U.S. v. Gengo, No. 86-1263, Bo. 114 (2nd Cir.) (808 F.2d 1) (December 22, 1986) (Judge Irving R. Kaufman)
Case held that a superseding indictment will relate back to the date of the original indictment only if the superseding indictment does not "broaden or substantially amend the original indictment." (Id., at 3).
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