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States v. Chalmers, 474 F. Supp. 2d 555 (S.D.N.Y. 2007) 225, 226 United States v. Chambers, 800 F. App'x 43 (2d Cir. 2020) 69 United States v. Chan Lo, No. 14 Cr. 491 (VSB), 2016 WL 9076234 (S.D.N.Y. Feb. 4, 2016), aff'd. 679 F. App'x 79 (2d Cir. 2017) United States v. Chen, 378 F.3d 151 (2d Cir
152 VIII. There Is No Basis to Strike Any Portion of the Indictment 157 A. Relevant Facts 158 B. Applicable Law 159 C. Discussion 161 IX. The Defendant's Motion to Dismiss Count One or Count Three as '\lultiplicitous Is Premature 169 A. Relevant Facts 169 B. Applicable Law 170 C. Discussion 172 X. Th
tion and internal quotation marks omitted)). "The testimony need not have actually influenced, misled, or impeded the proceeding." United States v. Chan Lo, No. 14 Cr. 491 (VSB), 2016 WL 9076234, at *8 (S.D.N.Y. Feb. 4,2016), aff'd 679 F. App'x 79 (2d Cir. 2017); see Fonie, 740 F. Supp. 2d at 412. Since
in Counts One and Three and pursuant to Rule 404(b), there is no basis to strike the allegations regarding Minor Victim-3 from the Indictment. IX. The Defendant's Motion to Dismiss Count One or Count Three as Multiplicitous Is Premature The defendant moves to dismiss Counts One or Three on the ground that they am m
States v. Chalmers, 474 F. Supp. 2d 555 (S.D.N.Y. 2007) 225, 226 United States v. Chambers, 800 F. App'x 43 (2d Cir. 2020) 69 United States v. Chan Lo, No. 14 Cr. 491 (VSB), 2016 WL 9076234 (S.D.N.Y. Feb. 4, 2016), aff'd. 679 F. App'x 79 (2d Cir. 2017) United States v. Chen, 378 F.3d 151 (2d Cir
ations set forth in Section 3283 applies to the crimes charged in Counts One through Four of the Indictment and her motion should be denied. III. The Defendant's Motion to Dismiss the Indictment Based on Alleged Improper Pre- Trial Delay Should Be Denied The defendant contends that the Indictment should be dismissed
tion and internal quotation marks omitted)). "The testimony need not have actually influenced, misled, or impeded the proceeding." United States v. Chan Lo, No. 14 Cr. 491 (VSB), 2016 WL 9076234, at ■8 (S.D.N.Y. Feb. 4, 2016), aff'd 679 F. App'x 79 (2d Cir. 2017); see Forde, 740 F. Supp. 2d at 412. Sinc
in Counts One and Three and pursuant to Rule 404(b), there is no basis to strike the allegations regarding Minor Victim-3 from the Indictment. IX. The Defendant's Motion to Dismiss Count One or Count Three as Multiplicitous Is Premature The defendant moves to dismiss Counts One or Three on the ground that they are
States v. Chalmers, 474 F. Supp. 2d 555 (S.D.N.Y. 2007) 225, 226 United States v. Chambers, 800 F. App'x 43 (2d Cir. 2020) 69 United States v. Chan Lo, No. 14 Cr. 491 (VSB), 2016 WL 9076234 (S.D.N.Y. Feb. 4, 2016), aff'd. 679 F. App'x 79 (2d Cir. 2017) United States v. Chen, 378 F.3d 151 (2d Cir
ations set forth in Section 3283 applies to the crimes charged in Counts One through Four of the Indictment and her motion should be denied. III. The Defendant's Motion to Dismiss the Indictment Based on Alleged Improper Pre- Trial Delay Should Be Denied The defendant contends that the Indictment should be dismissed
tion and internal quotation marks omitted)). "The testimony need not have actually influenced, misled, or impeded the proceeding." United States v. Chan Lo, No. 14 Cr. 491 (VSB), 2016 WL 9076234, at ■8 (S.D.N.Y. Feb. 4, 2016), aff'd 679 F. App'x 79 (2d Cir. 2017); see Forde, 740 F. Supp. 2d at 412. Sinc
