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s directive, courts in this Circuit regularly defer ruling on a multiplicity motion until after the conclusion of trial. See, e.g., United States v. Halkbank, No. 15 Cr. 867 (RMB), 2020 WL 5849512, at *9 (S.D.N.Y. Oct. I, 2020) (denying pretrial motion to dismiss multiplicitous count and noting that "[c]
s "are violated only when the challenged conduct invaded his legitimate expectation of privacy rather than that of a third party." United States v. Payner, 447 U.S. 727, 731 (1980) (emphasis in original); see also United States v. Villegas, 899 F.2d 1324, 1333 (2d Cir. 1990). Ultimately, the Fourth Ame
s directive, courts in this Circuit regularly defer ruling on a multiplicity motion until after the conclusion of trial. See, e.g., United States v. Halkbank,No. 15 Cr. 867 (RMB), 2020 WL 5849512, at *9 (S.D.N.Y. Oct. I, 2020) (denying pretrial motion to dismiss multiplicitous count and noting that "lc]o
s "are violated only when the challenged conduct invaded his legitimate expectation of privacy rather than that of a third party." United States v. Payner, 447 U.S. 727, 731 (1980) (emphasis in original); see also United States v. Villegas, 899 F.2d 1324, 1333 (2d Cir. 1990). Ultimately, the Fourth Ame
s directive, courts in this Circuit regularly defer ruling on a multiplicity motion until after the conclusion of trial. See, e.g., United States v. Halkbank,No. 15 Cr. 867 (RMB), 2020 WL 5849512, at *9 (S.D.N.Y. Oct. I, 2020) (denying pretrial motion to dismiss multiplicitous count and noting that "lc]o
s "are violated only when the challenged conduct invaded his legitimate expectation of privacy rather than that of a third party." United States v. Payner, 447 U.S. 727, 731 (1980) (emphasis in original); see also United States v. Villegas, 899 F.2d 1324, 1333 (2d Cir. 1990). Ultimately, the Fourth Ame
s directive, courts in this Circuit regularly defer ruling on a multiplicity motion until after the conclusion of trial. See, e.g., United States v. Halkbank, 15 Cr. 867 (RMB), 2020 WL 5849512, at *9 (S.D.N.Y. Oct. 1, 2020) (denying pretrial motion to dismiss multiplicitous count and noting that "[c]ourt
s "are violated only when the challenged conduct invaded his legitimate expectation of privacy rather than that of a third party." United States v. Payner, 447 U.S. 727, 731 (1980) (emphasis in original); see also United States v. Viliegas, 899 F.2d 1324, 1333 (2d Cir. 1990). Ultimately, the Fourth Ame
s directive, courts in this Circuit regularly defer ruling on a multiplicity motion until after the conclusion of trial. See, e.g., United States v. Halkbank, No. 15 Cr. 867 (RMB), 2020 WL 5849512, at *9 (S.D.N.Y. Oct. I, 2020) (denying pretrial motion to dismiss multiplicitous count and noting that "Ic]
s "are violated only when the challenged conduct invaded his legitimate expectation of privacy rather than that of a third party." United States v. Payner, 447 U.S. 727, 731 (1980) (emphasis in original); see also United States v. Villegas, 899 F.2d 1324, 1333 (2d Cir. 1990). Ultimately, the Fourth Ame
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David Boies
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Eric Schmidt
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Julie K. Brown
PERSONColleen McMahon
PERSONMartindell
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ORGANIZATIONthe Southern District
LOCATIONthe Second Circuit's
ORGANIZATIONFisher
PERSONCanfield
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