United States v. Angleton

MEMORANDUM AND OPINION

ROSENTHAL, District Judge.

Roger Angleton, the brother of defendant Robert Angleton, wrote five notes that were found in his cell after his suicide. The government moves for an order in limine as to these “jail notes.” (Docket Entry No. 71). Defendant has responded. The issues that can be addressed pretrial are whether, on the present record, the jail notes are admissible under specific exceptions to the hearsay rule, as dying declarations under Federal Rule of Evidence 804(b)(2); statements against interest under Rule 804(b)(3); excited utterances under Rule 803(2); or…