in Counts One and Three and pursuant to Rule 404(b), there is no basis to strike the allegations regarding Minor Victim-3 from the Indictment. IX. The Defendant's Motion to Dismiss Count One or Count Three as Multiplicitous Is Premature The defendant moves to dismiss Counts One or Three on the ground that they are
nited States v. Chalmers, 474 F. Supp. 2d 555 (S.D.N.Y. 2007) 150 United States v. Chambers, 800 F. App'x 43 (2d Cir. 2020) 48 United States v. Chan Lo, No. 14 Cr. 491 (VSB), 2016 WL 9076234 (S.D.N.Y. Feb. 4, 2016) 122 United States v. Chen, 378 F.3d 151 (2d Cir. 2004) 179 United States v. Cheu
limitations set forth in § 3283 applies to the crimes charged in Counts One through Four of the Indictment and her motion should be denied. III. The Defendant's Motion to Dismiss the Indictment Based on Alleged Improper Pre- Trial Delay Should Be Denied The defendant contends that the Indictment should be dismissed
tion and internal quotation marks omitted)). "The testimony need not have actually influenced, misled, or impeded the proceeding." United States v. Chan Lo, No. 14 Cr. 491 (VSB), 2016 WL 9076234, at ■8 (S.D.N.Y. Feb. 4, 2016), arid 679 F. App'x 79 (2d Cir. 2017); see Forde, 740 F.Supp.2d at 412. Since m
ree and pursuant to Rule 404(b), there is no basis to strike the allegations regarding Minor Victim-3 from the Indictment. 168 EFTA00095260 IX. The Defendant's Motion to Dismiss Count One or Count Three as Multiplicitous Is Premature The defendant moves to dismiss Counts One or Three on the ground that they are
States v. Chalmers, 474 F. Supp. 2d 555 (S.D.N.Y. 2007) 225, 226 United States v. Chambers, 800 F. App'x 43 (2d Cir. 2020) 69 United States v. Chan Lo, No. 14 Cr. 491 (VSB), 2016 WL 9076234 (S.D.N.Y. Feb. 4, 2016), aff'd. 679 F. App'x 79 (2d Cir. 2017) United States v. Chen, 378 F.3d 151 (2d Cir
ations set forth in Section 3283 applies to the crimes charged in Counts One through Four of the Indictment and her motion should be denied. III. The Defendant's Motion to Dismiss the Indictment Based on Alleged Improper Pre- Trial Delay Should Be Denied The defendant contends that the Indictment should be dismissed
tion and internal quotation marks omitted)). "The testimony need not have actually influenced, misled, or impeded the proceeding." United States v. Chan Lo, No. 14 Cr. 491 (VSB), 2016 WL 9076234, at *8 (S.D.N.Y. Feb. 4, 2016), aff'd 679 F. App'x 79 (2d Cir. 2017); see Forde, 740 F. Supp. 2d at 412. Sinc
in Counts One and Three and pursuant to Rule 404(b), there is no basis to strike the allegations regarding Minor Victim-3 from the Indictment. IX. The Defendant's Motion to Dismiss Count One or Count Three as Multiplicitous Is Premature The defendant moves to dismiss Counts One or Three on the ground that they are
Entities connected to both Chan Lo and The Defendant's Motion

United States
LOCATION
Anderson
PERSON
Figueroa
PERSONGreer
PERSONAmato
PERSON
Swanson
PERSONBenussi
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Eric Schmidt
PERSON
Butler
PERSON
Vickers
PERSONCanfield
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Napolitano
PERSONChuang
PERSONThe New York Daily News Article
ORGANIZATIONCromitie
PERSONDeFilippo
PERSONDewar
PERSONDiGregorio
PERSONMartin Weinberg
PERSONDorvee
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