What is the test for breaching section 1512 of the Criminal Code with intent to conceal or conceal an object in the context of a proceeding before a federal grand jury?

Section 1512 makes it illegal to "corruptly" "conceal[]" or attempt to conceal an "object" with the "intent to impair the object's integrity or availability for use in an official proceeding." 18 U.S.C. 1512(c)(1). A "proceeding before . . . a Federal grand jury" is an "official proceeding." Id. 1515(a)(1)(A). To prove a violation of section 1512, "the government must show that there was a nexus between the defendant's conduct and the pending, or foreseeable, official proceeding." United States v. Pugh, 945 F.3d 9, 21 (2d Cir. 2019) (internal quotation marks omitted).

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