Thanks for that. That is a lot of tap-dancing to say this in response to Request-2:
"People’s Response to Request No. 2: Defendant is not entitled to the information requested in Request No. 2. Where an intent to commit or conceal another crime is an element of an offense, the People need not prove intent to commit or conceal a particular crime; thus, the indictment need not identify any particular crime that the defendant intended to commit or conceal, and defendant is not entitled to such information in a bill of particulars."
So the BOP says that the secret crime does NOT need to be specified. Total Kangaroo Court.