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nt to the charge, then regardless of how prejudicial the language is, it may not be stricken."' Id. (brackets in original) (quoting United States v. DePalma, 461 F. Supp. 778, 797 (S.D.N.Y. 1978)); see also United States v. Mulder, 273 F.3d 91, 99 (2d Cir. 2001). "This standard is an exacting one, and 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 ofcell phone location records," which
nt to the charge, then regardless of how prejudicial the language is, it may not be stricken."' Id. (brackets in original) (quoting United States v. DePalma, 461 F. Supp. 778, 797 (S.D.N.Y. 1978)); see also United States v. Mulder, 273 F.3d 91, 99 (2d Cir. 2001). "This standard is an exacting one, and 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
nt to the charge, then regardless of how prejudicial the language is, it may not be stricken."' Id. (brackets in original) (quoting United States v. DePalma, 461 F. Supp. 778, 797 (S.D.N.Y. 1978)); see also United States v. Mulder, 273 F.3d 91, 99 (2d Cir. 2001). "This standard is an exacting one, and 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
ant to the charge, then regardless of how prejudicial the language is, it may not be stricken." Id. (brackets in original) (quoting United States v. DePalma, 461 F. Supp. 778, 797 (S.D.N.Y. 1978)); see also United States v. Mulder, 273 F.3d 91, 99 (2d Cir. 2001). "This standard is an exacting one, and 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
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