The United States, by and through its attorney, the United States Attorney for the District of Columbia, respectfully provides notice to the Court and defendant that the government may seek to introduce certain evidence of prior bad acts against the defendant, pursuant to Rule 404(b), Fed. R. Evid., and moves this Court to admit such evidence. In particular, the government seeks to introduce proof that defendant Fonseca previously traveled to Iran to install German-origin equipment purchased by Firstfield Engineering on behalf of an Iranian company, and also provided technical assistance and training to the Iranians regarding that German-origin equipment. Such evidence is admissible under Rule 404(b) to show the defendant’s knowledge, intent, motive, and lack of mistake or accident relating to his participation in a conspiracy to violate the International Emergency Economic Powers Act (IEEPA) and the Iranian Transactions and Sanctions Regulations (ITSR), in violation of 18 U.S.C. § 371; 50 U.S.C. § 1705; and 31 C.F.R. Part 560.
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