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United States v. Safavian

United States District Court for the District of Columbia
435 F. Supp. 2d 36 (D.D.C. 2006)


Facts

David Safavian (defendant) was charged with obstruction of justice during an investigation of his boss, lobbyist Jack Abramoff. The prosecution sought to admit approximately 260 emails to or from Safavian into evidence. Many of these emails contained the “@” symbol, which was indicative of an email address. Additionally, many of the email addresses contained the names of the individuals connected to those addresses, such as “David.Safavian@mail.house.gov” and “abramoffj@ftlaw.com.” Some of the emails did not contain any characteristics identifying the sender or recipient by name, such as emails to or from “MerrittDC@aol.com.” However, the bodies of many of the emails contained the name of the recipient or sender in the greeting or signature, and the contents of the emails also indicated in other ways that they were to or from the particular recipient or sender. For example, many of the emails discussed Safavian’s and Abramoff’s work or Abramoff’s restaurant. Safavian objected to the introduction of the emails, arguing that the emails could not be properly authenticated under Federal Rule of Evidence (FRE) 901.

Rule of Law

Issue

Holding and Reasoning (Friedman, J.)

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