BYE, Circuit Judge.
During the criminal prosecution of Cuauhtemoc Gonzalez-Lopez, the district court, acting under its inherent power, imposed sanctions against Joseph Low, the attorney retained by the defendant, after finding he violated the rules of professional conduct. In addition to imposing sanctions against Low, the district court imposed sanctions against Low's attorney, Karl Dickhaus, for Dickhaus's conduct in procuring the subpoena of a witness to testify...
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