In the Memorandum of Law supporting Sean Combs's Motion to Dismiss Count Three of the Superseding Indictment in case 1:24-cr-00542-AS, the defense argues that the charge is legally insufficient and fails to meet the required statutory elements. They contend that the indictment lacks specificity, particularly in detailing the alleged conduct and its connection to the purported criminal enterprise. Furthermore, the defense asserts that the prosecution's interpretation of the statute is overly broad, potentially criminalizing behavior beyond the law's intent. They emphasize that without clear evidence linking Combs to the alleged illegal activities in Count Three, the charge should be dismissed to uphold the principles of fair notice and due process.


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source:

gov.uscourts.nysd.628425.153.0.pdf