United Statesv.Crespo
A former federal health-care-fraud task-force agent appealed convictions for conspiracy to commit witness tampering, substantive witness tampering, and conspiracy to obstruct justice, along with a 97-month sentence. He challenged wiretap evidence, alleged prosecutorial misconduct and false testimony, limits on recross-examination, other-act evidence, sufficiency, jury instructions, cumulative error, and sentencing calculations. The Eleventh Circuit rejected each claim under the applicable preservation and review standards. It found the surveillance lawfully admitted, no trial error requiring a mistrial or reversal, sufficient evidence, and no reversible Guidelines error. The convictions and sentence were affirmed.
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