United States v. Concord Management and Consulting LLC

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA UNITED STATES OF AMERICA v. Criminal Action No. 18-cr-32-2 (DLF) CONCORD MANAGEMENT & CONSULTING LLC, Defendant. MEMORANDUM OPINION Concord Management and Consulting LLC moves to dismiss count I of the indictment— brought under the conspiracy statute, 18 U.S.C. § 371—on the grounds that it (1) fails to allege a defraud conspiracy under § 371 that interferes with a lawful government function; (2) fails to allege a mens rea of “willfulness”; (3) applies § 371’s conspiracy-to-defraud clause to Concord in an unconstitutionally vague…