The following excerpt is from United States v. Jacques, 20-1762, 20-3276, 20-3286 (2nd Cir. 2021):
The brief 1944 Advisory Committee Note to Rule 36 did not similarly refer to the term-of-court limitation; but it stated that Rule 36 continued "existing law," citing Rupinski v. United States, 4 F.2d 17 (6th Cir. 1925). In that case, the court of appeals held that it had the power to grant a request for the "clerical" correction of an "error . . . discovered[] long after the term had passed." Id. at 18 (emphasis added).
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