DEFENDANT’S MOTION FOR BILL OF PARTICULARS COMES NOW DEFENDANT, Joao Pereira da Fonseca, by and through undersigned counsel, and respectfully requests that this Court order the government to produce a bill of particulars informing the Court and the defendant as to his knowledge and participation in the alleged conspiracy.

Concise Argument

Mr. Pereira da Fonseca respectfully submits that the indictment fails to specify when and how he is alleged to have entered and participated in the alleged conspiracy. While the indictment details events between two other individuals, and companies, it does not reveal the knowledge component necessary to assign criminal responsibility to Mr. Pereira da Fonseca.

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