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hat each of the contingencies necessary to the legal discovery of the contested evidence would be resolved in the government's favor."' Id. (quoting Heath, 455 F.3d at 60). As the Supreme Court has explained, if the Government can establish that the evidence inevitably would have been discovered by la
t that the defendant "had not engaged in any business activity during the preceding six years").53 Accordingly, and consistent with the holdings in Ruiz and Broccolo, this Court should deny the severance motion. The defendant argues that the offenses are not connected because they involve different time periods.
that each of the contingencies necessary to the legal discovery of the contested evidence would be resolved in the government's favor." Id. (quoting Heath, 455 F.3d at 60). As the Supreme Court has explained, if the Government can establish that the evidence inevitably would have been discovered by la
t that the defendant "had not engaged in any business activity during the preceding six years").53 Accordingly, and consistent with the holdings in Ruiz and Broccolo, this Court should deny the severance motion. The defendant argues that the offenses are not connected because they involve different time periods.
that each of the contingencies necessary to the legal discovery of the contested evidence would be resolved in the government's favor." Id. (quoting Heath, 455 F.3d at 60). As the Supreme Court has explained, if the Government can establish that the evidence inevitably would have been discovered by la
t that the defendant "had not engaged in any business activity during the preceding six years").53 Accordingly, and consistent with the holdings in Ruiz and Broccolo, this Court should deny the severance motion. The defendant argues that the offenses are not connected because they involve different time periods.
that each of the contingencies necessary to the legal discovery of the contested evidence would be resolved in the government's favor." Id. (quoting Heath, 455 F.3d at 60). As the Supreme Court has explained, if the Government can establish that the evidence inevitably would have been discovered by la
rt that the defendant "had not engaged in any business activity during the preceding six years").54 Accordingly, and consistent with the holding in Ruiz and Broccolo, this Court should deny the severance motion. 54 While the defendant may argue that the fact that her deposition, unlike Ruiz, did not involve crim
that each of the contingencies necessary to the legal discovery of the contested evidence would be resolved in the government's favor." Id. (quoting Heath, 455 F.3d at 60). As the Supreme Court has explained, if the Government can establish that the evidence inevitably would have been discovered by la
t that the defendant "had not engaged in any business activity during the preceding six years").53 Accordingly, and consistent with the holdings in Ruiz and Broccolo, this Court should deny the severance motion. The defendant argues that the offenses are not connected because they involve different time periods.
Entities connected to both Heath and Ruiz and Broccolo

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