He continues to accuse the government of adding his mother to the indictment solely to drag things out, and:
Further:This flip-flopping of the government asserting that they have not requested a continuance, then separately arguing for a continuance then emphatically stating that it has NOT ONCE filed for a continuance is indicative of the incompetence and dishonesty of the prosecutors in this case.
Then he keeps screaming that the government was obliged to present exculpatory evidence to the grand jury. Then he seems to conveniently forget that his actions in Florida and Hawaii are in fact different acts at different times:However, the delay in the trial has been oppressive and prejudicial because had the undersigned been taken to trial within 70 days of the indictment he has no incertitude he would have won at trial...
What follows is more complaining that the government still hasn't properly responded to his motion to dismiss (mandating dismissal), and he includes an affidavit from what I presume is one of his clients stating that the client was defrauded by "Mortgage Enterprise", whom ATW claims is a copycat fraudulent company set up by others.III. DOUBLE JEOPARDY CLAUSE DOES BAR FEDERAL PROSECUTION AFTER DEFENDANT HAS BEEN CONVICTED
As previously outlined in the Sworn Motion to Dismiss Superseding Indictment the double jeopardy clause bars the prosecution twice for the same offense. By charging the defendant with charges by a different name for the same conduct defendant has been wrongfully convicted of in Florida, the government seems to have the erroneous presumption that the double jeopardy principle doesn't apply.
...
The defendant is not being prosecuted for different acts in Florida and federal court but prosecuted for the exact same acts, conduct and business but merely labeled as different charges. The defendants [business] application, business practices and procedures are the exact same in all states his business operates in so there were no different acts just different charges filed for the same acts in an attempt to circumvent the double jeopardy clause. Therefore the Double Jeopardy Clause in fact does apply.
(Apologies for not quoting more from the document, but it's composed of scanned images and Acrobat Pro DC doesn't want to OCR it for some reason)