NORMAN L. VROMAN
Lawyer
c/o General Delivery
Hopland, California

IN PROPRIA PERSONA








                  UNITED STATES DISTRICT COURT

                 NORTHERN DISTRICT OF CALIFORNIA


UNITED STATES OF AMERICA         )  No. CR 91 0213 EFL
                                 )
      PLAINTIFF,                 )  RESPONSE TO OPPOSITION
                                 )  TO BILL OF PARTICULARS
      V.                         )
                                 )
NORMAN LEON VROMAN               )
                                 )
      DEFENDANT.                 )
                                 )
_________________________________)


                            RESPONSE

     The government has termed the defendant's request for a Bill

of Particulars as "frivolous".  Nothing could be further from the

truth.   Close examination  of  the  indictment  in  this  matter

discloses the  only reference  to Title  26 Internal Revenue Code

(IRC) to  be sections  7201 and  7203.   (See Appendix A for full

text of  these sections.)   Both  of these  sections rely  on  an

omission or  commission prohibited  or  mandated  by  some  other

section of the IRC to trigger their application.

     Since the  indictment is  devoid of  any  reference  to  any

triggering statues  or regulations  of the IRC, the defendant has

no idea  what the government is relying on to bring sections 7201

and 7203 to focus upon him.  The government's response reiterates

facts while the defendant is seeking the law that requires him to

do the acts or prohibits the acts the indictment alleges.


         Response to Opposition to Bill of Particulars:
                          Page 1 of 3


     These sections of the IRC are not unusual in being dependant

on another  section or title to bring them into play. A search of

Title 18  U.S.C. reveals  a number  of sections such as 545, 546,

642, 35, 41, 111 and 152 to name but a few, all require or depend

upon another  section to  trigger  their  application.  Thus  the

defendant's request  that the  government specify  the statue  or

regulation that  prohibited or  commanded that  he  do  something

which brought  him within  sections 7201  & 7203 IRC is certainly

not frivolous  and is absolutely necessary before he may begin to

prepare a defense.

     THEREFORE defendant respectfully requests the Court to grant

his motion for a Bill of Particulars.


Dated: July 23, 1991


/s/ Norman Vroman
_______________________________
NORMAN L. VROMAN

In Propria Persona


         Response to Opposition to Bill of Particulars:
                          Page 2 of 3


                     CERTIFICATE OF SERVICE

     It is  hereby certified  that a true and correct copy of the
foregoing was  hand delivered  to the  United States Attorney, at
his respective office, on this 23rd day of July 1991.


/s/ Norman Vroman
_________________________________
NORMAN L. VROMAN


         Response to Opposition to Bill of Particulars:
                          Page 3 of 3


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U.S.A. v. Vroman