defendant, terms that provide identifying information about the non-declarant co-defendant, or terms that quantify the number of people involved in the specific conduct. Substitutions can include neutral pronouns or identifiers such as “someone,” “guy(s),” “individual(s),” “person,” “people,” “another person,” or “others.” See Order, ECF #462, at 2-3 (May 1, 2009). The Court also directed the government to ensure that the redacted statements did not create an “inevitable association” with a particular defendant when the statement is viewed with other evidence, recognizing that a redacted statement may, in some circumstances, give rise to an immediate and direct inference of a particular defendant’s involvement. See United States v. Washington, 952 F.2d 1402, 1406-07 (D.C.Cir.1991) (<HOLDING>) (emphasis added). All of these rulings were
holding that where a defendants name is replaced with a neutral pronoun as long as identification of the defendant is clear or inculpatory only by reference to evidence other than the redacted confession and a limiting instruction is given to the jury there is no bruton violation holding that when all references to the defendant in a codefendants statement are replaced with indefinite pronouns or other general terms the confrontation clause is not violated by the redacted statements admission if when viewed together with other evidence the statement does not create an inevitable association with the defendant and a proper limiting instruction is given holding that the clause was not violated by a redacted confession with a proper limiting instruction holding that the fact that a redacted statement may have inferentially incriminated   the defendant when read in context with other evidence does not create a bruton violation holding that admission of statement with references to we or they which did not directly implicate defendant did not violate defendants confrontation rights