1. Whether the term "members" as stated in the language of the indictment is sufficient to allege the essential element of a natural and specific "person" as mandated by the statute of 18 USC 2261A(2)(A) and;

2. Can the Federal Bureau of Investigations ("FBI") acting as a sovereign government be a "person" that is cognizable within the purview and meaning of person in accordance with the Violence Against Women ACT ("VAWA"), 18 USC 2261 A(2)(A).

Whether the term 'members' in an indictment sufficiently alleges a specific 'person' under 18 USC 2261A(2)(A) and whether the FBI can be considered a 'person' under the Violence Against Women Act