The following excerpt is from U.S. v. Baker, 641 F.2d 1311 (9th Cir. 1981):
Washington v. Washington State Commercial Passenger Fishing Vessel Association, 443 U.S. 658, 692-93 n.32, 99 S.Ct. 3055, 3078-79 n.32, 61 L.Ed.2d 823 (1979).
6 But see, Shakman v. Democratic Organization of Cook County, 533 F.2d 344, 352 (7th Cir.), cert. denied, 429 U.S. 858, 97 S.Ct. 156, 50 L.Ed.2d 135 (1976) (court finds city employee had actual notice of injunction issued against city but doubts Rule 65(d) requires him to receive actual notice before he can be held in civil contempt).
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