Prof. Ben Trachtenberg’s article “Coconspirators, ‘Coventurers,’ and the Exception Swallowing the Hearsay Rule,” published in 61 Hastings Law Journal 581 (2010), was cited recently in a brief filed with a federal court in Chicago.
Counsel representing Eugene Klein, a Roman Catholic priest who worked as a prison chaplain in Springfield, Mo., cited Prof. Trachtenberg’s article in a discussion of the proper scope of the “coconspirator statement” exception to the hearsay rule. Among other things, Klein is charged with helping Chicago mobster Frank Calabrese, who died in December 2012 while serving a life sentence for multiple murders, recover a valuable violin reportedly hidden in a Wisconsin house to keep the government from selling it.
The case is United States v. Eugene Klein, No. 11 CR 401 (Northern District of Illinois).