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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]
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
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
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
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
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
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]
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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