Motion to Adopt Co-Defendant's Motion for Additional Peremptory Strikes — United States v. Macaulay

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Defendant Macaulay's Motion to Adopt, Join, and Conform Co-Defendant Rahbar's Motion for Additional Peremptory Strikes, Case No. 24-cr-180-PTG-2, Document 97, filed March 31, 2025, in the United States District Court for the Eastern District of Virginia. Ryan Macaulay, through undersigned counsel, asks the Court to allow him to adopt Defendant Rahbar's Motion for Additional Peremptory Strikes (Dkt. No. 95). The motion states that facts and legal arguments in motions filed by his co-defendant are equally relevant to his case and that separate motions would largely mirror those already filed. A certificate of service is dated the 31st day of March, 2025.

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Case 1:24-cr-00180-PTG          Document 97          Filed 03/31/25    Page 1 of 2 PageID# 563




                         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 MOTION FOR ADDITIONAL PEREMPTORY STRIKES

       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 97         Filed 03/31/25    Page 2 of 2 PageID# 564




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 Motion for Additional Peremptory Strikes. See Dkt. No. 95.

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

motion to adopt, join, and conform the motions 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 31st day of March, 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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