The following excerpt is from United States v. Bonventre, No. 14-4714-cr(L), No. 14-4715-cr(Con), No. 14-4716-cr(Con), No. 14-4719-cr(Con), No. 15-50-cr(Con) (2nd Cir. 2016):
1. Although the parties appear to agree that Rule 8(b)and not Rule 8(a)governs joinder of offenses in multi-defendant trials, we have yet to resolve the matter. See United States v. Shellef, 507 F.3d 82, 97 n.12 (2d Cir. 2007). Nor must we do so here, insofar as joinder was proper under either standard.
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