This column reports on several significant representative decisions handed down recently in the U.S. District Court for the Eastern District of New York. Judge Eric R. Komitee, denying a motion to suppress statements made to foreign officials in Bulgaria, found that there was no “joint venture” between U.S. and Bulgarian agents so as to require Miranda warnings. Judge Sterling Johnson Jr., held that there was no subject matter jurisdiction over claims against Interpol. And Judge Brian M. Cogan sanctioned plaintiffs’ counsel, in a Fair Labor Standards Act case, for improper client solicitation.

‘Miranda’ Statements Made to Foreign Officials

In United States v. Zhukov, 18 CR 633 (E.D.N.Y. May 3, 2021), Judge Komitee declined to suppress statements made by defendant to Bulgarian officials in Varna, Bulgaria, without Miranda warnings, where the degree and nature of coordination between U.S. and Bulgarian law enforcement did not amount to a “joint venture”.