Judge Upholds Contempt for Va. Attorney Who Refused to Stand for Deposition
Matthew LeFande was held in contempt by a magistrate judge last year for "obstructing the administration of justice."
February 27, 2018 at 04:37 PM
3 minute read
A federal judge in Washington, D.C., this week upheld a magistrate judge's contempt order against a local attorney.
U.S. Magistrate Judge Deborah Robinson issued an order in September 2017 against Matthew LeFande, a lawyer based in Arlington, Virginia, holding him in contempt for refusing to take the stand to be sworn in for a deposition. In upholding Robinson's order Monday, District Judge Amy Berman Jackson wrote that Robinson “appropriately exercised her criminal contempt authority.”
“The Court finds that the evidence recited in the Magistrate Judge's Criminal Contempt Order is sufficient to establish beyond a reasonable doubt that LeFande had the necessary intent, and that his actions were 'both calculated and willful,'” Jackson wrote. “Indeed, LeFande informed the Magistrate Judge through his counsel that he would rather 'take the risk of going to jail' than comply with her orders.”
In the underlying case, the court ruled against LeFande's clients in a dispute with a real estate settlement company called District Title. After the decision, District Title's attorneys sought to conduct post-judgment discovery related to its efforts to collect money from the judgment and attorneys' fees and costs.
The company eventually sought to subpoena LeFande, but he opposed, citing his Fifth Amendment rights against self-incrimination and attorney-client privilege. Robinson ruled LeFande would have to assert those rights on a question-by-question basis, and that a blanket assertion of the privileges would not be acceptable.
After LeFande did not appear for his deposition at the plaintiffs lawyers' offices in August, Robinson ordered LeFande to appear for the deposition in court.
When he did so, on Sept. 21, he refused to take the stand despite multiple orders from Robinson. In addition to holding him in contempt for “obstructing the administration of justice,” Robinson fined LeFande $5,000. The lawyer filed objections to the order shortly after, again raising arguments about the Fifth Amendment and attorney-client privilege.
Jackson said in her opinion that, consistent with prior orders from the court in the case, LeFande could not avoid appearing at the deposition by using a blanket assertion of attorney-client privilege. She wrote that Robinson's order outlining LeFande's actions made it clear he intended to misbehave.
“[LeFande] not only disobeyed the Magistrate Judge's multiple orders in the courtroom in her presence, but he also failed to comply with the opinions and orders of this Court which required him to appear and to respond to the questions on an individual basis,” the judge wrote. “Lefande's violation of these orders impeded the administration of justice by making it impossible for the plaintiff to conduct post-judgment discovery.”
LeFande and his attorney, Horace Bradshaw, did not yet respond to requests for comment. District of Columbia bar records show LeFande is in good standing. He once volunteered as a reserve police officer in the District, but was fired for sending e-mails criticizing his superiors. He sued over the termination, but lost the case in the federal circuit court in 2016.
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