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ing evidence and part of the speaker's effort to conceal the offense. See Ruiz, 894 F.2d at 505; Potamitis, 739 F.2d at 791 (citing United States v. Carson, 464 F.2d 424, 436 (2d Cir. 1972); Sweig, 441 F.2d at 118-19) (affirming denial of a severance motion where the false statements "concern the subst
is case are far removed from the "narrow" circumstances in which the Supreme Court has found an exception to the third party doctrine. For example, the Carpenter Court, while stressing that its holding was a "narrow one," 138 S. Ct. at 2220, held that "[g]iven the unique nature ofcell phone location records," which
ing evidence and part of the speaker's effort to conceal the offense. See Ruiz, 894 F.2d at 505; Potamitis, 739 F.2d at 791 (citing United States v. Carson, 464 F.2d 424, 436 (2d Cir. 1972); Sweig, 441 F.2d at 118-19) (affirming denial of a severance motion where the false statements "concern the subst
is case are far removed from the "narrow" circumstances in which the Supreme Court has found an exception to the third party doctrine. For example, the Carpenter Court, while stressing that its holding was a "narrow one," 138 S. Ct. at 2220, held that "[g]iven the unique nature of cell phone location records," whic
ing evidence and part of the speaker's effort to conceal the offense. See Ruiz, 894 F.2d at 505; Potamitis, 739 F.2d at 791 (citing United States v. Carson, 464 F.2d 424, 436 (2d Cir. 1972); Sweig, 441 F.2d at 118-19) (affirming denial of a severance motion where the false statements "concern the subst
is case are far removed from the "narrow" circumstances in which the Supreme Court has found an exception to the third party doctrine. For example, the Carpenter Court, while stressing that its holding was a "narrow one," 138 S. Ct. at 2220, held that "[g]iven the unique nature of cell phone location records," whic
ing evidence and part of the speaker's effort to conceal the offense. See Ruiz, 894 F.2d at 505; Potamitis, 739 F.2d at 791 (citing United States v. Carson, 464 F.2d 424, 436 (2d Cir. 1972); Sweig, 441 F.2d at 118-19) (affirming denial of a severance motion where the false statements "concern the subst
is case are far removed from the "narrow" circumstances in which the Supreme Court has found an exception to the third party doctrine. For example, the Carpenter Court, while stressing that its holding was a "narrow one," 138 S. Ct. at 2220, held that "[g]iven the unique nature of cell phone location records," whic
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