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Ifelowo v. United States

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Appeal from the Superior Court of the District of Columbia (Hon. John H. Bayly, Jr., Trial Judge)

Argued June 13, 2000

In this case, appellant Babajide Ifelowo, who was convicted of several criminal offenses, *fn1 contends that the trial court (1) abused its discretion by failing to sever counts of the indictment relating to three separate events; (2) erred by: (a) limiting his cross-examination of a rebuttal witness with respect to credibility, while permitting the government to bolster the witness’s credibility during closing argument; and (b) failing to give the complete standard instruction regarding witness immunity. We affirm the trial court’s judgment of convictions. We hold that the combination of consistent features of each of the three robberies outweighed the variations, and that any striking differences were cured by the rebuttal testimony of the other robber, Shotikare, who implicated Ifelowo in all three incidents. We summarily dispose of Ifelowo’s other arguments.

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