Since 2011. An occasional commonplacing of the U.S. Circuit Courts of Appeal.
Not written by a barrister. The name was thought up by a second-year American law student sitting in a coffeehouse in Manhattan. Neither an authoritative statement of the law nor legal advice. Don't rely. Quick work.
Tenth Circuit: United States v. Garcia-Herrera
After entry of judgment, a court has no jurisdiction over a subsequent motion by a deft to compel former counsel to produce files that would aid in his defense.