6 F.3d 924, *; 1993 U.S. App. LEXIS 26472, **;
37 Fed. R. Evid. Serv. (Callaghan) 1148; 127 A.L.R. Fed. 599

 
UNITED STATES OF AMERICA, Appellee, v. FRANK LOCASCIO, and JOHN GOTTI, Defendants-Appellants.

Docket Nos. 92-1382, 92-1384, 92-1671, 93-1181

UNITED STATES COURT OF APPEALS FOR THE SECOND CIRCUIT

6 F.3d 924; 1993 U.S. App. LEXIS 26472; 37 Fed. R. Evid. Serv. (Callaghan) 1148; 127 A.L.R. Fed. 599

  
June 17, 1993, Argued   
October 8, 1993, Decided

SUBSEQUENT HISTORY:  [**1]  As Amended October 22, 1993. Certiorari Denied May 2, 1994, Reported at: 1994 U.S. LEXIS 3353.

PRIOR HISTORY: Appeal from judgment entered in the United States District Court for the Eastern District of New York (Glasser, J.) convicting defendants after jury trial for substantive and conspiracy violations of the Racketeer Influenced Corrupt Organizations Act ("RICO"), 18 U.S.C. § 1962(c) and (d) (1988), and judgment denying defendants' motion for a new trial and renewed motion for a new trial pursuant to Fed. R. Crim. P. 33.

DISPOSITION: Affirmed.

 
CASE SUMMARY

 
PROCEDURAL POSTURE: Defendants appealed from the judgments of conviction of the United States District Court for the Eastern District of New York which found them guilty of substantive and conspiracy violations of the Racketeer Influenced Corrupt Organizations Act, 18 U.S.C.S. § 1962(c) and (d), and various predicate acts charged as separate counts.

 
OVERVIEW: Defendants were found guilty of substantive and conspiracy violations of the Racketeer Influenced Corrupt Organizations Act (RICO), 18 U.S.C.S. § 1962(c) and (d), for unlawfully conducting and participating in the affairs of a criminal enterprise through a pattern of racketeering activity. Their motions for a new trial were denied. The motions that were the subject of this appeal included: the government's successful motion to sequester an anonymous jury; the government's successful motion to disqualify counsel for both defendants for various conflicts of interest; and one defendant's motion to sever his trial. After review, the court concluded that the district court properly exercised its discretion in determining that defendants' counsel should be disqualified, the jury instructions were proper, sequestration was not error, and that denial of one defendant's motion to sever was not erroneous. Further, the district court did not abuse its discretion in denying the motions for a new trial. The district court's judgment was affirmed.

 
OUTCOME: The court affirmed the judgments of conviction of the district court which found defendants guilty of substantive and conspiracy violations of the Racketeer Influenced Corrupt Organizations Act and various predicate acts. The court held that the district court properly disqualified defendants' counsel for conflicts of interest, properly denied one defendant's motions to sever his trial, and properly sequestered an anonymous jury.

CORE TERMS: conspiracy, disqualification, murder, racketeering, defendants-appellants, organized crime, expert testimony, new trial, indictment, mere presence, prosecutor, tape, unsworn, juror, conversation, motive, house counsel, apartment, short-hand, sequestration, convicted, involvement, membership, predicate, Sixth Amendment, conspiracy to murder, fair trial, disqualified, instructing, cross examination

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COUNSEL: JOHN GLEESON, JAMES ORENSTEIN, Assistant United States Attorneys, New York, New York (Mary Jo White, United States Attorney, Eastern District of New York, New York, New York; David C. James, Assistant United States Attorney, Eastern District of New York, New York, New York, of counsel), for Appellee.
 
CHARLES OGLETREE, Boston, Massachusetts (Ephraim Margolin, Margolin, Arguimbau & Battson, San Francisco, California, of counsel), for Defendant-Appellant John Gotti.
 
MICHAEL E. TIGAR, Austin, Texas (Dennis P. Riordan, Riordan & Rosenthal, San Francisco, California, Michael Kennedy, Michael Kennedy, P.C., New York, New York, of counsel) for Defendant-Appellant Frank Locascio.

JUDGES: Before: KEARSE, MINER, and ALTIMARI, Circuit [**2]  Judges. Judge Kearse concurs in a separate opinion.

OPINIONBY: ALTIMARI

OPINION:
 
 [*929]  ALTIMARI, Circuit Judge:

Defendants-appellants John Gotti and Frank Locascio appeal from judgments of conviction entered on June 23, 1992 in the United States District Court for the Eastern District of New York (Glasser, J.). They also appeal from the district court's October 30, 1992 order denying their motion for a new trial and a subsequent denial of a renewed motion for a new trial.

Gotti and Locascio were convicted after a jury trial of substantive and conspiracy violations of the Racketeer Influenced Corrupt Organizations Act, 18 U.S.C. § 1962(c) and (d) (1988), and various predicate acts charged as separate counts. They were each principally sentenced to life imprisonment. The charges stemmed from their involvement with the Gambino Crime Family of La Cosa Nostra, an extensive criminal organization.

On appeal, Gotti and Locascio raise numerous challenges to their convictions and the subsequent denial of their motion for a new trial. For the reasons stated below, we affirm the judgments of the district court.

BACKGROUND

On July 18, 1991, a grand jury in the Eastern District [**3]  of New York returned a thirteen count superseding indictment against Gotti and Locascio. The indictment also named two other defendants, Salvatore Gravano and Thomas Gambino, who are not parties to this appeal. All four defendants were charged with violating the Racketeer Influenced and Corrupt Organizations Act ("RICO"), 18 U.S.C. § 1962(c)-(d) (1988), for unlawfully conducting and participating in the affairs of a criminal enterprise through a pattern of racketeering activity. The charged enterprise was the Gambino Organized Crime Family of La Cosa Nostra ("the Gambinos," "The Gambino Family," or "the Gambino Crime Family"). Gotti was charged as the head of the organization, and Locascio was accused of being the "underboss," or second-in-command.

Gravano was charged as the "consigliere," or advisor, to Gotti. Following the indictment, Gravano pleaded guilty to a superseding racketeering charge and testified at length at trial against Gotti and Locascio. The charges against Gambino, a "captain" in the organization, were severed.

