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Motion to Adopt, Join, and Conform Omnibus Motion in Limine — United States v. Macaulay

Summary

Defendant Macaulay's Motion to Adopt, Join, and Conform Co-Defendant Rahbar's Omnibus Motion in Limine, Case No. 24-cr-180-PTG-2, Document 104, filed April 8, 2025, in the United States District Court for the Eastern District of Virginia. Ryan Macaulay, by and through undersigned counsel, moves to adopt, join, and conform to motions filed by his co-defendant insofar as they may relate to him. The motion states that requiring separate motions on the same issues would result in redundant and inefficient use of time and resources. It asks the Court to allow him to adopt Defendant Rahbar's Omnibus Motion in Limine (Dkt. No. 102). The signature block names David Benowitz and Rammy G. Barbari as counsel for Ryan Macaulay.

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“Motion to Adopt, Join, and Conform Omnibus Motion in Limine — United States v. Macaulay.” Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/gov-uscourts-vaed-558615-104-0-49c59832a3/, SHA-256 8fc055047bb53a8d6e21787e98bcef6d7b074bf6e78b8290c654c5fefc73ed88.

Full text

Case 1:24-cr-00180-PTG          Document 104            Filed 04/08/25   Page 1 of 2 PageID# 623




                            ‭UNITED STATES DISTRICT COURT‬
                       ‭FOR THE EASTERN DISTRICT OF VIRGINIA‬

                                      ‭)‬
‭UNITED STATES‬                        ‭)‬
                                        ‭)‬
        ‭v.‬                             ‭)‬
                                          ‭)‬            ‭Case No. 24-cr-180-PTG-2‬
‭RYAN MACAULAY‬                            ‭)‬
         ‭Defendant‬                        ‭)‬
 ‭____________________________________)‬

      ‭DEFENDANT MACAULAY’S MOTION TO ADOPT, JOIN, AND CONFORM‬
           ‭CO-DEFENDANT RAHBAR’S OMNIBUS MOTION IN LIMINE‬

       ‭Ryan Macaulay, by and through undersigned counsel, respectfully moves to adopt, join,‬

‭and conform to specific motions, petitions, and other applications for relief that have been filed‬

‭by or on behalf of his co-defendant in this case, insofar as they may relate to him.‬

       ‭As such, facts that are contained in the motions filed by Mr. Macaulay’s co-defendant are‬

‭equally relevant and applicable to his case in this prosecution. The legal arguments and‬

‭authorities outlined in those motions are essentially the same that Mr. Macaulay would have‬

‭raised had he filed separate motions. Requiring Mr. Macaulay to prepare and file individual‬

‭motions addressing the same issues would result in redundant and inefficient use of time and‬

‭resources, as the motions would largely mirror those already filed by his co-defendant.‬

       ‭Motions to adopt, join, and conform are a practical and efficient way to address legal‬

‭issues common to multiple defendants in a multi-defendant case. Permitting a defendant to‬

‭adopt, join, or conform to motions filed by a co-defendant eliminates unnecessary duplication of‬

‭effort when the legal and factual issues overlap. Courts routinely grant motions to adopt, join, or‬

‭conform where such overlap exists, recognizing the efficiency of addressing shared issues in a‬

‭unified manner. See, e.g.,‬‭United States v. Cawthorn‬‭,‬‭2023 U.S. Dist. LEXIS 96352, *2-3 (D.‬

‭Md. 2023);‬‭United States v. Fawley‬‭, 2012 U.S. Dist.‬‭LEXIS 68649, *4-5 (N.D. W.Va. 2012);‬

                                                  ‭1‬
Case 1:24-cr-00180-PTG         Document 104             Filed 04/08/25    Page 2 of 2 PageID# 624




‭United States v. Kloptoski‬‭, 2010 U.S. Dist. LEXIS 1291, *12 (M.D. Pa. 2010)‬‭.‬‭Such motions‬

‭conserve judicial and party resources by avoiding the filing of duplicative motions and ensuring‬

‭consistent legal arguments across related defendants.‬

       ‭Mr. Macaulay respectfully requests this Court allow him to adopt the following‬

‭co-defendant motion previously filed in this matter:‬

       ‭1.‬ ‭Defendant Rahbar’s Omnibus Motion in Limine.‬‭See‬‭Dkt.‬‭No. 102.‬

       ‭For the foregoing reasons, Ryan Macaulay respectfully requests that the Court grant this‬

‭motion to adopt, join, and conform the motion delineated herein.‬


                                                         ‭Respectfully submitted,‬


                                                         ‭__________/s/___________________‬
                                                          ‭David Benowitz‬
                                                           ‭VSB # 91194‬
                                                            ‭Rammy G. Barbari‬
                                                             ‭VSB # 88414‬
                                                              ‭Price Benowitz LLP‬
                                                               ‭409 7th Street, NW‬‭,‬‭Suite 200‬
                                                                ‭Washington, D.C. 20004‬
                                                                 ‭Tel: 202-271-5249‬
                                                                  ‭Tel: 202-870-0139‬
                                                                   ‭Fax: 202-664-1331‬
                                                                    ‭david@pricebenowitz.com‬
                                                                     ‭rammy@pricebenowitz.com‬

                                                         ‭Counsel for Ryan Macaulay‬


                                 ‭CERTIFICATE OF SERVICE‬

       ‭I hereby certify that on this 8th day of April, 2025, a true and correct copy of the‬

‭foregoing Defendant’s Motion has been served via CM/ECF to all parties in this matter.‬


                                                         ‭__________/s/___________________‬
                                                          ‭David Benowitz‬

                                                  ‭2‬


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