Description:

This Memorandum of Law is submitted on behalf of defendant Ross Ulbricht in support of his pretrial motions addressing the face of the Indictment, which charges Mr. Ulbricht with Conspiracy to Distribute and Possess with Intent to Distribute Controlled Substances, in violation of 21 U.S.C. §846 (Count One), Continuing Criminal Enterprise, in violation of 21 U.S.C. §848(a) (Count Two), Conspiracy to Commit Fraud and Related Activity in Connection with Computers, in violation of 18 U.S.C. §1030(b) (Count Three), and Money Laundering, in violation of 18 U.S.C. §1956(h) (Count Four). For the reasons set forth below, it is respectfully submitted that all of the charges against Mr. Ulbricht should be dismissed.