Gerard C. Borean

Following an earlier finding that a defendant knowingly assisted in a cover-up of the truth by failing to ensure production of sales invoices required by court order, the court determined whether that conduct constituted contempt.

The court held that aiding and abetting a breach of a court order can ground contempt and applied the aiding and abetting framework to the defendant's omissions and knowledge.

Unsworn submissions about counsel conflict, lack of intent, and apology did not displace the prior factual findings.

The defendant was held in contempt, with a further hearing directed on the appropriate relief.