The following excerpt is from United States v. Kloszewski, 17-4054 (2nd Cir. 2019):
We review de novo a challenge to the district court's ruling regarding venue. United States v. Lange, 834 F.3d 58, 69 (2d Cir. 2016). "The Government bears the burden of proving venue by a preponderance of the evidence." Id. "Where the Government has prevailed at trial, we review the sufficiency of the evidence as to venue in the light most favorable to the Government, crediting every inference that could have been drawn in its favor." Id. (internal quotation marks omitted).
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