https://github.com/davepinch/pinchy.cc/blob/master/content/topics/news/sean-combs/cases/united-states-v-combs/documents/2/paragraphs/13-d.md
Paul Verhoeven was born in Amsterdam on 18 July 1938, the son of a schoolteacher, Wim Verhoeven, and a hatmaker, Nel van Schaardenburg.
multiple acts indictable under Title 18, United States Code, Sections 1589 and 2 (relating to forced labor);
multiple acts involving bribery, chargeable under the following provisions of state law: California Penal Code § 137(a) (bribery of a witness), California Penal Code §§ 21(a), 664 (attempt), California Penal Code§ 31 (aiding and abetting), and California Penal Code § 182 (conspiracy);