DUDLEY, TOPPER AND FEUERZEIG, UP 1000 Frederketerg 13.50e P.O. Box 756 7homee, US. VI 076060756 (344) 774-4422 IN THE SUPERIOR COURT OF THE VIRGIN ISLANDS DIVISION OF ST. THOMAS AND ST. JOHN PEOPLE OF THE VIRGIN ISLANDS, v. JOHN P. DE JONGH, JR., Plaintiff, Defendant. Case No. ST-15-CR-309 Hon. Michael C. Dunston Presiding Judge :fl DEFENDANT'S MOTION TO DISMISS THE INFORMATION PURSUANT TO FED. R. CRIM. P. 12(b)(3)(B)(iv) Defendant, Gov. John P. de Jongh, Jr., respectfully moves this Honorable Court pursuant to Fed. R. Crim. P. 12(a)(3)(B)(iv) and Super. Ct. R. 7 for an order dismissing the Information dated September 2, 2015. (Exhibit A),I INTRODUCTION The fact that the People's entire case against Gov. de Jongh hinges on a matter of remedial English punctuation makes one thing perfectly clear: this case is not legitimately about the criminal law. Instead, it appears to be a politically-driven and poorly conceived vendetta initiated by the current Governor, whom Gov. de Jongh defeated handily in his last reelection campaign in 2010. This sham prosecution is a disgrace both upon the Virgin Islands Department of Justice and the Governor's Office. The current Administration accuses Gov. de Jongh of stealing approximately $490,000.00 from the public fisc and using the money to add value to his private home. Ironically, in the short time the current Governor has been in office he has apparently already I The instant motion is in addition to Gov. de Jongh's motion to dismiss the charges against him as time-barred, filed on September 3, 2015. The People filed no opposition to that motion, and it is far too late to do so now. EFTA01074706