Whether it is constitutional to extend 18 U.S.C. § 2423(c) to noncommercial conduct allegedly committed by a foreign citizen and resident against other foreign citizens entirely within a foreign country

QUESTIONS PRESENTED I. Whether it is constitutional to extend 18 U.S.C. § 2423(c) to noncommercial conduct allegedly committed by a foreign citizen and resident against other foreign citizens entirely within a foreign country. II. Whether a defendant’s exercise of his right to counsel of choice by timely requesting to substitute retained counsel may be circumscribed by the factors implicated in a request to substitute appointed counsel, or instead whether the right to retained counsel of choice must be honored in the absence of compelling justification. ii STATEMENT OF RELATED CASES ¢ United States of America v. Abramov, No. 2:14-cr00241-ODW-1, U.S. District Court for the Central District of California. Judgment Entered March 14, 2016. e United States of America v. Abramov, No. 1650104, United States Court of Appeals for the Ninth Circuit. Judgment Entered November 7, 2018. Petition for Rehearing Denied March 29, 2019.