The document below is
17 Pages - GOVERNMENT’S OPPOSITION TO DEFENDANT’S MOTION FOR A BILL OF PARTICULARS
Case 1:21-cr-00582-CRC Document 19 Filed 10/20/21 Page 1 of 17
Also
"Follow the pen"... The pen is missing.
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GOVERNMENT’S OPPOSITION TO DEFENDANT’S MOTION FOR A BILL OF PARTICULARS
"The United States of America, by and through its attorney, Special Counsel John H. Durham, respectfully submits this opposition to the defendant’s Motion for a Bill of Particulars (Document 17, hereinafter “Mot.”). For reasons stated below, the government submits that the motion should be denied. The grand jury’s detailed, 27-page speaking indictment more than adequately informs the defendant of the charges against him and provides him with sufficient information and facts to prepare his defense at trial. Moreover, all or nearly all of the information that the defendant seeks either has already been, or soon will be, made available to him through the government’s discovery. Accordingly, the defendant’s motion seeking an order for a bill of particulars fails as a matter of well-settled law."
FACTUAL BACKGROUND
"The defendant is charged in a one-count indictment with making a materially false statement to an FBI official, in violation of Title 18, United States Code, Section 1001."
A.
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17 pages here.
Goes with 223:
18 U.S. Code § 1001 - Statements or entries generally
(a) Except as otherwise provided in this section, whoever, in any matter within the jurisdiction of the executive, legislative, or judicial branch of the Government of the United States, knowingly and willfully—
(1) falsifies, conceals, or covers up by any trick, scheme, or device a material fact;
(2) makes any materially false, fictitious, or fraudulent statement or representation; or
(3) makes or uses any false writing or document knowing the same to contain any materially false, fictitious, or fraudulent statement or entry;
shall be fined under this title, imprisoned not more than 5 years or, if the offense involves international or domestic terrorism (as defined in section 2331), imprisoned not more than 8 years, or both. If the matter relates to an offense under chapter 109A, 109B, 110, or 117, or section 1591, then the term of imprisonment imposed under this section shall be not more than 8 years.
(b) Subsection (a) does not apply to a party to a judicial proceeding, or that party’s counsel, for statements, representations, writings or documents submitted by such party or counsel to a judge or magistrate in that proceeding.
(c) With respect to any matter within the jurisdiction of the legislative branch, subsection (a) shall apply only to—
(1) administrative matters, including a claim for payment, a matter related to the procurement of property or services, personnel or employment practices, or support services, or a document required by law, rule, or regulation to be submitted to the Congress or any office or officer within the legislative branch; or
(2) any investigation or review, conducted pursuant to the authority of any committee, subcommittee, commission or office of the Congress, consistent with applicable rules of the House or Senate.
Also note from post 223:
on page 14-15 of Durham's 17-page OPPOSITION TO DEFENDANT’S MOTION FOR A BILL OF PARTICULARS
"As noted above, the government has produced, and will continue producing, voluminous discovery materials that will reveal, among other things, statements that key witnesses made in interviews with the FBI and in testimony before the grand jury."
"These statements and testimony will include numerous key witnesses’ recollections of the events referenced in the Indictment, including their views regarding the relevance and materiality of the false statements at issue. The government has also produced and will continue to produce emails, reports, and other records concerning the events and false statements at issue."