Counts One and Two of the indictment charged Gotti and Locascio with the substantive and conspiracy violations of RICO.  [**4]  Many of the crimes charged as racketeering acts in the RICO counts were also the basis of separate counts in the indictment. Gotti was charged with the following predicate acts: the conspiracy to murder and the murder of Paul Castellano; the murder of Thomas Bilotti; the conspiracy to murder and the murder of Robert DiBernardo; the conspiracy to murder and the murder of Liborio Milito; and obstruction of justice at the Thomas Gambino trial. Gotti and Locascio were both charged with the following predicate acts: the conspiracy to murder and the murder of Louis DiBono; the conspiracy to murder Gaetano Vastola; conducting an illegal gambling business in Queens, New York; conducting an illegal gambling business in Connecticut; conspiracy to make extortionate extensions of credit; and obstruction of justice in the investigation of the Castellano murder. Gotti and Locascio were also  [*930]  charged in separate counts for a conspiracy to obstruct grand jury investigations, bribery of a public servant, and a conspiracy to defraud the United States.

Gotti and Locascio were tried before a sequestered anonymous jury in the United States District Court for the Eastern District of New York (Glasser,  [**5]  J.). Prior to trial, there were numerous government and defense motions, most of which need not be recounted at length. The motions that are the subject of this appeal included: the government's successful motion to sequester an anonymous jury; the government's successful motion to disqualify counsel for both Gotti and Locascio for various conflicts of interest; and Locascio's unsuccessful motion to sever his trial from Gotti's.

Trial began in February 1992. The government's proof to support the allegations that Gotti and Locascio had been in command of an extensive criminal enterprise was comprised mostly of lawfully intercepted tape-recorded conversations of the defendants-appellants and other alleged members of the Gambino Family. The government introduced tape recordings from four different locations over an eight-year period.

The most significant evidence consisted of conversations intercepted at 247 Mulberry Street in New York during the period from late 1989 until early 1990. The government had installed three listening devices in that building: in the Ravenite Social Club on the first floor, in a hallway behind the club's rear door, and in an apartment two stories above [**6]  the club ("the Ravenite Apartment"). It was this last location that proved the most fruitful for the government, and the most damaging for the defendants-appellants. In the discussions in the Ravenite Apartment, Gotti, Locascio, and other Gambino Family members discussed various illegal acts. These discussions formed the core of the proof against the defendants-appellants at trial. Another major source of evidence was the testimony of Salvatore Gravano, who cooperated with the government following the indictment. As a high-level insider in the Gambino Family, Gravano's testimony was especially damaging. The tape recordings, combined with Gravano's testimony, presented to the jury a picture of a large-scale enterprise involved in various criminal activities. The jury heard evidence on the structure and inner workings of the Gambino Family, and learned of the miscellaneous crimes with which Gotti and Locascio were charged: murders, obstruction of legal proceedings, conspiracies, gambling operations, and loansharking activities. It is unnecessary to recount the evidence in detail at this point, since much of it is unnecessary for full understanding of the issues on appeal.

Following  [**7]  a six-week trial, the jury found Gotti guilty of all charges in the indictment. Locascio was found guilty of all charges except the count relating to a gambling operation in Queens, New York. Each defendant-appellant was sentenced by the district court to life in prison on the RICO and murder counts, and the statutory maximum prison terms on all remaining counts, with all sentences to run concurrently. The court also imposed five years of supervised release, a $ 250,000 fine on each defendant, and mandatory special assessments.

Several months after sentencing, government attorneys discovered previously undiscovered reports that potentially pertained to Gravano's credibility. The government turned over those reports to the defendants-appellants, who subsequently moved for a new trial pursuant to Fed. R. Crim. P. 33, on the ground that the government had not disclosed relevant evidence under Brady v. Maryland, 373 U.S. 83, 10 L. Ed. 2d 215, 83 S. Ct. 1194 (1963). This motion and a later renewed motion were both denied by the district court.

On appeal, Gotti and Locascio raise myriad challenges to their convictions and to the subsequent denial of their new trial motions. They contend that [**8]  the district court erred in: (1) disqualifying counsel for both Gotti and Locascio for conflicts of interest; (2) allowing certain government expert testimony; (3) instructing the jury; (4) allowing evidence of other crimes that were inadmissible against them; (5) impanelling an anonymous sequestered jury; (6) refusing to sever Locascio's trial; and (7) denying a motion for a new  [*931]  trial based on the government's suppression of material relating to Gravano's credibility. The defendants-appellants also argue that they were denied a fair trial based on the government's suppression of exculpatory evidence and prosecutorial misconduct.

For the following reasons, we affirm the judgment of the district court.
 
I. Disqualification of Counsel
 
Prior to trial, the district court disqualified attorneys for both Gotti and Locascio. Gotti and Locascio now contend that these disqualifications were unwarranted and violated their Sixth Amendment rights.
 
A. Applicable Law
 
The Sixth Amendment to the Constitution provides that "in all criminal prosecutions, the accused shall enjoy the right . . . to have the Assistance of Counsel for his defence." U.S. Const. amend. VI. The accused, however,  [**9]  does not have the absolute right to counsel of her own choosing. See Wheat v. United States, 486 U.S. 153, 159, 100 L. Ed. 2d 140, 108 S. Ct. 1692 (1988). As the Court stated in Wheat,
while the right to select and be represented by one's preferred attorney is comprehended by the Sixth Amendment, the essential aim of the Amendment is to guarantee an effective advocate for each criminal defendant rather than to ensure that a defendant will inexorably be represented by the lawyer whom he prefers.

 
Id. Similarly, although a criminal defendant can waive her Sixth Amendment rights in some circumstances, that right to waiver is not absolute, since "federal courts have an independent interest in ensuring that criminal trials are conducted within the ethical standards of the profession and that legal proceedings appear fair to all who observe them." Id. at 160. The question of disqualification therefore implicates not only the Sixth Amendment right of the accused, but also the interests of the courts in preserving the integrity of the process and the government's interests in ensuring a just verdict and a fair trial. See id.

In deciding a motion [**10]  for disqualification, the district court recognizes a presumption in favor of the accused's chosen counsel, although this presumption can be overcome by a showing of an actual conflict or potentially serious conflict. See id. at 164; United States ex rel. Stewart v. Kelly, 870 F.2d 854, 856 (2d Cir. 1989). We accord the district court's decision to disqualify an attorney "substantial latitude," and review the decision only for an abuse of discretion. Wheat, 486 U.S. at 163-64.
 
