With respect of Count One of the Indictment, describe those alleged co-conspirators both known and unknown to the grand jurors and if there be no evidence of such, then strike the surplusage.ħ. With respect to Count 1 of the Indictment, please also state with particularity each and every overt act allegedly committed in furtherance of the conspiracy alleged in Count One, by whom each act was allegedly committed, and the date, time, and place of occurrence of each act.Ħ. With respect to Count One of the Indictment, if indeed the government considers the persons listed in the discovery material to be unindicted co-conspirators, then please state with particularity the manner and means of the alleged conspiracy(s), as there is not an indication as to which acts constituted this conspiracy(s), how it (or multiple conspiracies) occurred, who was involved, or how such persons were involved.ĥ. With respect to Count One of the Indictment, if the government considers the persons listed in the discovery material received to date to be unindicted co-conspirators, then please state with particularity how many conspiracies are alleged to have existed, the identities of the co-conspirators, and the involvement of each person.Ĥ. With respect to Count One of the Indictment, please state with particularity the time period(s) that Defendant RODNEY DOE is alleged to have participated in the conspiracy.ģ. With respect to Count One of the Indictment, please state with particularity the basis and manner and means, including the date, place, time, and names of alleged participants, of the simple allegation that Defendant DOE did knowingly or intentionally combine, conspire, confederate and agree together with other defendants and with other persons known and unknown to the Grand Jury to distribute or possess with intent to distribute: “GHB”, “Ecstasy/MDMA”, cocaine, “crack” cocaine, methamphetamine, and marijuana.Ģ. Government to file a bill of particulars pursuant to Fed.
NOW COMES defendant JOHN DOE, through undersigned counsel, and moves that the Court direct the SHERMAN DIVISION UNITED STATES OF AMERICA
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