motionAugust 12, 2022
Motion to Dismiss Count Two — grammatical interpretation of otherwise (p.11 of 21)
Doc 138 p.11 of 21. Section 3: Argues DOJ/Court mistaken grammatical interpretation. Word "otherwise" was intended to marry 1512(c)(1) and (c)(2) together. Notes Congress used "or" nine times in 18 USC 1512 to demarcate 20 separate methods; "otherwise" alone is inserted between (c)(1) and (c)(2) for unique constructive purpose. Therefore Nichols cannot defend separately against 1512(c)(2).
Source: J6 Scan 32 — Motions / IGPs / Drive
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