There are many situations in which a district court can determine that disqualification of counsel is necessary. The most typical is where the district court finds a potential or actual conflict in the chosen attorney's representation of the accused, either in a multiple representation situation, see Wheat, 486 U.S. at 159-60; United States v. DiTommaso, 817 F.2d 201, 219 (2d Cir. 1987); United States v. Curcio, 680 F.2d 881, 886 (2d Cir. 1982), or because of the counsel's prior representation of a witness or co-defendant,  [**11]  see Stewart, 870 F.2d at 856-57. Courts have also considered disqualification where the chosen counsel is implicated in the allegations against the accused and could become an unsworn witness for the accused, see United States v. Arrington, 867 F.2d 122, 129 (2d Cir.), cert. denied, 493 U.S. 817 (1989); United States v. Kwang Fu Peng, 766 F.2d 82, 87 (2d Cir. 1985), or where the chosen counsel is somehow unable to serve without unreasonable delay or inconvenience in completing the trial, see United States v. Scopo, 861 F.2d 339, 344 (2d Cir. 1988), cert. denied, 490 U.S. 1048, 104 L. Ed. 2d 426, 109 S. Ct. 1957 (1989).

In this case, the government moved to disqualify attorneys for both Gotti and Locascio on multiple theories. We consider each of the defendants-appellants in turn.
 
B. Gotti
 
1. Background

Bruce Cutler served as Gotti's attorney in previous criminal trials in federal court. Prior to trial, the government moved to disqualify  [*932]  Cutler from acting as Gotti's attorney. Although the motion also dealt with the disqualification [**12]  of other Gotti attorneys, only the disqualification of Cutler has been challenged on appeal.

The district court granted the motion to disqualify on several grounds. United States v. Gotti, 771 F. Supp. 552 (E.D.N.Y. 1991). Judge Glasser, in a thoughtful and well-reasoned opinion, found that Cutler had acted as "house counsel" to the Gambino Crime Family by receiving "benefactor payments" from Gotti to represent others in the criminal enterprise. Id. at 560. The district court based this conclusion on excerpts from the government's taped transcripts, which left "little doubt that Gotti paid significant sums of money for legal services rendered to others." Id.

The district court further determined that Cutler's participation in government-taped conversations at which illegal activity was discussed would impair his representation of Gotti. Id. at 562-63. Specifically, the court noted that Cutler's mere presence at trial could make him an "unsworn witness" before the jury in explaining his own conduct and interpreting Gotti's conversations on the tapes. Id. at 563. [**13]  Even if Gotti waived the conflict, and even if the government did not intend to call Cutler as a witness, the district court found that Cutler's representation would still compromise the integrity of the proceeding. Id.

Third, the district court found that Cutler's prior representation of Michael Coiro, a potential government witness, gave rise to a conflict of interest. Id. The court reasoned that this conflict mandated disqualification both because Cutler was privy to events surrounding an obstruction charge, and because Cutler's cross examination of Coiro at trial would be circumscribed by the prior representation. Id. at 563-65.

Finally, the district court also found disqualification warranted because of the implication by Gotti in taped conversations that he had paid Cutler money "under the table." Id. at 565. This made Cutler a potential accomplice as well as a potential witness to Gotti's tax fraud.

In conclusion, the district court noted that it was mindful that disqualification is a drastic remedy for conflict problems, but that no less severe alternatives were viable. Id. at 566. [**14]  The court therefore held that "the grave peril the continued representation by [Cutler] poses to the integrity of the trial process" mandated disqualification. Id.

Gotti now appeals the district court's ruling, arguing that the disqualification was an abuse of discretion. We disagree, and affirm the disqualification on two grounds: (1) Cutler's role as house counsel to the Gambino Crime Family; and (2) Cutler's anticipated role as an "unsworn witness" for Gotti had he been allowed to serve. We note that, importantly, Gotti does not challenge the effectiveness of his replacement trial counsel. Although the government cannot justify an otherwise unwarranted disqualification by arguing that the disqualification did not result in the accused receiving ineffective assistance of counsel, see United States v. Diozzi, 807 F.2d 10, 16 (1st Cir. 1986), the fact that Gotti received more than competent representation is an additional consideration strongly supporting the district court's otherwise entirely correct ruling.
 
2. Cutler's Role as House Counsel
 
Gotti argues that the facts before the district court did not merit the conclusion that Cutler had [**15]  acted as "house counsel" to the Gambino Crime Family. Rather, Gotti argues that Cutler was merely his personal attorney.

Ethical considerations warn against an attorney accepting fees from someone other than her client. As we stated in a different context, the acceptance of such "benefactor payments" "may subject an attorney to undesirable outside influence" and raises an ethical question "as to whether the attorney's loyalties are with the client or the payor." In re Grand Jury Subpoena Served Upon John Doe, 781 F.2d 238, 248 n.6 (2d Cir. 1985) (in banc), cert. denied, 475 U.S. 1108, 89 L. Ed. 2d 913, 106 S. Ct. 1514 (1986). In this context, proof of house counsel can be used by the government to help establish the existence of the criminal enterprise under RICO, by showing the connections among  [*933]  the participants. See United States v. Simmons, 923 F.2d 934, 949 (2d Cir.) (holding that government can use evidence of benefactor payments to prove existence of enterprise), cert. denied, 114 L. Ed. 2d 104, 111 S. Ct. 2018 (1991); United States v. Castellano, 610 F. Supp. 1151 (S.D.N.Y. 1985) [**16]  (disqualifying attorney because attorney's acceptance of benefactor payments could be used to prove existence of enterprise).

Contrary to Gotti's assertions, there was sufficient evidence for the district court to determine that Cutler had acted as house counsel to the Gambino Crime Family. For example, the court cited one conversation in which Gotti, in the time-honored tradition of legal clients, complained about his legal fees:
I gave youse [sic] 300,000 in one year. Youse [sic] didn't defend me. I wasn't even mentioned in none of these [expletive deleted] things. I had nothing to do with none of these [expletive deleted] people. What the [expletive deleted] is your "beef?" . . . Before youse [sic] made a court appearance, youse [sic] got 40,000, 30,000 and 25,000. That's without counting [attorney] John Pollok. . . . You standing there in the hallway with me last night, and you're plucking me. . . . "Tony Lee's" lawyer, but you're plucking me. I'm paying for it. . . . Where does it end? Gambino Crime Family? This is the Shargel, Cutler and who do you call it Crime Family.

