The following excerpt is from Ling v. Asphalt Green, Inc., 13-3563 (2nd Cir. 2014):
(decision to impose sanctions reviewed for abuse of discretion). A district court "may not impose a filing injunction on a litigant . . . without providing the litigant with notice and an opportunity to be heard." Iwachiw v. N.Y. State Dep't of Motor Vehicles, 396 F.3d 525, 529 (2d Cir. 2005).
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