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USA v. Feneziani
Memorandum of Law in Support of Defendant's Pretrial Motions:
This memorandum is submitted in support of the defendant’s pretrial motions for dismissal and discovery, the latter specifically in connection with the question of the vindictive nature of the prosecution. The defense is specifically asking the Court to withhold determination of the “vindictive prosecution” claim until the defendant has been provided with discovery and a hearing with respect to any contested issues related to the vindictiveness claim.