 
 771 F. Supp. at 555. Gotti thus demonstrated that he was incurring the [**17]  legal fees for representation of others. As support for disqualification, the government indicated that it would introduce the testimony of Michael Coiro, who would testify that he had paid nothing to Cutler and another attorney for their services to him, presumably because Gotti paid for his defense.

Cutler's role as house counsel to the Gambinos raised a credible issue of the ethical propriety of his representation of Gotti in this case. An attorney cannot properly serve two masters, and the evidence before the district court indicated that Cutler had represented the Gambino Family as a whole. Moreover, Cutler's status as house counsel was potentially part of the proof of the Gambino criminal enterprise. We cannot say that the district court abused its discretion in disqualifying Cutler on this basis, considering the volume of proof of Cutler's proximity to the affairs of the Gambino Crime Family offered by the government in this case.
 
3. Cutler's Role as an Unsworn Witness
 
An even stronger basis for disqualification, however, was the possibility that Cutler would function in his representational capacity as an unsworn witness for Gotti. An attorney acts as an unsworn witness [**18]  when his relationship to his client results in his having first-hand knowledge of the events presented at trial. If the attorney is in a position to be a witness, ethical codes may require him to withdraw his representation. See Model Code of Professional Responsibility DR 5-102(A) (1992).

Even if the attorney is not called, however, he can still be disqualified, since his performance as an advocate can be impaired by his relationship to the events in question. For example, the attorney may be constrained from making certain arguments on behalf of his client because of his own involvement, or may be tempted to minimize his own conduct at the expense of his client. Moreover, his role as advocate may give his client an unfair advantage, because the attorney can subtly impart to the jury his first-hand knowledge of the events without having to swear an oath or be subject to cross examination. See United States v. McKeon, 738 F.2d 26, 34-35 (2d Cir. 1984) (requiring disqualification where attorney would be essentially acting as both an advocate and a witness); United States v. Cunningham, 672 F.2d 1064, 1075 (2d Cir. 1982) [**19]  (upholding disqualification where an attorney would act as an unsworn witness for defendant); Castellano, 610 F. Supp. at 1167 (finding that attorney's appearance at counsel table would itself distort the factfinding process).

This is different from the situation in Wheat, since the conflict in Wheat -- multiple representation -- was a conflict inuring to the detriment of the accused. In such a case, waiver by the accused of the conflict can  [*934]  conceivably alleviate the constitutional defect, so long as the representation by counsel does not seriously compromise the integrity of the judicial process. When an attorney is an unsworn witness, however, the detriment is to the government, since the defendant gains an unfair advantage, and to the court, since the factfinding process is impaired. Waiver by the defendant is ineffective in curing the impropriety in such situations, since he is not the party prejudiced. See Cunningham, 672 F.2d at 1074-75.

The district court disqualified Cutler partially on the ground that his representation of Gotti would place him in the role of such an unsworn witness. The clearest support [**20]  for this finding was Cutler's presence during the Ravenite Apartment discussions taped by the government. The government was legitimately concerned that, when Cutler argued before the jury for a particular interpretation of the tapes, his interpretation would be given added credibility due to his presence in the room when the statements were made. This would have given Gotti an unfair advantage, since Cutler would not have had to take an oath in presenting his interpretation, but could merely frame it in the form of legal argument.

Gotti argues, however, that the district court erred in disqualifying Cutler where the government had no intention of calling Cutler. He also maintains that Cutler's presence and participation on the government's tapes could have been redacted to eliminate references to and statements by Cutler, thereby eliminating the unsworn witness problem. The first contention is meritless, since the district court explicitly and correctly noted that "whether the government will or will not call . . . Cutler . . . has no significance for this motion." 771 F. Supp. at 562. The second contention is equally unavailing, since the district court [**21]  explicitly found that redaction of the tapes would have eviscerated the government's case. We are not in a position to second-guess the district court's clearly supported factual findings on review. Moreover, we agree with the district court that the government's case should not be unfairly impaired so that an accused can continue with conflicted counsel.

The unsworn witness problem arises not only in relation to the Ravenite tapes, but to other grounds cited by the district court in support of disqualification. For example, the court found that Gotti's references to Cutler's acceptance of fees "under the table" were relevant to the government's case on the tax fraud count. Had Cutler argued Gotti's defense to that count, he would not only have had a conflict of interest but he would have been arguing as to events in which he was allegedly involved.

We are aware that disqualification is a drastic remedy to the unsworn witness problem. We are also, however, cognizant that this is an unusual case, in that Cutler had allegedly entangled himself to an extraordinary degree in the activities of the Gambino Crime Family: he is recorded on government tapes when discussions of allegedly illegal [**22]  activity took place; he is allegedly involved in the tax fraud count against Gotti; his role as house counsel could be used to prove the criminal enterprise; and his representation of government witnesses caused a conflict with his representation of Gotti. Although we are cognizant of the right of the accused to secure representation, we are also conscious of the institutional interest in protecting the integrity of the judicial process. If an attorney will not perform his ethical duty, it is up to the courts to perform it for him. Bruce Cutler had no place representing John Gotti in this case, and the district court properly determined that he should be disqualified.
 
C. Locascio
 
Locascio challenges the district court's disqualification of attorney George Santangelo, arguing that the district court abused its discretion in disqualifying Santangelo. Santangelo was disqualified for much the same reasons as Cutler: (1) because Santangelo was house counsel to the Gambino Crime Family; and (2) because Santangelo could conceivably become an unsworn witness if he represented Locascio.
 
1. Background
 
On January 6, 1992, thirteen months after Locascio's indictment, Santangelo [**23]  filed a notice  [*935]  of appearance on behalf of Locascio. The government quickly moved for disqualification. The motion was argued on January 17, 1992 and granted four days later. United States v. Gotti, 782 F. Supp. 737 (E.D.N.Y. 1992).

