U.S. v. Cozzi

In prosecution on charge of violation of individual's civil rights by defendant-police officer, Dist. Ct. did not err in denying defendant's motion to dismiss indictment based on contention that: (1) incoming superintendent of police department sent two e-mails to FBI asking whether FBI had begun investigation of defendant and attached copy of video-clip of incident that formed basis of eventual charge; and (2) instant e-mails constituted improper use of defendant's immunized statements that he made during internal police investigation of said incident where incoming superintendent was aware of content of said statements. Record showed no improper use of imunized statements where instant e-mails did not reveal content of subject statements. Fact that content of statements was known by author of e-mails did not require dismissal of indictment.