United States v. Hon

In 1988, undercover agents from the United States Customs Service purchased eight counterfeit watches from Nam Ping Hon (defendant) and his wife, Sandy Hon. Seven months after the first purchase, agents arranged a larger purchase of 1,200 counterfeit watches. Agents arrested the Hons and seized two shopping bags containing 889 counterfeit watches from the trunk of the Hons’ car. Sandy pleaded guilty, and a federal jury convicted Nam of trafficking and attempting to traffic in counterfeit wrist watches. Agent Bonnie Goldblatt testified that after she and her partner purchased the initial eight watches, Goldblatt placed the watches in a sealed and labelled evidence bag that she stored in a locked cabinet in her office until she gave the watches to Special Agent Blaise Piazza. Although Goldblatt wrote an incorrect case number on the bag, Goldblatt could identify the eight watches admitted at trial as the watches she handled. Piazza testified that he kept the bag of eight watches in his unlocked desk and left the bag unsealed after breaking the seal to examine the watches. Another agent testified that the agent and his partner handed the two bags of 889 watches to Piazza. Piazza testified that he stored the 889 watches in his supervisor’s locked office and then in two separate locked evidence rooms before bringing them to the United States Attorney’s office for trial preparation. Piazza did not seal this evidence but testified that he found the evidence in the same position when he moved it from room to room. Nam appealed from his conviction, arguing in relevant part that the prosecution (plaintiff) had failed to provide a proper chain of custody for the counterfeit watches.