In 2003, Quattrone was confronted with evidence of allegedly incriminating emails in a widely publicized series of trials. Some of the evidence included Quattrone forwarding to his entire staff an email with the subject 'Re: Time to clean up those files' after being told Credit Suisse First Boston was under investigation by a grand jury. The first trial resulted in a hung jury. The second trial resulted in a conviction. On appeal the U.S. Court of Appeals for the Second Circuit reversed Quattrone's conviction, ruling, based in part upon the Supreme Court case Arthur Andersen LLP v. United States that Quattrone's jury had been given erroneous jury instructions. The appeals court also agreed with the defense that in the interest of justice, subsequent proceedings should take place in front of a different judge.