The district court began by reviewing the evidence presented by the government that Santangelo was house counsel to the Gambino Family. The court noted that Gravano was expected to testify that, after arraignment, Gotti had stated to him that Gotti was going to assign Santangelo to represent either Gravano or Locascio. Gravano was also expected to testify that Gotti controlled the actions of attorneys answerable to him, in the interests not of the individual clients but of the Gambino Family. The court found that this testimony would support the inference that Santangelo was "answerable to Gotti," which was probative of the charged RICO enterprise. The court also reviewed intercepted conversations presented by the government that supported Gravano's allegations that Gotti controlled Santangelo. The district court concluded:
Santangelo's relationship to Gotti and to Gotti's associates is properly the object of proof by  [**24]  the government in its case in chief. But, as with Cutler, . . . Santangelo cannot present himself as counsel for the defendants when his relationship to those defendants is itself an issue under the consideration of the jury. His presence at counsel table could readily serve as a signal to the jury that the court discounts the government's proof on this point -- that the court does not believe this evidence. Moreover, Santangelo could not argue against the existence of the charged RICO enterprise without becoming an unsworn witness.

 
 Id. at 741.
 
2. Discussion
 
We have already discussed the applicable law on the issue of counsel disqualification. See supra § I.A. Locascio offers the same arguments that we rejected in our discussion of the disqualification of Bruce Cutler. Simply put, Locascio recharacterizes the record and disagrees that the government proffered evidence to the district court that merits disqualification of Santangelo.

As in our discussion of Cutler's disqualification, we review the district court's rulings only for an abuse of discretion. Wheat, 486 U.S. at 163-64; Stewart, 870 F.2d at 856. [**25]  Here, the district court specifically found that Gravano's testimony and the intercepted conversations substantiated the argument that Santangelo was house counsel. This raised two serious conflicts of interest: first, that Santangelo's previous representations of Gambino Family members would be used to prove the existence of the enterprise; and second, that his loyalty to Locascio would be compromised by his relationship to Gotti. These findings were supported in the record, and Locascio's recharacterization of the record does not compel us to reverse them.

As discussed previously, Locascio's Sixth Amendment concerns are not the only interests at stake here: the district court has an independent duty to protect the integrity of the judicial process, and the government has its own fair trial interests that should not be unnecessarily impaired so that Locascio can enjoy the services of ethically compromised counsel. This is especially true in these circumstances, since Locascio suffered no prejudice from the disqualification of Santangelo. Although actual prejudice is not determinative of the propriety of a disqualification, it is worth noting that this is not a case where an attorney [**26]  worked on a case for months only to be disqualified on the eve of trial. Santangelo filed his first notice of appearance on January 6, 1992, and was disqualified fifteen days later. Locascio cannot argue this disqualification impacted his ability to prepare for trial.
 
D. Conclusion

Although disqualification is a drastic measure, the district court is in the best position to evaluate what is needed to ensure a fair trial. Here, the district court made careful findings of fact on each disqualification, and supported its decisions with well-reasoned opinions. We conclude that the district court properly exercised its discretion in disqualifying Bruce Cutler and George Santangelo.
 
 [*936]  II. Admission of Expert Testimony
 
Gotti and Locascio both contend that the district court committed reversible error in admitting the testimony of government experts to assist the jury in understanding the structure of organized crime families. More specifically, they principally challenge various facets of FBI Agent Lewis Schiliro's testimony, arguing that: (1) Schiliro's testimony was too broad and went beyond the scope of expert testimony; (2) he was not properly qualified as an expert; (3)  [**27]  his use of hearsay and un-introduced evidence to substantiate his opinions violated Fed. R. Evid. 703, as well as the Confrontation Clause; and (4) the availability of similar testimony by an accomplice witness rendered his testimony unnecessary.
 
A. Background
 
At trial, Special Agent Schiliro testified at great length on the nature and function of organized crime families, imparting the structure of such families and disclosing the "rules" of the La Cosa Nostra. For example, Schiliro testified that a "boss" must approve all illegal activity and especially all murders, and that the functions of the "consigliere" and "underboss" are only "advisory" to the "boss." In addition, as part of his testimony, he interpreted the numerous surreptitiously taped conversations introduced into evidence, and identified the individuals speaking by their voices. Schiliro specifically named John Gotti as the boss of the alleged Gambino Family and Gravano as the consigliere. Additionally, he identified, together with their titles, ranks, and functions, numerous members and associates of the Gambino Family and other criminal organizations. When pressed about his sources for individuals' titles,  [**28]  ranks, and functions, Schiliro admitted that his sources of information were not necessarily before the court.
 
B. Discussion

Under the Federal Rules of Evidence, an expert is permitted to testify in the form of an opinion or otherwise when that testimony would "assist the trier of fact to understand the evidence or to determine a fact in issue." Fed. R. Evid. 702. In determining whether such evidence will assist the jury, the district court must make a "'common sense inquiry'" into "'whether the untrained layman would be qualified to determine intelligently and to the best possible degree the particular issue without enlightenment from those having a specialized understanding of the subject involved in the dispute.'" Fed. R. Evid. 702, advisory committee note, (quoting Ladd, Expert Testimony, 5 Vand. L. Rev. 414, 418 (1952)), quoted in United States v. Onumonu, 967 F.2d 782, 788 (2d Cir. 1992). In applying this standard, the district court has broad discretion regarding the admission of expert testimony, and this Court will sustain the admission unless "manifestly erroneous." United States v. DiDomenico, 985 F.2d 1159, 1163 (2d Cir. 1993); [**29]  United States v. Rivera, 971 F.2d 876, 887 (2d Cir. 1992).

Gotti and Locascio contend that the district court erred in admitting Schiliro's testimony for several reasons. The thrust of their argument is that Schiliro did not actually testify as an expert, but rather was simply a conduit allowing inadmissible evidence and arguments to flow into the court. They assert that Schiliro's testimony was too broad, sweeping, and unsubstantiated to be admissible. We will consider their specific points in turn.
 
