United States v. Jonas Klimavicius

BOWNES, Circuit Judge.

The issue in this case is whether the district court abused its discretion in revoking the citizenship of a defendant in a denaturalization proceeding by means of a default judgment issued under Federal Rule of Civil Procedure 37(b)(2) as a sanction for failure to comply with discovery orders. Defendant-appellant, Jonas Kli-mavicius, refused to comply with the government's discovery requests on fifth amendment grounds. Klimavicius continued to assert the privilege even after the district court found the fifth amendment inapplicable. Citing bad faith and willful…