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2008-08-13_Jack_Thomas_v_COH_-_Motion_for_Summary_Judgment
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2008-08-13_Jack_Thomas_v_COH_-_Motion_for_Summary_Judgment
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Case 1:07-cv-00251-JMS-LEK Document 42-2 Filed 08/13/2008 Page 17 of 27 <br /> his authorized discretion cannot deprive him of absolute immunity"). A prosecutor <br /> is also entitled to absolute immunity despite allegations of his "knowing use of <br /> perjured testimony" and the "deliberate withholding of exculpatory information." <br /> Imbler, 424 U.S. at 431 n. 34, 96 S.Ct. at 995. Although such conduct would be <br /> "reprehensible," it does not make the prosecutor amenable to a civil suit for <br /> damages. Id. In sum, the nature of absolute immunity is such that it "accords <br /> protection from ... any judicial scrutiny of the motive for and reasonableness of <br /> official action." Robison v. Via, 821 F.2d 913, 918 (2d Cir.1987). "[In] the realm <br /> of absolute immunity, ... evaluation of motive and reasonableness is forbidden ...." <br /> Id. at 920; see, e.g., Dory v. Ryan, 25 F.3d 81, 83 (2d Cir.1994) (the absolute <br /> character of absolute immunity is that it "protects a prosecutor from §1983 liability <br /> for virtually all acts, regardless of motivation, associated with his function as an <br /> advocate"). These principles are not affected by allegations that improperly <br /> motivated prosecutions were commenced or continued pursuant to a conspiracy. <br /> See, e.g., id.; Bernard, 356 F.3d at 503. <br /> The documents filed with the Separate Concise Statement clearly show that <br /> the acts of the Prosecuting Attorney and Deputy Prosecuting Attorney were acts <br /> traditionally performed by the prosecutor and were not investigative in nature. <br /> Unlike the facts of Kalina v. Fletcher, the evidence shows the prosecutor assigned <br /> 10 <br />
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