United States Ninth Circuit

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US v. Katakis, 14-10283

District court's order granting defendant a judgment of acquittal after a jury convicted him of obstruction of justice in violation of 18 U.S.C. section 1519, is affirmed where: 1) the evidence was insufficient to show that defendant actually deleted electronic records or files; and 2) proving that defendant moved emails from an email client's inbox to the deleted items folder does not demonstrate defendant actually concealed those emails within the meaning of section 1519.

Appellate Information

  • Decided 08/31/2015
  • Published 08/31/2015




  • United States Ninth Circuit