United States v. HVIZDZAK, 1:21-cr-00030

U.S. v. Hvizdzak involves two defendants charged in a 65-count indictment in the Western District of Pennsylvania with conspiracy to commit wire fraud, wire fraud, and money laundering.
Counts 2–65 differentially name the defendants and/or both defendants; the jury would assess guilt on each count against each defendant.
The parties filed a Joint Filing seeking a verdict form; they could not agree on a single vs. separate verdict slips for the two defendants.
Sean Hvizdzak urged separate verdict slips to aid individual consideration of guilt or innocence; the government supported a single verdict slip.
The court evaluated case law, noting Desmond and Palmeri address special interrogatories, not separate verdict slips, and that both defendants face overlapping counts.
The court ultimately denied Sean Hvizdzak’s request and ordered that a single, government-proposed verdict slip would be used, with instructions ensuring personal guilt/innocence for each defendant per count.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether to use separate verdict slips for each defendant	Hvizdzak argued for separate verdict slips for each defendant.	Hvizdzak contends separate slips prevent confusion and ensure individual verdicts.	Denied; single verdict slip chosen.

United States v. Desmond, 670 F.2d 414 (3d Cir. 1982) (special interrogatories not controlling for separate verdict slips)
United States v. Palmeri, 630 F.2d 192 (3d Cir. 1980) (special interrogatories proper in racketeering; separate verdict slips not used)