Article | June 30, 2026
FCPA Enforcement: Where the Bribery Actually Happened
FCPA enforcement trends analyzed by geography. Discover where bribery risk is concentrated and how it impacts global compliance, investigations and risk management.
December 9, 2024
Neil Gaudion provided an expert report and testimony on behalf of Five Star Resort Owner, LLC, in construction dispute litigation surrounding a $2 billion Ritz-Carlton Hotel development. The jury awarded $2 million, plus interest, an amount determined from Mr. Gaudion’s testimony.
In 2021, Scottsdale-based Five Star Resort Owner LLC (“Five Star”) selected PWI Construction Inc. (“PWI”), a Las Vegas-based general contractor, to lead the construction of the Ritz-Carlton Hotel and Villas, a luxurious project in Paradise Valley with an estimated value of $2 billion. However, in August and September 2021, PWI terminated its contracts with Five Star and filed $7 million in liens, alleging missed payments, lost profits, and other damages. Five Star subsequently filed suit for breach of contract against PWI.
Neil Gaudion, Managing Director at Secretariat, was retained by Stein Ray LLP on behalf of Five Star to provide expert analysis and testimony regarding construction damages. He quantified Five Star’s additional costs incurred due to PWI, reviewed PWI’s unpaid invoices and supporting records, then opined on the amounts owed to PWI.
Mr. Gaudion provided testimony and was cross-examined in a two-week jury trial in Phoenix, Arizona in October 2024. The jury agreed with Mr. Gaudion’s testimony, awarding Five Star the full amount Neil Gaudion calculated—$2 million, plus interest—and rejecting the vast majority of PWI’s counterclaims.
FCPA Enforcement: Where the Bribery Actually Happened
FCPA enforcement trends analyzed by geography. Discover where bribery risk is concentrated and how it impacts global compliance, investigations and risk management.
Secretariat is pleased to share that 56 of our experts have been recognized in the Lexology Index 2026 Construction report for their outstanding work on complex construction disputes and claims around the world. With 12 experts named as Global Elite Thought Leaders—the report’s most exclusive ranking, achieved by only 5% of listed professionals—Secretariat has earned the No. 1 spot in this category for the second year in a row among more than 750 ranked firms.
Eric Poer, a Managing Director in Secretariat’s Global Investigations & Disputes practice, was retained by the U.S. Securities and Exchange Commission (SEC) to serve as their forensic accounting expert in a high-profile securities fraud dispute.