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Plot. Kelly versus the united states. Mr. Chief justice, and may it please the court, once again, the government is trying to use openended federal statutes to enforce federal government state and local at the state and local levels. Its theory this time is that the defendants committed property fraud, by reallocating two traffic lanes from one public road to another, without disclosing their real political reason for doing so. This theory turns the integrate integrity of every official level of every government into a potential federal fraud investigation. It ends runs mcnally and skilling by subsuming on a Services Fraud within property fraud and by criminalizing ulterior motives even without bribes or kick backs. It would affect the sweeping expansion of federal criminal jurisdiction interview particularly fraught area. This is not the law. This court in cleveland held that Regulatory Authority is not property. So unofficial who introduces a sovereign decision through deceit has not

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