MEMORANDUM OPINION AND ORDER
NORA BARRY FISCHER, District Judge.
I. INTRODUCTION
On September 25, 2007, a grand jury returned an eight-count indictment against Samuel J. Manfredi ("Mr. Manfredi") and Marilyn T. Manfredi ("Mrs. Manfredi") (collectively, "Defendants") charging both with the following crimes: (1) at Count One with conspiracy to commit offenses against the United States under 18 U.S.C. § 371 including income tax evasion in violation...
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