On Dec. 5, 2022, U.S. District Judge J. Paul Oetken of the Southern District of New York granted in part Kramer Levin’s motion to dismiss a bribery and fraud indictment on behalf of former New York Lt. Gov. Brian Benjamin. Specifically, charges of bribery, honest services wire fraud and conspiracy to commit those two offenses were dismissed. In doing so, Judge Oetken ruled that federal prosecutors had failed to allege an explicit quid pro quo.