fear of retaliation, and (2) the reliability of her statements to law enforcement officers. As to the first finding, Harris argues that the court initially misunderstood the government’s submission to' indicate that Harris had threatened the witness. Any such concern, however, was alleviated by the prosecutor’s clarification that the victim felt threatened by Harris, not that he had explicitly issued threats. Harris further speculates that the victim’s refusal to appear was animated more by her own criminal conduct than her fear of retaliation by him. But that conjecture is belied b as convincingly demonstrated here is supported by evidence that (1) the victim reported the assault in a 911 call, see Navarette v. California, — U.S. -, 134 S.Ct. 1683, 1689-90, 188 L.Ed.2d 680 (2014) (<HOLDING>); (2) Officer Ayala observed the victim’s
holding that the chief financial officer of a hospital had sufficient access to the allegedly false cost reports resulting from the false invoices to require him to plead at least one example of a false claim with particularity holding that where defendant disputed his knowledge and intent to facilitate securities fraud by producing false audit reports evidence of his prior preparation of false audit reports in connection with a similar fraud scheme was properly admitted holding corporate officer liable as aider and abettor in filing of false reports even though reports were not authorized or approved of by officers recognizing the possibility but denying relief recognizing that possibility of tracing and identifying 911 callers provides some safeguards against making false reports with immunity