Tag Archives: Fed. R. Evid. 803(6)

Document Created 19 Days Before Trial Was Not A “Business Record” For Purposes of Hearsay Exception Fed. R. Evid. 803(6), Holds Tenth Circuit

In United States v. Harper, No. 23-5091 (10th Cir. Oct. 3, 2024), the Tenth Circuit reverses the kidnapping conviction where the only record of an essential jurisdictional element was a verification letter generated shortly before trial that the panel holds cannot thereby stand as a business record under Fed. R. Evid. 803(6). The defendant wasContinue reading “Document Created 19 Days Before Trial Was Not A “Business Record” For Purposes of Hearsay Exception Fed. R. Evid. 803(6), Holds Tenth Circuit”

Eleventh Circuit Holds That District Court Erred in Excluding Evidence of Colombian Prosecution Documents in Torture Victim Protection Act Case

In Does 1 Through 976 v. Chiquita Brands Int’l, Inc., No. 19-13926 (11th Cir. Sept. 6, 2022), the Eleventh Circuit substantially reverses summary judgment in a dozen bellwether cases against Chiquita Brands International, Inc. and a host of other defendants brought under the Torture Victim Protection Act, 28 U.S.C. § 1350 note, and Colombian law. InContinue reading “Eleventh Circuit Holds That District Court Erred in Excluding Evidence of Colombian Prosecution Documents in Torture Victim Protection Act Case”