to Rule 12 list examples of such defenses, including “[i]l-legal selection or organization of the grand jury, disqualification of individual grand jurors, presence of unauthorized persons in the grand jury room, other irregularities in grand jury proceedings, defects in indictment or information other than lack of jurisdiction or failure to state an offense, etc.” Fed. R.CRIM. P. 12 Advisory Committee Notes (1944 Adoption). Harrod objects, as a matter of law, to the broad definition of “similitude” adopted by the lower court, not to any procedural irregularity or violation of the type that “must” be raised under 12(b). See also 1 Charles Alan Wright, Federal PractiCE and Prooedure § 193 (1982) (listing “irregularities in obtaining the indictment or information, improper h Cir.1970) (<HOLDING>). Many courts, however, have pointed out that
holding that application of the modified categorical approach did not establish a covered conviction where the judgment of conviction did not contain the factual basis for the crime holding that counsels efforts did not justify vacatur and reentry holding that states interests were sufficiently important to justify the rule prohibiting dual officeholding holding that onesided photocopies of bills on pinkish paper did not sufficiently resemble actual currency to justify a  472 conviction holding that reasoning which would justify the arrest by the search and at the same time justify the search by the arrest  will not do