D.P.R.: Cell phone records obtained by SW not self-authenticating as evidence under 902(11)

Cell phone records obtained by warrant are not self-authenticating under F.R.E. 902(11). More will be required. United States v. Charbonier-Laureano, 2023 U.S. Dist. LEXIS 218249 (D.P.R. Dec. 5, 2023).

The government’s knowledge fraud co-conspirators communicated by cell phone during period of the conspiracy supported a search warrant for their phones. United States v. Rosenfeld, 2023 U.S. Dist. LEXIS 218168 (S.D.N.Y. Dec. 7, 2023).*

The fact spousal communications were by cell phone doesn’t destroy their confidential nature. There’s still a reasonable expectation of privacy. United States v. Candelaria, 2023 U.S. Dist. LEXIS 218310 (D.N.M. Dec. 7, 2023).*

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