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"Kissing the ring"? They want his test documents, not his fealty.

They want his compliance, or his $21k/day. The document is all stick and no carrot. And it is a big, federal regulatory agency stick. I think "kissing the ring" applies.

You also they often have very common procedures for these types of letters, right? Usually brought on by court cases, etc. For example:

http://www.fda.gov/ICECI/ComplianceManuals/RegulatoryProcedu...

They also generally warn of fines ahead of time, because otherwise they get people arguing due process.

Seriously, this is not that uncommon. Note the fine warnings in all of these special orders:

http://www.documentcloud.org/documents/1349845-n-h-t-s-a-spe...

https://www.google.com/url?sa=t&rct=j&q=&esrc=s&source=web&c...

http://www.safercar.gov/staticfiles/safercar/recalls/Special...

http://www.autosafety.org/sites/default/files/imce_staff_upl...

etc

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