Editor's note.
The January 2007 edition of The Florida Bar Journal contained an
article written by Glenn J. Waldman entitled "Federal Court
Sanctions Against Attorneys Under 28 U.S.C. [section]1927--The 11th
Circuit Court of Appeals Attempts to Divide the Standard for Multiplying
the Proceedings in Bad Faith." That piece discussed the case of
Amlong & Amlong, P.A. v. Denny's, Inc., 457 F.3d 1180 (11th
Cir. 2006), and the preparation of a deposition errata sheet involved in
an attorney sanctions award that was overturned in that appeal. The
author stated that a client of the Amlong law firm, "with the
assistance of the Amlong attorneys, produced a deposition errata sheet
consisting of 63 pages and a total of 868 changes" to her
deposition. Neither the Journal nor the author meant to imply by that
statement that the Amlong attorneys engaged in any unethical or wrongful
conduct or that they otherwise were involved in suborning perjury. As
clearly explained in the 11th Circuit opinion and the Journal article,
the trial judge's entry of sanctions against the Amlongs was
invalidated as an abuse of judicial discretion and remanded for further
proceedings.
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No portion of this article can be reproduced without the express written permission from the copyright holder.
Copyright 2007 Gale, Cengage Learning. All rights reserved.
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