanksgiving holiday, and Mr. McIntosh is thinking about closing operations for the entire week in the hopes that the EPA investigator will reschedule the on-site inspection. Mr. McIntosh is afraid - because of the possibility of criminal sanctions - that he may have to go to jail.

Suggest a recommendations to her promptly and completely. Keep in mind that it is clear that Jackson & Carter LLC is suffering from lapse in ethical judgment and probably needs some guidance there as well.