cell, 18 Cr. 081 (DLC); and the charge of the Hon. P. Kevin Castel in United States v. William Walters, 16 Cr. 338 (PKC). See also United States v. Khalupsky, 5 F.4th 279 (2d Cir. 2021) ("The government bears the burden of proving appropriate venue on each count, as to each defendant, by a preponderance

trial, and where the variance is not such as to deprive the accused of his right to be protected against another prosecution for the same offense." Khalupsky, 5 F.4th at 294 (quoting Sahnonese, 352 F.3d at 621-22). Moreover, when a defendant has sufficient notice of the Government's theory at trial, she c