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36 ¦ JUNE 22, 2020 CONNECTICUT OPINIONS

reason. The court found the mere existence of the PERSONAL INJURY
pandemic was not an extraordinary or compel-
ling reason for release, and defendant’s health is- Court Grants Dismissal in Malicious
sues were not sufficiently detrimental to warrant Prosecution Claim
a compelling reason for compassionate release.

CASE: Liu v. Tangney
DISCOVERY COURT: U.S. District Court for Connecticut
DOC. NO.: 3:19-cv-894
COURT OPINION BY: Haight
Court Finds Attorney-Client Privilege DATE: June 05, 2020 • PAGES: 16
Only Applies To Discovery In Personal Defendant Zhou alleged that plaintiff had as-
Legal Matters saulted her, and on the basis of that allegation,
defendant Tangney issued a warrant for plain-
CASE: United States v. Rankin tiff’s arrest. Plaintiff was charged with assault
COURT: U.S. District Court for Connecticut in the third degree but was ultimately acquitted.
DOC. NO.: 3:18-cr-00272 Plaintiff then brought this claim against defen-
COURT OPINION BY: Meyer dants seeking damages, attorney fees and costs.
DATE: June 05, 2020 • PAGES: 7
Defendant Zhou filed a motion to dismiss for
Defendant was formerly the chief financial of- lack of subject matter jurisdiction for over-run-
ficer of a publicly traded energy cooperative. ning the statute of limitations and for failure to
A grand jury indicted him of misappropriat- state a claim. The defendant argued the clock
ing funds for personal use, and the government began running at the time of plaintiff’s arrest,
moved to compel the cooperative to produce however the court disagreed and found the clock
documents, and the defendant objected to the began running at the time of the acquittal. The
motion claiming attorney-client privilege. The court also found plaintiff sufficiently alleged lack
court found defendant never sought legal advice of probable cause to support a malicious pros-
on personal, only corporate matters. The court ecution claim, however he failed to show that de-
therefore granted the government’s motion to fendant acted with malice. The court dismissed
compel discovery. the state law claim without prejudice to amend.

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