United States v. Deutsch

CUMMINGS, Circuit Judge. Melvin Deutsch appeals the district court's refusal to reconsider a prior ruling. We affirm because
the motion to reconsider was untimely, depriving the district court of jurisdiction. Along the way we attempt to clarify the
law regarding the characterization of motions under Federal Rules of Civil Procedure 59(e) and 60(b). I. BACKGROUND