held that the term ‘willfully’ in criminal statutes typically does not require the government to prove the defendant’s specific intent to violate the particular criminal statute in question”). As Judge Learned Hand recognized long ago, “willful” in a criminal statute “means no more than that the person charged with the duty knows what he is doing. It does not mean that, in addition, he must suppose that he is breaking the law.” Am. Surety Co. of New York v. Sullivan, 7 F.2d 605, 606 (2d Cir.1925). Accordingly, Peterson’s motion to dismiss Count Two as vague is denied, as is his alternative request with respect to proof of willfulness. CONCLUSION For the foregoing reasons, Peterson’s motions are denied in all respects. SO ORDERED. 1 . See, e.g., United States v. Naranjo, 14 F.3d at 147
holding that venue is proper in any district where any act in furtherance of the conspiracy took place holding that the notion of enterprise conspiracy has largely rendered the old distinction between single conspiracy and multiple conspiracy irrelevant to rico conspiracy charges holding in narcotics conspiracy case that phone calls from one district into another can establish venue in the latter district so long as they further the ends of the conspiracy holding that in a conspiracy case venue lies where the conspiracy agreement was formed or in any jurisdiction where an overt act in furtherance of the conspiracy was committed by any of the conspirators holding that venue for a conspiracy prosecution was proper in a district where an overt act took place although defendant had never been there and the conspiracy was not formed there