We represented a manufacturer in the Dallas-Fort Worth area who was cited with more than 40 citations, including alleged willful violations of the Occupational Safety and Health Act. The proposed citation fines were in the six figures. We assisted the client with an aggressive campaign to identify flaws in the investigation methodology, especially in areas of noise conservation and respiratory protection, to present a firm defense at the informal conference. Our response also included the defense of vindictive prosecution by the government. The matter moved to contested proceedings and we obtained a favorable resolution after the hearing with the settlement judge.