B.D. PARKER, JR., Circuit Judge.
Shirley Rangolan appeals from a judgment of the United States District Court for the Eastern District of New York (Wexler, J.) holding her in criminal contempt under 18 U.S.C. § 401(1), which authorizes courts to punish the "[m]isbehavior of any person in its presence or so near thereto as to obstruct the administration of justice." Id. On appeal, Rangolan contends that her misbehavior did not occur in, or sufficiently...
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