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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),
t that the information is held by a third party does not by itself overcome the user's claim to Fourth Amendment protection." Id. at 2217; see also Zietzke v. United States, 426 F. Supp. 3d 758, 768 (W.D. Wash. 2019) ("The Court. . . will extend Carpenter to new circumstances only if they directly implicate the privacy
. 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),
t that the information is held by a third party does not by itself overcome the user's claim to Fourth Amendment protection." Id. at 2217; see also Zietzke v. United States, 426 F. Supp. 3d 758, 768 (W.D. Wash. 2019) ("The Court . . . will extend Carpenter to new circumstances only if they directly implicate the privacy
. 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),
t that the information is held by a third party does not by itself overcome the user's claim to Fourth Amendment protection." Id. at 2217; see also Zietzke v. United States, 426 F. Supp. 3d 758, 768 (W.D. Wash. 2019) ("The Court . . . will extend Carpenter to new circumstances only if they directly implicate the privacy
the counts would waste judicial resources by requiring a second trial at 53 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),
t that the information is held by a third party does not by itself overcome the user's claim to Fourth Amendment protection." Id. at 2217; see also Zietzke v. United States, 426 F. Supp. 3d 758, 768 (W.D. Wash. 2019) ("The Court ... will extend Carpenter to new circumstances only if they directly implicate the privacy
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),
t that the information is held by a third party does not by itself overcome the user's claim to Fourth Amendment protection." Id. at 2217; see also Zietzke v. United States, 426 F. Supp. 3d 758, 768 (W.D. Wash. 2019) ("The Court . . . will extend Carpenter to new circumstances only if they directly implicate the privacy
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