1. Challenge to Scope of Expert Testimony

The defendants-appellants challenge the admission of expert testimony on the inner workings of the Gambino Family as being outside the scope of expert testimony. We have, however, previously upheld the use of expert testimony to help explain the operation, structure, membership, and terminology of organized crime families. See United States v. Daly, 842 F.2d 1380, 1388 (2d Cir.), cert. denied, 488 U.S. 821 (1988); see also United States v. Skowronski, 968 F.2d 242, 246 (2d Cir. 1992) (upholding expert testimony of  [**30]  government agents explaining organized crime jargon); United States v. Tutino, 883 F.2d 1125, 1134 (2d Cir. 1989) (same), cert. denied, 493 U.S. 1081, 107 L. Ed. 2d 1044, 110 S. Ct. 1139 (1990); United States v. Ardito, 782 F.2d 358, 363  [*937]  (2d. Cir.) (same), cert. denied, 475 U.S. 1141 (1986); United States v. Gallo, 118 F.R.D. 316, 317-18 (E.D.N.Y. 1987) (FBI agents could testify as experts as to methods of operation of organized crime). Other circuits considering the issue are in agreement. See United States v. Pungitore, 910 F.2d 1084, 1148-49 (3d Cir. 1990) (upholding testimony of agent who testified about structure of organized crime families), cert. denied, 111 S. Ct. 2009 (1991); United States v. Angiulo, 847 F.2d 956, 973-75 (1st Cir.) (same), cert. denied, 488 U.S. 852 (1988).
 
In Daly, this Court confronted a similar claim that a district court committed reversible error in admitting expert testimony on the structure of organized crime [**31]  families. There, the government agent who testified "identified the five organized crime families that operate in the New York area; he described their requirements for membership, their rules of conduct and code of silence, and the meaning of certain jargon, . . . and he described how, in general, organized crime has infiltrated labor unions." 842 F.2d at 1388. Additionally, the expert identified voices on surveillance tapes. In sustaining the admission of such testimony, we explained that such expert testimony "was relevant to provide the jury with an understanding of the nature and structure of organized crime families." Id. We further added that there was "no question that there was much that was outside the expectable realm of knowledge of the average juror." Id.

We continue to believe that despite the unfortunate fact that our society has become increasingly familiar with organized crime and its activities from such sources as newspapers, movies, television, and books, it is still a reasonable assumption that jurors are not well versed in the structure and methods of organized crime families. Moreover, much of the information gleaned from such [**32]  sources may be inaccurate. Consequently, the subject matter of Agent Schiliro's testimony, namely the structure and operations of organized crime families, was properly admitted.
 
2. Schiliro's Qualifications as an Expert

The defendants-appellants argue that Schiliro was not properly qualified as an expert, since his testimony required knowledge of linguistics, the sociology of crime, tape recording technology, and voice analysis. Gotti and Locascio contend that because he was not an expert in any of those areas, he was not qualified to interpret tapes or give his opinion on the Gambino Family structure.

This argument ignores the fact that Schiliro had been an FBI agent for seventeen years, and for five years had been on the FBI's Organized Crime Program, a squad that investigated only organized crime cases. For more than two years, he was the supervisor of the Organized Crime Program. Rule 702 only requires that an expert witness have "scientific, technical, or other specialized knowledge" gained through "knowledge, skill, experience, training, or education." Fed. R. Evid. 702. Because Schiliro's background qualifies as "specialized knowledge," the district court did not err [**33]  in qualifying him as an expert. See United States v. Simmons, 923 F.2d 934, 946 (2d Cir.) (holding that a veteran DEA agent was "well-suited" to offer expert testimony about coded narcotics terminology), cert. denied, 114 L. Ed. 2d 104, 111 S. Ct. 2018 (1991); United States v. Roldan-Zapata, 916 F.2d 795, 804-05 (2d Cir. 1990) (holding that a narcotics investigator was properly qualified to testify about "the narcotics-related nature" of items found in a defendant's apartment and about "drug trafficking techniques generally"), cert. denied, 499 U.S. 940, 113 L. Ed. 2d 453, 111 S. Ct. 1397 (1991). Schiliro did not need to be a voice analysis expert to be able to recognize the defendants-appellants' voices on the tapes, nor did he need a linguistics degree to understand what was being said. Schiliro testified as an expert on organized crime, and he was sufficiently qualified on that basis. Although he had never before been qualified as an expert witness, even the most qualified expert must have his first day in court.
 
3. Sources of Information
 
Defendants-appellants next argue that because Schiliro relied [**34]  upon "countless  [*938]  nameless informers and countless tapes not in evidence," his testimony violated Fed. R. Evid. 703 and the Confrontation Clause of the Sixth Amendment. The government responds that, although Schiliro relied upon information that was not before the court, this reliance is permitted under the rules of evidence.

According to Rule 703, the facts that form the basis for an expert's opinions or inferences need not be admissible in evidence "if of a type reasonably relied upon by experts in the particular field." Fed. R. Evid. 703 (emphasis added). Thus, expert witnesses can testify to opinions based on hearsay or other inadmissible evidence if experts in the field reasonably rely on such evidence in forming their opinions. See Daly, 842 F.2d at 1387 (holding that organized crime expert can rely on otherwise inadmissible hearsay in forming his opinion); cf. Reardon v. Manson, 806 F.2d 39, 42 (2d Cir. 1986) (holding that reliance by experts on information provided by others does not violate Sixth Amendment rights if expert is available for cross examination), cert. denied, 481 U.S. 1020 (1987). [**35]  Therefore, Schiliro was entitled to rely upon hearsay as to such matters as the structure and operating rules of organized crime families and the identification of specific voices heard on tape in forming his opinion, since there is little question that law enforcement agents routinely and reasonably rely upon such hearsay in the course of their duties. An expert who meets the test of Rule 702, as Schiliro does, is assumed "to have the skill to properly evaluate the hearsay, giving it probative force appropriate to the circumstances." In re "Agent Orange" Product Liability Litigation, 611 F. Supp. 1223, 1245 (E.D.N.Y. 1985), aff'd, 818 F.2d 187 (2d Cir. 1987), cert. denied, 487 U.S. 1234 (1988). The fact that Schiliro relied upon inadmissible evidence is therefore less an issue of admissibility for the court than an issue of credibility for the jury. See United States v. Young, 745 F.2d 733, 761 (2d Cir. 1984) (pointing out that the defendants were free to expose the weaknesses in the prosecution's widespread use of expert testimony through cross examination),  [**36]  cert. denied, 470 U.S. 1084 (1985).

