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Case 1:20-cr-00330-PAE Document 410-1 Filed 11/04/21 Page 72 of 93 Venue [Tf requested by defense] With respect to each of the counts in the indictment, you must also consider the issue of venue, namely, whether any act in furtherance of the unlawful activity charged in that count occurred within the Southern District of New York. The Southern District of New York encompasses the following counties: New York County (i¢., Manhattan), Bronx, Westchester, Rockland, Putnam, Dutchess, Orange and Sullivan Counties. Anything that occurs in any of those places occurs in the Southem District of New York. Venue must be examined separately for each count in the Indictment. Venue on one count does not establish venue on another count, though if applicable, you may rely on the same evidence to establish venue on multiple counts. Commented [CE88]: This language is unnecessary and unfairly highlights the government’s theory of the case It is issue See United States v. Pizarro, 17 Cr 151 (AJN) 72 DOJ-OGR- 00006138