Phoenix atlantica in 1935 by the French botanist Auguste Chevalier. Its appearance is very similar to "Phoenix dactylifera", being more similar in form to "P. dactylifera" than to "Phoenix canariensis", and possessing characters of both. Tamareira is a clustering palm with 2 to 6 trunks, 5–15 m in height with dark green leaves 2–3 m in length. "P. atlantica" can be distinguished easily from "P. canariensis" by its clustering growth form and its shorter, straighter leaves. The Canary Island date palm is adapted to a wetter climate and cooler temperatures, down to −8 °C. Other distinctions between "P. atlantica" and "P. dactylifera"
Fruit of the poisonous tree a witness who freely and voluntarily testifies is enough of an independent intervening factor to sufficiently "attenuate" the connection between the government's illegal discovery of the witness and the witness's voluntary testimony itself. ("United States v. Ceccolini", 435 U.S. 268 (1978)) The "fruit of the poisonous tree" doctrine is an extension of the exclusionary rule, which, subject to some exceptions, prevents evidence obtained in violation of the Fourth Amendment from being admitted in a criminal trial. Like the exclusionary rule, the fruit of the poisonous tree doctrine is intended to deter police from using illegal means to obtain evidence. The