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274 United States v. Tones, 901 F.2d 205 (2d Cir. 1990) 266,268,271 United States v. Towne, 870 F.2d 880 (2d Cir. 1989) 251 United States v. Tracy, 12 F.3d 1186 (2d Cir. 1993) 283 United States v. Tramunti, 513 F.2d 1087 (2d Cir. 1975) 225,233 United States v. Mantilla), 606 F. Supp. 2d 3
Should Be Denied 182 1. Applicable Law 182 2. Discussion 184 C. The Defendant's Additional Requests for Disclosure Should Be Denied 185 XI. The Use of a Grand Jury Siting in White Plains Was Entirely Proper 193 A. Background 194 1. The SDNY and Local Rules for the Division of Business 194 2. The SDNY Any Plan 19
ements may be admitted at trial on a conditional basis without the need for any pretrial consideration of their admissibility. See United States v. Tracy, 12 F.3d 1186,1199 (2d Cir. 1993) ("The decision as to whether the four prerequisites have been met, like all other preliminary questions of admiss
eks before the beginning of trial. There is therefore no need to issue the order Defendant seeks."). Accordingly, this motion should be denied. XL The Use of a Grand Jury Siting in White Plains Was Entirely Proper On June 29,2020, amidst a global pandemic that suspendedgrand juries across the country, the Government sought
ements may be admitted at trial on a conditional basis without the need for any pretrial consideration of their admissibility. See United States v. Tracy, 12 F.3d 1186, 1199 (2d Cir. 1993) ("The decision as to whether the four prerequisites have been met, like all other preliminary questions of admis
ks before the beginning of trial. There is therefore no need to issue the order Defendant seeks."). Accordingly, this motion should be denied. XI. The Use of a Grand Jury Siting in White Plains Was Entirely Proper On June 29, 2020, amidst a global pandemic that suspended grand juries across the country, the Government sough
ements may be admitted at trial on a conditional basis without the need for any pretrial consideration of their admissibility. See United States v. Tracy, 12 F.3d 1186, 1199 (2d Cir. 1993) ("The decision as to whether the four prerequisites have been met, like all other preliminary questions of admis
ks before the beginning of trial. There is therefore no need to issue the order Defendant seeks."). Accordingly, this motion should be denied. XI. The Use of a Grand Jury Siting in White Plains Was Entirely Proper On June 29, 2020, amidst a global pandemic that suspended grand juries across the country, the Government sough
ements may be admitted at trial on a conditional basis without the need for any pretrial consideration of their admissibility. See United States v. Tracy, 12 F.3d 1186, 1199 (2d Cir. 1993) ("The decision as to whether the four prerequisites have been met, like all other preliminary questions of admis
ks before the beginning of trial. There is therefore no need to issue the order Defendant seeks."). Accordingly, this motion should be denied. XI. The Use of a Grand Jury Siting in White Plains Was Entirely Proper On June 29, 2020, amidst a global pandemic that suspended grand juries across the country, the Government sough
ements may be admitted at trial on a conditional basis without the need for any pretrial consideration of their admissibility. See United States v. Tracy, 12 F.3d 1186, 1199 (2d Cir. 1993) ("The decision as to whether the four prerequisites have been met, like all other preliminary questions of admis
ks before the beginning of trial. There is therefore no need to issue the order Defendant seeks."). Accordingly, this motion should be denied. XI. The Use of a Grand Jury Siting in White Plains Was Entirely Proper On June 29, 2020, amidst a global pandemic that suspended grand juries across the country, the Government sough
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