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U.S. v. Valentin

Trial Severance Under Rule 14 Is Denied; Evidence May Overlap But Must Be Considered Alone

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MEMORANDUM AND ORDER Defendant Gregory Bruce moved to sever his trial from that of his codefendants under Federal Rules of Criminal Procedure 8(b) and 14. See Gregory Bruce Mot. to Sever (Dkt. #98). The Court granted severance based upon improper joinder under Rule 8 without reaching Gregory Bruce’s arguments that Rule 14 also required severance. See Mem. & Order (Dkt. #118). A grand jury then returned a fourth superseding indictment that cured the defect that formed the basis for severance under Rule 8. See Fourth Superseding Indictment (Dkt. #126). With the consent of the parties, the Court construes Gregory Bruce’s previously filed motion for severance under Rule 14 as directed against the fourth superseding indictment. See Nov. 5, 2024 Min. Entry & Order. The motion for severance under Rule 14 is denied. BACKGROUND The fourth superseding indictment in this case alleges a kidnapping conspiracy and related offenses, with Gregory Bruce charged only in an obstruction count. In Count One, defendants Lesly Valentin, Aasim Boone, and Jarrett Bruce are charged with kidnapping conspiracy in violation of 18 U.S.C. §1201(c). Fourth Superseding Indictment

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