1

IN THE UNITED STATES DISTRICT COURT

FOR THE SOUTHERN DISTRICT OF NEW YORK


)
UNITED STATES OF AMERICA, )
)
-v- ) No. 14 CR 440 (VLB)
)
THOMAS W. LIBOUS, ) NOTICE OF MOTION
)
Defendant. )
)



PLEASE TAKE NOTICE, that upon the accompanying papers, Memorandum of Law,
any exhibits attached thereto, and upon proceedings heretofore had, Thomas W. Libous
(Senator Libous), by his attorney, Paul DerOhannesian II, Esq., will move this Court, before
the Honorable Vincent L. Briccetti, in the United States District Court for the Southern District
of New York, for an Order, pursuant to Rule 7(f) of the Federal Rules of Criminal Procedure,
directing the government to file a Bill of Particulars, as follows:
1. Identify the name and identity of the Special Agents of the FBI who
interviewed Senator Libous as set forth in 3 of the Indictment.
2. Identify the name and identity of any person present during the interview of
Senator Libous as set forth in 3 of the Indictment.
3. Identify the City, Town or Village where the interview of Senator Libous took
place as set forth in 3 of the Indictment.
4. Identify the approximate time of the interview of Senator Libous as set forth
in 3 of the Indictment.
5. Identify the address of the location where of the interview of Senator Libous
took place as set forth in 3 of the Indictment.
6. Identify the room where the interview of Senator Libous took place as set
forth in 3 of the Indictment.
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7. Identify the address and location in the Southern District of New York
referred to in 4 of the Indictment.
8. Identify the address and location of the elsewhere referred to in 4 of the
Indictment.
9. Identify the conduct forming the basis that Senator Libous knowingly and
willfully falsified, concealed and covered up material facts by trick, scheme
and device referred to in 4 of the Indictment.
10. Identify the exact questions posed to Senator Libous when interviewed by
Special Agents of the FBI referred to in 3 of the Indictment.
11. Identify the statements made to Senator Libous by Special Agents of the FBI
when interviewed as referred to in 4 of the Indictment.
12. Identify the exact statements made by Senator Libous on or about June 24,
2010, constituting the false statements as referred to in 3 of the Indictment.
13. Identify the name and identify of Senator Libous son referred to in 2 of
the Indictment.
14. Identify the name and identity of the partner referred to in 2 of the
Indictment.
15. Identify Law Firm 1 referred to in 2 of the Indictment.
16. Identify Lobbying Firm 1 referred to in 2 of the Indictment.
17. Identify the business received by Law Firm 1 referred to in 2 of the
Indictment.
and any other relief the Court deems just and proper.
Dated: July 14, 2014
Albany, New York
Respectfully submitted,
By: /s/ Paul DerOhannesian II
Paul DerOhannesian II (PD0523)
DerOhannesian & DerOhannesian
677 Broadway, Suite 707
Albany, New York 12207
(518) 465-6420
Attorneys for Defendant Thomas W. Libous
cc: All Counsel (via ECF)
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