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3. Invasion of privileged attorney-client
communications through unlawful monitoring of
meetings and telephone conversations.
4. Deprivation of access to vital business books and
records by their seizure and extended retention
pursuant to a search warrant that was improperly
sought and wrongfully issued on the basis of
material misrepresentations of fact made under
oath.
5. Misrepresentation of the status and duration of a
related grand Jury investigation in a manner that
seriously impeded the civil tax litigation.
6. Improper dissemination of grand jury materials.
7. Recalcitrance during discovery, resulting in
abnormal prejudicial delay.
8. Obstreperousness and stonewalling during the
hearing on this matter, causing additional
unwarranted delay.
After discussing certain preliminary matters, we shall
address the items in petitioner’s list, keeping in mind
petitioner’s principal complaints and the claimed harms (as
stated at the end of the hearing) as an aid to understanding
petitioner’s list.
III. Jurisdiction
A. Introduction
Respondent filed a brief in answer to petitioner’s
memorandum (respondent’s brief). In that brief, respondent asks:
As a matter of law, does the TMP have standing to
raise (or rely upon) alleged violations of the
constitutional rights of third parties (specifically
AMCOR, its principals, and AMCOR-sponsored partnerships
(other than Crop Associates-1986)) as the basis for his
request for sanctions against Respondent?
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