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UNITED STATES OF AMERICA        )    No. CR 91 0213 EFL
                                )    RESPONSE TO PLAINTIFF
                                )    MOTION IN LIMINE
     PLAINTIFF,                 )
     v.                         )
NORMAN LEON VROMAN              )
     DEFENDANT.                 )


     The government  has filed  this motion  in limine because it

has "anticipated"  that the  defense  may  attempt  to  argue  or

present   evidence   concerning   the   alleged   invalidity   or

unconstitutionality  of   "certain  provisions  of  the  Internal

Revenue Code."

     It is precisely because these certain provisions have yet to

be revealed  to the  defendant that  he  is  unable  to  form  an

intelligent response to the motion.  Due to the complexity of the

Internal Revenue  Code and  the accompanying Regulations it would

require guessing  on the  part of the defendant to determine just

exactly which  provisions the  government was  alluding to.  This

defendant was  under the  impression that  he was not required to

guess at what he was charged with in a criminal case.

                 Response to Motion In Limine:
                          Page 1 of 4

     "Willfulness,  as   construed  by  our  prior  decisions  in

criminal tax cases, requires the Government to prove that the law

imposed a  duty on the defendant, that the defendant knew of this

duty, and  that he  voluntarily and  intentionally violated  that

duty.  We deal first with the case where the issue is whether the

defendant knew of the duty purporting imposed by the provision of

the statute  or regulation he is accused of violating,..."  Cheek

v United  States, 498 U.S. ___, 112 L Ed 2nd 617, 111 S. Ct. 604,

at 629-30, 112 L.Ed.2d.

     Thus we  deal directly with the problem facing the defendant

in the case at bar, the complete lack of knowledge of the statute

or regulation  that he  is accused  of violating!!   While  it is

beyond question  that the  government must  prove  that  the  law

imposed a duty on the defendant, what law that might be is yet to

be revealed.   Until  the defendant  is informed as to what those

"certain provisions  of the  Internal Revenue Code" might be that

he would  want to  allege as being invalid or unconstitutional he

can not respond to the government's Motion In Limine.

     The government  alleges that  the United States Constitution

is not relevant to the case at bar.  If that is so the court must

be operating  as an  equity court but the defendant is unaware of

what document  he signed conferring jurisdiction and removing his

constitutional safeguards.

     Until such  time as  the government  sees fit  to inform the

defendant of  what law required him to make and file a return, be

it statute  or regulation, he is unable to adequately prepare any


                 Response to Motion In Limine:
                          Page 2 of 4

Dated:  July 23, 1991

/s/ Norman Vroman
In Propria Persona

                 Response to Motion In Limine:
                          Page 3 of 4

                     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

                 Response to Motion In Limine:
                          Page 4 of 4

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U.S.A. v. Vroman