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746 KB
Extraction Summary
7
People
4
Organizations
5
Locations
1
Events
0
Relationships
6
Quotes
Document Information
Type:
Legal document
File Size:
746 KB
Summary
This legal document, filed on February 4, 2021, argues that the court has the inherent authority to suppress evidence obtained through the government's misrepresentation. It cites multiple legal precedents to establish that this power is not limited to misconduct within the immediate courtroom but can extend to related actions in other proceedings. The core argument is that the government's deception was essential to obtaining the factual basis for certain counts, and therefore, the resulting evidence should be suppressed.
People (7)
| Name | Role | Context |
|---|---|---|
| Cortina |
Party in the case United States v. Cortina, cited as legal precedent.
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| Lambus |
Party in the case United States v. Lambus, cited as legal precedent.
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| Benkovitch |
Party in the case Benkovitch v. Gorilla, Inc., cited as legal precedent.
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| Chambers |
Party in the case Chambers v. NASCO, Inc., cited as legal precedent.
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| Klein |
Party in the case Klein v. Weidner, cited as legal precedent.
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| Weidner |
Party in the case Klein v. Weidner, cited as legal precedent.
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| Yun |
Party in the case Manhattan Review LLC v. Yun, cited as legal precedent.
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Organizations (4)
| Name | Type | Context |
|---|---|---|
| United States | government agency |
Referred to as "the government" and as a party in several cited cases (e.g., United States v. Cortina).
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| Gorilla, Inc. | company |
Party in the case Benkovitch v. Gorilla, Inc., cited as legal precedent.
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| NASCO, Inc. | company |
Party in the case Chambers v. NASCO, Inc., cited as legal precedent.
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| Manhattan Review LLC | company |
Party in the case Manhattan Review LLC v. Yun, cited as legal precedent.
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Timeline (1 events)
2021-02-04
A legal document (Document 134) was filed in case 1:20-cr-00330-AJN, arguing that the court has inherent authority to suppress evidence due to government misrepresentation.
Locations (5)
| Location | Context |
|---|---|
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Jurisdiction for the United States v. Cortina case citation.
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Jurisdiction for the United States v. Lambus case citation.
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District of New Jersey, jurisdiction for the Benkovitch v. Gorilla, Inc. case citation.
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Eastern District of Pennsylvania, jurisdiction for the Klein v. Weidner case citation.
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Southern District of New York, jurisdiction for the Manhattan Review LLC v. Yun case citation.
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Key Quotes (6)
"The court has inherent authority to regulate the administration of criminal justice among the parties before the bar . . . [by] exclud[ing] evidence taken from the defendant by willful disobedience of law."Source
— United States v. Cortina, 630 F.3d 1207, 1214 (7th Cir. 1980)
(Cited as precedent to support the court's authority to suppress evidence.)
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Quote #1
"It is within the court’s inherent authority to suppress evidence gathered unlawfully in order to maintain the integrity of its own proceedings . . . ."Source
— United States v. Lambus, 897 F.3d 368, 386 (2d Cir. 2018)
(Cited as precedent to support the court's authority to suppress evidence.)
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Quote #2
"District courts have ‘inherent authority’ to impose a variety of sanctions, including . . . suppression of evidence . . . ."Source
— Benkovitch v. Gorilla, Inc., No. 2:15-cv-7806 (WJM), 2017 WL 4005452, at *2 (D.N.J. Sept. 12, 2017)
(Cited as precedent to support the court's authority to suppress evidence.)
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Quote #3
"As long as a party receives an appropriate hearing, . . . the party may be sanctioned for abuses of process occurring beyond the courtroom . . . ."Source
— Chambers v. NASCO, Inc., 510 U.S. 32, 57 (1991)
(Cited to argue that the court can sanction misconduct that occurred outside its direct proceedings.)
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Quote #4
"Courts have held that inherent authority sanctions may be imposed for misconduct in another court where the misconduct is . . . in some way related to the case before the sanctioning court."Source
— Klein v. Weidner, Civ. No. 08-3798, 2017 WL 2834260, at *6 (E.D. Pa. June 30, 2017)
(Cited to support the argument that the court's sanctioning power extends to related misconduct in other courts.)
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Quote #5
"The inherent power . . . can punish conduct before a different court if it is intimately related to the relevant case."Source
— Manhattan Review LLC v. Yun, 16 Civ. 0102 (LAK) (JCF), 2017 WL 11455317, *7 n.3 (S.D.N.Y. Sept. 21, 2017)
(Cited to reinforce the court's ability to address related misconduct from other proceedings.)
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Quote #6
Full Extracted Text
Complete text extracted from the document (2,247 characters)
Case 1:20-cr-00330-AJN Document 134 Filed 02/04/21 Page 20 of 23
4. This court possesses the inherent authority to order suppression.
Incident to its inherent power to superintend proceedings, this Court has the authority to suppress the fruits of the government’s misrepresentation. See, e.g., United States v. Cortina, 630 F.3d 1207, 1214 (7th Cir. 1980) (“The court has inherent authority to regulate the administration of criminal justice among the parties before the bar . . . [by] exclud[ing] evidence taken from the defendant by willful disobedience of law.” (citation omitted)); United States v. Lambus, 897 F.3d 368, 386 (2d Cir. 2018) (“It is within the court’s inherent authority to suppress evidence gathered unlawfully in order to maintain the integrity of its own proceedings . . . .”); Benkovitch v. Gorilla, Inc., No. 2:15-cv-7806 (WJM), 2017 WL 4005452, at *2 (D.N.J. Sept. 12, 2017) (“District courts have ‘inherent authority’ to impose a variety of sanctions, including . . . suppression of evidence . . . .”).
It does not matter that the government made its misrepresentations to [REDACTED] and not directly to this Court. “As long as a party receives an appropriate hearing, . . . the party may be sanctioned for abuses of process occurring beyond the courtroom . . . .” Chambers v. NASCO, Inc., 510 U.S. 32, 57 (1991). “Courts have held that inherent authority sanctions may be imposed for misconduct in another court where the misconduct is . . . in some way related to the case before the sanctioning court.” Klein v. Weidner, Civ. No. 08-3798, 2017 WL 2834260, at *6 (E.D. Pa. June 30, 2017) (citation and alteration omitted); Manhattan Review LLC v. Yun, 16 Civ. 0102 (LAK) (JCF), 2017 WL 11455317, *7 n.3 (S.D.N.Y. Sept. 21, 2017) (“The inherent power . . . can punish conduct before a different court if it is intimately related to the relevant case.” (citing Klein, 2017 WL 2834260, at *4)). Here, the government’s misrepresentation to [REDACTED] was not simply “related” to Counts Five and Six; only by the government’s deception was it able to obtain the factual predicate for those counts. Accordingly, the Court may exercise its inherent authority to suppress that evidence. And it should.
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