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Evidence Keyed to Sklansky
United States v. Lundstrom
Citation:880 F.3d 423 (8th Cir. 2018)
The defendant was convicted of fraudulently concealing a bank loan losses. During trial, the prosecution was allowed to admit reports written by employees of the federal Office of Thrift Supervision under the business records exception. The defendant argued that the business records exception could not apply because Federal Rule 803(8), which was the rule for the public records exception, excluded “factual findings from a legally authorized investigation when a report containing such findings is offered against a criminal defendant.”
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