United States v. Habteyes

The defendant, who has been indicted for making false material representations to immigration/naturalization officials regarding his background in Ethiopia, seeks to exclude from the court’s consideration a ledger of firearms distributions to supporters of Ethiopia’s military council (which was waging a campaign of violence against its political opponents).

The proffered document is properly classified as an ancient document pursuant to Federal Rule of Evidence 901(b)(8). Four entries from the ledger are also admissible under rule 803(16), the ancient-document exception to the hearsay rule; in the alternative, they are not hearsay but rather adoptive admissions.

Motion in limine denied.

United States v. Habteyes, No. 1:18cr305, Dec. 18, 2018. EDVA at Alexandria (Ellis).



Categories: Opinions, U.S. District Court - Eastern District of Virginia

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