As part of its investigation into allegations raised in qui tam suits under the False Claims Act ("FCA"), the government tried to interview several Amgen employees without an Amgen attorney present. Amgen argued that this was a violation of the "no-contact" attorney-conduct rule, which generally prohibits an attorney representing a client from communicating about the subject of the representation with a party that the attorney knows to be represented by another attorney in the matter, unless the attorney has the consent of the other attorney or the communication is authorized by law or court order. On June 10, 2011, Judge Sandra L. Townes in the Eastern District of New York adopted the Report and Recommendation of Magistrate Judge James Orenstein in its entirety and agreed that the court did not have "supervisory authority over the conduct of an investigation … that may never result in the government filing an action ." The Report and Recommendation further stated that the "no-contact" rule "governs the behavior of individuals who practice law" and does not constrain the rights of the government or establish rights for an adversary. Consistent with many jurisdictions, the court held that the no-contact rule applies "only to matters that fall literally within its scope" and relied heavily on narrow definitions of the key terms "party" and "matter."