Gotti and Locascio do not seriously contest the point that hearsay and other inadmissible evidence are often reasonably relied upon by law enforcement agents in the field, and that this reliance is anticipated by Rule 703. Rather, they argue that a district court admitting expert testimony based on inadmissible evidence must make an explicit finding that the underlying sources of information used by the expert are trustworthy. See Barrel of Fun, Inc. v. States Farm Fire & Casualty Co., 739 F.2d 1028, 1033 (5th Cir. 1984) (holding that an expert's testimony was inadmissible because the factual premises underlying the opinion were "inherently suspect"). We agree that a district court is not bound to accept expert testimony based on questionable data simply because other experts use such data in the field. The Supreme Court's recent decision of Daubert v. Merrell Dow Pharmaceuticals Inc., 125 L. Ed. 2d 469, 113 S. Ct. 2786 (1993), makes this clear. In Daubert the Court abandoned the traditional rule of Frye v. United States, 54 App. D.C. 46, 293 F. 1013, 1014 (D.C. Cir. 1923), [**37]  which required "general acceptance" in the particular field before novel scientific evidence or techniques could be admitted in court. The Court in Daubert asserted that such a rigid standard for admitting expert scientific testimony was inconsistent with the liberal thrust of the federal rules, 113 S. Ct. at 2794, holding that district courts have the authority and discretion to determine whether novel scientific evidence is trustworthy. Id. at 2796. Although Daubert involved Rule 702 and scientific evidence, the flexibility of the federal rules also applies to Rule 703 and the determination of the trustworthiness of the sources of expert testimony. The district court has broad discretion to decide the admissibility of expert testimony based on inadmissible evidence.

We decline, however, to shackle the district court with a mandatory and explicit trustworthiness analysis. The district judge, who has the ideal vantage point to evaluate an expert's testimony during trial, already has the authority under Fed. R. Evid. 403 to  [*939]  conduct an explicit trustworthiness analysis should she deem one necessary. See Shatkin v. McDonnell Douglas Corp., 727 F.2d 202, 208 (2d Cir. 1984) [**38]  (noting that the district court has the "discretionary right under Rule 703 to determine whether the expert acted reasonably in making assumptions of fact upon which he would base his testimony"). In fact, we assume that the district court consistently and continually performed a trustworthiness analysis sub silentio of all evidence introduced at trial. We will not, however, circumscribe this discretion by burdening the court with the necessity of making an explicit determination for all expert testimony. This is especially true in this case, because the sources relied upon by Schiliro are no different from those previously allowed by this Court. See Daly, 842 F.2d at 1387-88.
 
4. Availability of Alternative Methods of Proof

Finally, the defendants-appellants argue that because an accomplice witness was available to provide similar testimony concerning the operations of organized crime families, the government was not permitted to introduce expert testimony on the subject. Rule 702, however, requires only that an expert have "some specialized knowledge that will assist the trier of fact." There is no requirement that prohibits a government agent [**39]  from testifying as an expert merely because an accomplice witness is also available.

The defendants-appellants mistakenly rely upon United States v. Long, 917 F.2d 691 (2d Cir. 1990), and United States v. Castillo, 924 F.2d 1227 (2d Cir. 1991), to support their contention. In Long, we held that the district court abused its discretion by admitting expert testimony regarding organized crime, but only because the crimes alleged had merely a marginal connection to organized crime. 917 F.2d at 701-02. The present case is readily distinguishable in that the charges against the defendants-appellants are intimately related to organized crime.

Similarly, in Castillo, this Court held that expert testimony had been erroneously admitted not because a lay witness could have provided the same testimony, but because we concluded that the jury "was entirely capable of understanding the evidence before it and determining the facts in issue without [the expert's] assistance." 924 F.2d at 1233. The same cannot be said about this case.
 
5. Other Challenges
 
The defendants-appellants [**40]  challenge the introduction of testimony from two other sources: FBI Agents George Mueller and George Gabriel. The record reflects, however, that neither of these witnesses testified as experts, and that neither defendant-appellant objected to their testimony when it was given. Therefore, we find no reason to disturb the district court's admission of their testimony.
 
C. Conclusion
 
Although we recognize the dangers inherent in the use of government experts in cases such as this one, we hold that the admission of such testimony was not manifestly erroneous. We remind the district courts, however, that they are not required to admit such testimony, and when they do the testimony should be carefully circumscribed to ensure that the expert does not usurp either the role of the judge in instructing on the law, or the role of the jury in applying the law to the facts before it. Cf. United States v. Bilzerian, 926 F.2d 1285, 1294 (2d Cir. 1991), cert. denied, 116 L. Ed. 2d 39, 112 S. Ct. 63 (1991).
 
III. Jury Instructions
 
Gotti and Locascio make various challenges to the district court's instructions to the jury. We review those [**41]  instructions de novo, and will only reverse on this basis if the defendants-appellants can show that the charge given, when read as a whole, caused them prejudice. See United States v. Pujana-Mena, 949 F.2d 24, 27 (2d Cir. 1991).
 
A. Section 1959
 
Gotti argues that the district court erroneously instructed the jury on the murder and murder conspiracy counts. These  [*940]  charges were founded on 18 U.S.C. § 1959, which provides:
(a) Whoever, as consideration for the receipt of, or as consideration for a promise or agreement to pay, anything of pecuniary value from an enterprise engaged in racketeering activity, or for the purpose of gaining entrance to or maintaining or increasing position in an enterprise engaged in racketeering activity, murders, kidnaps, maims, assaults with a dangerous weapon, commits assault resulting in serious bodily injury upon, or threatens to commit a crime of violence against any individual in violation of the laws of any State or the United States, or attempts or conspires so to do, shall be punished . . . .

 
 18 U.S.C. § 1959(a) (emphasis [**42]  added). The "maintaining or increasing" requirement is given its ordinary meaning and is "satisfied if the jury could properly infer that the defendant committed his violent crime because he knew it was expected of him by reason of his membership in the enterprise or that he committed it in furtherance of that membership." United States v. Concepcion, 983 F.2d 369, 381 (2d Cir. 1992).

