Defendant Igor Danchenko’s Reply in Support of Motion to Dismiss the Indictment for Failure to State an Offense

Danchenko Reply by FightWithKash on Scribd

SUMMARY 

The Special Counsel filed an Indictment that devotes 111 paragraphs and 39 pages to superfluous allegations but fails as a matter of law to support the actual false statements charges. Rather than directly confront the deficiencies in the Indictment or the arguments raised by Defendant Igor Danchenko in his Motion to Dismiss the Indictment, the Special Counsel seeks to muddy the waters in a cursory and disjointed opposition (“SCO Opposition”) that confuses issues of law and fact, misstates legal standards, introduces extraneous evidence that is irrelevant to whether the Indictment actually states an offense, and sidesteps the significant legal impediments raised by Mr. Danchenko that warrant dismissal.