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n individual right and applies only where it results in appreciable deterrence." United States v. Eldred, 933 F.3d 110, 118 (2d Cir. 2019) (quoting Herring v. United States, 555 U.S. 135, 141 (2009)); see also Herring, 555 U.S. at 144 (concluding that "[t]o trigger the exclusionary rule, police conduct must be sufficie
t that the defendant "had not engaged in any business activity during the preceding six years").53 Accordingly, and consistent with the holdings in Ruiz and Broccolo, this Court should deny the severance motion. The defendant argues that the offenses are not connected because they involve different time periods.
n individual right and applies only where it results in appreciable deterrence." United States v. Eldred, 933 F.3d 110, 118 (2d Cir. 2019) (quoting Herring v. United States, 555 U.S. 135, 141 (2009)); see also Herring, 555 U.S. at 144 (concluding that "[t]o trigger the exclusionary rule, police conduct must be sufficie
t that the defendant "had not engaged in any business activity during the preceding six years").53 Accordingly, and consistent with the holdings in Ruiz and Broccolo, this Court should deny the severance motion. The defendant argues that the offenses are not connected because they involve different time periods.
n individual right and applies only where it results in appreciable deterrence." United States v. Eldred, 933 F.3d 110, 118 (2d Cir. 2019) (quoting Herring v. United States, 555 U.S. 135, 141 (2009)); see also Herring, 555 U.S. at 144 (concluding that "[t]o trigger the exclusionary rule, police conduct must be sufficie
rt that the defendant "had not engaged in any business activity during the preceding six years").54 Accordingly, and consistent with the holding in Ruiz and Broccolo, this Court should deny the severance motion. 54 While the defendant may argue that the fact that her deposition, unlike Ruiz, did not involve crim
n individual right and applies only where it results in appreciable deterrence." United States v. Eldred, 933 F.3d 110, 118 (2d Cir. 2019) (quoting Herring v. United States, 555 U.S. 135, 141 (2009)); see also Herring, 555 U.S. at 144 (concluding that "[t]o trigger the exclusionary rule, police conduct must be sufficie
t that the defendant "had not engaged in any business activity during the preceding six years").53 Accordingly, and consistent with the holdings in Ruiz and Broccolo, this Court should deny the severance motion. The defendant argues that the offenses are not connected because they involve different time periods.
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