United States v. Komasa, No. 13-1534 (2d Cir. 2014)Annotate this Case
Defendants appealed from their convictions on multiple counts of mail, wire, and bank fraud, as well as conspiracy. Defendants' convictions stemmed from a mortgage fraud scheme in which defendants purchased and refinanced various residential properties. At issue in this appeal was their challenge to the district court's decision to admit the loan files at issue as self-authenticating under Federal Rule of Evidence 902(11). The court concluded that the district court did not clearly err in excusing the government's lack of written notice because defendants had actual notice of the government's intention to admit the records as self-authenticating. Accordingly, the court affirmed the judgment.