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In the Courts

By ALM Staff | Law Journal Newsletters |
June 28, 2011

Second Circuit Overturns Securities Fraud Conviction Of Former Credit Suisse Broker

On June 15, in United States v. Tzolov, No. 10-561-cr, the United States Court of Appeals for the Second Circuit, in an opinion authored by Circuit Judge Barrington D. Parker, reversed the substantive securities fraud conviction of former Credit Suisse Securities (USA) LLC (Credit Suisse) broker Eric Butler, on the grounds that Butler's passage through John F. Kennedy International Airport (JFK Airport) ' on his way to meet with investors ' was insufficient to establish proper venue in the Eastern District of New York, where he had previously been tried and convicted.

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