That Nexus to a Pending Proceeding Requirement does not Extend to Klein Conspiracies In United States v. Flynn, 969 F.3d 873 (8th Cir.), reh g and reh g en banc denied (8th Cir. Sep. 17, 2020), the Eighth Circuit held, inter alia, that the nexus requirement of Marinello does not extend to Klein conspiracies. During 2006 and 2008, Scott Phillip Flynn ( Flynn ) assisted in two reverse-merger transactions. As payment, he received shares of stock in the resulting public companies. Flynn tra.
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