The following excerpt is from United States v. Rutigliano, 790 F.3d 389 (2nd Cir. 2015):
For an offense deemed to be continuing, venue may be proper in more than one location. See United States v. Kim, 246 F.3d 186, 191 (2d Cir.2001) (explaining that venue in a continuing offense is proper in any district in which the offense began, continued, or concluded). A conspiracy is a continuing offense in which venue is proper in any district in
[790 F.3d 396]
which an overt act in furtherance of the conspiracy was committed by any of the coconspirators. The defendant need not have been present in the district, as long as an overt act in furtherance of the conspiracy occurred there. United States v. Geibel, 369 F.3d 682, 696 (2d Cir.2004) (internal quotation marks omitted).
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