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31 (approving of similar precautions when introducing evidence of a defendant's prior felony conviction); Pizarro, 2018 WL 1737236, at *7; see also Zafiro, 506 U.S. at 540 ("[J]uries are presumed to follow their instructions." (citation and internal quotation marks omitted)). There is every reason to
o 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), 2015 WL 5231168, at *4 n.2 (S.D.N.Y. Sept 8, 2015), afd, 730 F. App'x 25 (2d Cir. 2018) (citing
wyer is called "on a significant issue other than on behalf of the client, and it is apparent that the testimony may be prejudicial to the client." N.Y. R.P.C. 3.7(b); see generally Murray v. Met. Life Ins. Co., 583 F.3d 173, 177-80 (2d Cir. 2009) (discussing the advocate-witness rule). 149 EFTA00100116 VII.
31 (approving of similar precautions when introducing evidence of a defendant's prior felony conviction); Pizarro, 2018 WL 1737236, at *7; see also Zafiro, 506 U.S. at 540 ("[J]uries are presumed to follow their instructions." (citation and internal quotation marks omitted)). There is every reason to
o 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), 2015 WL 5231168, at *4 n.2 (S.D.N.Y. Sept. 8, 2015), aff'd, 730 F. App'x 25 (2d Cir. 2018) (citi
wyer is called "on a significant issue other than on behalf of the client, and it is apparent that the testimony may be prejudicial to the client." N.Y. R.P.C. 3.7(b); see generally Murray v. Met. Life Ins. Co., 583 F.3d 173, 177-80 (2d Cir. 2009) (discussing the advocate-witness rule). 149 EFTA00077781 VII.
31 (approving of similar precautions when introducing evidence of a defendant's prior felony conviction); Pizarro, 2018 WL 1737236, at *7; see also Zafiro, 506 U.S. at 540 ("[J]uries are presumed to follow their instructions." (citation and internal quotation marks omitted)). There is every reason to
o 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), 2015 WL 5231168, at *4 n.2 (S.D.N.Y. Sept. 8, 2015), aff'd, 730 F. App'x 25 (2d Cir. 2018) (citi
wyer is called "on a significant issue other than on behalf of the client, and it is apparent that the testimony may be prejudicial to the client." N.Y. R.P.C. 3.7(b); see generally Murray v. Met. Life Ins. Co., 583 F.3d 173, 177-80 (2d Cir. 2009) (discussing the advocate-witness rule). 149 EFTA00039596 VII.
31 (approving of similar precautions when introducing evidence of a defendant's prior felony conviction); Pizarro, 2018 WL 1737236, at *7; see also Zafiro, 506 U.S. at 540 ("[J]uries are presumed to follow their instructions." (citation and internal quotation marks omitted)). There is every reason to
o 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), 2015 WL 5231168, at *4 n.2 (S.D.N.Y. Sept. 8, 2015), aff'd, 730 F. App'x 25 (2d Cir. 2018) (citi
wyer is called "on a significant issue other than on behalf of the client, and it is apparent that the testimony may be prejudicial to the client." N.Y. R.P.C. 3.7(b); see generally Murray v. Met. Life Ins. Co., 583 F.3d 173, 177-80 (2d Cir. 2009) (discussing the advocate-witness rule). 149 EFTA00103174 VII.
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