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uld apply to cell site information obtained pursuant to a subpoena authorized by magistrate judge pursuant to 18 U.S.C. § 2703(d)); United States v. Ashburn, 76 F. Supp. 3d 401, 406, 414-18 (E.D.N.Y. 2014) (applying Leon to § 2703(d) orders for historical cell-site data obtained and finding that the goo
determining whether an indictment is in fact multiplicitous," and the record cannot be fully established until trial is complete. United States v. McCouny, 562 F.3d 458, 469 (2d Cir. 2009). Additionally, because double jeopardy is meant to protect a defendant from successive punishments for the same of
uld apply to cell site information obtained pursuant to a subpoena authorized by magistrate judge pursuant to 18 U.S.C. § 2703(d)); United States v. Ashburn, 76 F. Supp. 3d 401, 406, 414-18 (E.D.N.Y. 2014) (applying Leon to § 2703(d) orders for historical cell-site data obtained and finding that the goo
determining whether an indictment is in fact multiplicitous," and the record cannot be fully established until trial is complete. United States v. McCouny, 562 F.3d 458, 469 (2d Cir. 2009). Additionally, because double jeopardy is meant to protect a defendant from successive punishments for the same of
uld apply to cell site information obtained pursuant to a subpoena authorized by magistrate judge pursuant to 18 U.S.C. § 2703(d)); United States v. Ashburn, 76 F. Supp. 3d 401, 406, 414-18 (E.D.N.Y. 2014) (applying Leon to § 2703(d) orders for historical cell-site data obtained and finding that the goo
determining whether an indictment is in fact multiplicitous," and the record cannot be fully established until trial is complete. United States v. McCouny, 562 F.3d 458, 469 (2d Cir. 2009). Additionally, because double jeopardy is meant to protect a defendant from successive punishments for the same of
Entities connected to both Ashburn and McCouny

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Julie K. Brown
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George Mitchell
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