The following excerpt is from United States v. Galpin, 720 F.3d 436 (2nd Cir. 2013):
We have not previously prescribed how the severance analysis is to be conducted. We do so now, adopting the step-by-step methodology for warrant redaction that was established in United States v. Sells, 463 F.3d 1148 (10th Cir.2006). First, the court must separate the warrant into its constituent clauses. Id. at 1155;see also United States v. Christine, 687 F.2d 749, 754 (3d Cir.1982). Second, the court must examine each individual clause to determine whether it is sufficiently
[720 F.3d 449]
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