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. at 538-39. "[L]ess drastic measures . .. such as limiting instructions, 52 While Zafiro involved a motion to sever defendants, rather than counts, the Supreme Court's construction of Rule 14(a) applies in either case. See Page, 657 F.3d at 129 (relying on Zafiro); United States v. Gracesqui, No. 10 Cr. 74 (PKC),
n—that caused the Government to proceed via subpoena [to Boies Schiller] and its related Application." (Id. at 23-24). The Court further noted that the "Government's interest is bolstered" as the request was made by a grand jury that had issued a "subpoena for the production of documents as part of an ongoing in
. at 538-39. "[L]ess drastic measures . .. such as limiting instructions, 52 While Zafiro involved a motion to sever defendants, rather than counts, the Supreme Court's construction of Rule 14(a) applies in either case. See Page, 657 F.3d at 129 (relying on Zafiro); United States v. Gracesqui, No. 10 Cr. 74 (PKC),
n—that caused the Government to proceed via subpoena [to Boies Schiller] and its related Application." (Id. at 23-24). The Court further noted that the "Government's interest is bolstered" as the request was made by a grand jury that had issued a "subpoena for the production of documents as part of an ongoing in
d. at 538-39. "[L]ess drastic measures ... such as limiting instructions, 52 While Zafiro involved a motion to sever defendants, rather than counts, the Supreme Court's construction of Rule 14(a) applies in either case. See Page, 657 F.3d at 129 (relying on Zafiro); United States v. Gracesqui, No. 10 Cr. 74 (PKC),
n—that caused the Government to proceed via subpoena [to Boies Schiller] and its related Application." (Id. at 23-24). The Court further noted that the "Government's interest is bolstered" as the request was made by a grand jury that had issued a "subpoena for the production of documents as part of an ongoing in
Entities connected to both Supreme Court and the "Government's

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Julie K. Brown
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LOCATIONthe Southern District
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George Mitchell
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Michael Jackson
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Chris Tucker
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Kentucky
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