- Accusing a state liquor agent who was investigating Venezia's business operations of bribery and requesting that the State Attorney indict the agent.
- Filing a complaint for bribery against the agent in state court.
- Drawing the agent into court on a separate matter, and then serving the agent papers which required him to appear for a preliminary injunction hearing within fifteen minutes.
- A fter the court entered a preliminary injunction against the agent prohibiting the agent from investigating Venezia, and the agent ignored the injunction and continued investigating Venezia's illegal gambling operations, Cueto requested that the agent be held in contempt.
- When the agent prevailed in federal court to dissolve the injunction, Cueto filed an appeal in the Court of Appeals and, upon denial, filed a petition for certiorari to the Supreme Court.
- Once the grand jury was empaneled to investigate Venezia, Cueto filed various motions to hinder the investigation and to discharge the grand jury.
4 The Second Circuit noted that any work product protection was still subject to the "substantial need" showing of Rule 26(b)(3) and other well-established restrictions on the work product doctrine itself.