DC Circuit: USA v. Gregory Sitzmann

Consideration of extraterritorial conduct did not violate the presumption against extraterritoriality, given the domestic elements of the conspiracy.

Assuming manufactured venue is a thing, agents' instructions to wire funds to DC was not an impermissible creation of venue.

As venue was not objected to prior to the close of the prosecutions case in chief, no error in court's holding that it was not an issue for the finder of fact.

No Brady claim in late release of co-conspirator's grand jury testimony, as insufficiently exculpatory.

Purportedly false evidence presented insufficiently prejudicial.

Introduction of co-conspirator's guilty plea not plain error, as insufficiently prejudicial.

No ineffective assistance.

https://www.cadc.uscourts.gov/internet/opinions.nsf/38541443F92BCBB4852582BB00514136/$file/15-3074.pdf