David Lapin and his team from Applied Business Ethics, Inc. [sic] (ABEI) [SBE was formerly known as Applied Business Ethics International] were engaged to assist with the re-writing of the labor and immigration code and restructuring of the Department of Labor and Immigration.  It is my recollection that they were hired because of their prior experience with multi-cultural environments like the CNMI.  I specifically recall attending a week long conference run by Mr. Lapin dealing with the cultural issues involved in labor and immigration reform.  The purpose of the conference was to help identify ways to streamline the guest worker system (approval of entry and resolution of disputes between guest workers and their employers) and to remove from the system those procedural elements which could be abused (i.e. graft).  In short, ABEI was hired to address real or perceived problems with CNMI labor and immigration raised by Rep. George Miller and the Washington Post.

...

It is my understanding through recent press articles (New York Times) that the current Attorney General Pam Brown has stated that she has no knowledge of ABEI or David Lapin's work.  This is understandable since General Brown was not working for the administration at the time.  My recollection is she was either counsel for the CNMI Senate, which was not a friendly body to the Froilan Tenorio administration or in a private law practice which included numerous suits against the Froilan Tenorio administration; specifically his efforts to reorganize the government.  Notably, Froilan Tenorio, who initiated the agreements with ABEI, is currently running against Juan Babauta for Governor.  General Brown was appointed by Governor Babauta.

While General Brown would have no first hand knowledge of the work of ABEI or David Lapin, I would be very surprised to learn that she did not know of the administration's efforts to address accusations of labor and immigration abuse and specifically that a new labor and immigration code had been drafted and introduced in the legislature.  It was widely reported in local papers and, if she were Senate Counsel, would presumable [sic] be aware of its introduction as a bill."