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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),
t analysis, the defendant cites no case for the proposition that the setting in which the statement is made is significant, much less determinative. Cl Broccolo, 797 F. Supp. at 1190 (false statement 145 EFTA00077777 in bankruptcy proceeding). And the cases the defendant cites in which a perjury or false
. 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 analysis, the defendant cites no case for the proposition that the setting in which the statement is made is significant, much less determinative. Cl Broccolo, 797 F. Supp. at 1190 (false statement 145 EFTA00039592 in bankruptcy proceeding). And the cases the defendant cites in which a perjury or false
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 analysis, the defendant cites no case for the proposition that the setting in which the statement is made is significant, much less determinative. Cl Broccolo, 797 F. Supp. at 1190 (false statement in bankruptcy proceeding). And the cases the defendant cites in which a perjury or false statements count wa
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 analysis, the defendant cites no case for the proposition that the setting in which the statement is made is significant, much less determinative. Cl Broccolo, 797 F. Supp. at 1190 (false statement 145 EFTA00103170 in bankruptcy proceeding). And the cases the defendant cites in which a perjury or false
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