Gotti argues, however, that the district court's instructions on the § 1959 counts were ambiguous, allowing him to be convicted even if the jury found that the murders were committed to advance someone else's position, not his own. Gotti's theory of defense was that many of the murders committed by Gambino Family associates were actually authorized by Gravano, the government witness, solely for his own purposes. Gotti argued to the jury that Gravano had orchestrated the murders to improve his own financial position, and that Gotti had nothing to do with them.

Gotti and Locascio focus on two parts of the instructions: (1) the court's language at the end of its instructions on the counts charging substantive violations of § 1959; and (2) the court's charge on the § 1959 conspiracy [**43]  counts. For the reasons stated below, we find no basis for reversal, even though we recognize that the district court should have more clearly stated and reiterated the "maintaining or increasing position" motive requirement of § 1959 in both the substantive and conspiracy counts.
 
(1) Language in the Substantive § 1959 Counts
 
A review of the instruction reveals that the district court initially clearly instructed the jury that the government had to prove that Gotti and Locascio committed the murders in order to maintain or increase their respective positions in the enterprise. Referring to substantive counts four, six, and eight, the court specifically charged that 
the fourth element that the Government must prove beyond a reasonable doubt is that the defendant's purpose in committing the murder was to maintain or increase his position in the racketeering enterprise. In determining whether a defendant's purpose in committing the murder was to maintain or increase his position in that enterprise, you should give the words "maintain" or "increase" their ordinary meaning. You should consider all the facts and circumstances in making that determination.

 


For example,  [**44]  you may consider evidence that the crime, if proved, was committed in order to maintain discipline within the enterprise and served to maintain the defendant's position with the enterprise.

 


If the defendant committed a crime because he thought it would enhance his position or prestige within the enterprise, or if he committed it because he thought it was necessary to maintain the position he already held in the enterprise, the element would be established.

 


These examples are only meant by way of illustration. They are not exhaustive.

 
These instructions are entirely consistent with the language in Concepcion. See id.

The district court's initial instructions on the substantive § 1959 counts, then, correctly reflected the government's burden to show that Gotti and Locascio acted to increase or maintain their respective positions in the enterprise. As the instructions continued, however, the district court unfortunately began to use a short-hand phrase to refer to the § 1959 motive requirement.

 [*941]  Toward the end of its instructions on the substantive § 1959 counts, the court summarized its § 1959 instructions without mentioning the maintaining-or-increasing-his-position [**45]  motive and using instead the short-hand phrase "in aid of racketeering." The court said, "in short," that the jury should convict on the substantive § 1959 count in question if it found that the government proved beyond a reasonable doubt that the defendant the jury was considering committed the crime of murder or aided or abetted the commission of that crime "in aid of racketeering." Since virtually all crimes could be committed "in aid of racketeering" without the motive of maintaining or increasing the perpetrator's position in the enterprise, this summary was unfortunately vague. Though the phraseology may be cumbersome, the district court should remind the jury of the position-related motivation requirement that is applicable to each § 1959 count.

Gotti and Locascio argue that the charge was fatally flawed because of the use of the "in aid of racketeering" language. The district court, however, only used the ambiguous short-hand language in the summary of the instruction, after having articulated the requirement correctly throughout the rest of the explanation of the counts. Moreover, the court gave the jurors the indictment, which alleged that Gotti and in some cases Locascio [**46]  "together with others" conspired to murder and/or murdered four individuals "for the purpose of maintaining and increasing their positions in the Gambino Family." At the point when the district court lapsed into short-hand, the jury was already well aware of the motive requirement.
 
(2) Language on the § 1959 Conspiracy Counts
 
In the district court's instructions on the § 1959 conspiracy counts, the court again used language that blurred the § 1959 motive requirement. As with the substantive counts, the court began by informing the jury of the charge in the indictment and of the statutory provision, both of which include the "maintaining or increasing position" clause.

In proceeding to instruct the jury as to what it needed to find in order to convict on these counts, though, the court again used its "in aid of racketeering" catch phrase. The court did not at that point expressly advise the jury that, in order to convict on the § 1959 conspiracy counts, the jury was required to find that the defendant in question conspired to commit murder for the purpose of maintaining or increasing his position in the enterprise.

At another point, when instructing the jury as to the nature [**47]  of the alleged conspiracy, the court often used a short-hand phrase with respect to the object of the conspiracy that did not adequately reflect the need for proof of a position-related purpose. For example, the court instructed that a "conspiracy is defined very simply as an agreement between two or more persons to commit a crime" and that


it is enough if the Government proved two or more persons, one of whom being the defendant you are considering in any way, either expressly or impliedly, came to a common understanding to commit a crime to violate the law . . . .

 
(emphasis added). The court also concluded using the short-hand:


Summing up then, the essential elements of the offense charged in counts three, five, seven and nine, conspiracy to murder in aid of racketeering, each of which the Government must prove beyond a reasonable doubt are:

 


First, that [a] conspiracy existed. That is two or more people, one of whom is the defendant that you are considering, agreed to violate federal law against murder in aid of racketeering.

 


And second, that the defendant knowingly and willfully became a member of the conspiracy.


. . . .


The burden is on the Government [**48]  to prove each and every element. There are two, the existence of the conspiracy and the defendant's membership in it, beyond a reasonable doubt.

 
(emphasis added). These instructions arguably left the potential for the jury to misunderstand  [*942]  the nature of the § 1959 conspiracy charges against Gotti and Locascio. It should be noted, though, that these lapses came after the district court had already properly instructed the jury on the position-related motive requirement of § 1959. The jury did receive accurate instructions initially, although the district court proceeded to refer back to the motive requirement with the short-hand "in aid of racketeering" catch-phrase rather than the more precise "increase or maintain" language.
 
(3) Conclusion
 
Gotti and Locascio argue that the vagueness in the instructions, caused by the district court's lapses into short-hand, constitutes reversible error. We note, though, that "a single instruction to a jury may not be judged in artificial isolation, but must be viewed in the context of the overall charge." Cupp v. Naughten, 414 U.S. 141, 146-47, 38 L. Ed. 2d 368, 94 S. Ct. 396 (1973). We disagree that the district court's charge was erroneous,  [**49]  because, even with the lapses, the instruction as a whole accurately charged the jury, especially considering that the court did properly impart the motive requirement numerous times and did give the jury the indictment, which also used the "increase or maintain" language.

Even if the district court had committed error in its instructions, however, the defendants failed to object to these aspects of the instructions at trial.