The question of venue arises when the unlawful act occurs in a district other than the district in which the affected investigation or proceeding is pending. This issue generated a conflict among the United States Courts of Appeals, but in 1988 Congress enacted 18 U.S.C. § 1512(h), which provides that venue under that section and section 1503 may lie either in the district in which the conduct allegedly occurred or in the district in which the official proceeding was intended to be affected. In United States v. Cofield, 11 F.3d 413 (4th Cir. 1993), the court held that a similar choice of venue is available under 18 U.S.C. § 1513.
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