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At its Fall 2007 meeting, the Appellate Rules Advisory Committee discussed the current circuit split over whether Federal Rule of Appellate Procedure 7 authorizes the inclusion of attorney fees in a bond for costs on appeal.
Order, In re September 11 Litigation, No. 1:21-mc-97 (S.D.N.Y. Aug. 9, 2007), D.E. 1175.