the use of Le Roux as an informant amounted to “outrageous con- duct” on the part of the government. In the filing, Kirton appeared to be laying the foundation for a rarely used, and even more rarely successful, defense known as duress. A claim of duress argues, es- sentially, that a defendant committed a crime because he faced an imminent threat of serious bodily harm or death. A person could be found innocent of a crime, in other words, if someone held a loaded gun to his head and told him to commit it. Hunter, the ar- gument went, had gone along with the assassination plan only be- cause he believed Le Roux would kill him if he refused.

Years before either man was arrested, Hunter claimed, Le Roux had threatened him and his family over a gold deal gone bad. And Hunter was in a unique position to know that Le Roux followed through on his threats. “Mr. _________ literally killed and threat- ened his associates with the full knowledge of his other associ- ates,” Kirton wrote in the motion. (Le Roux’s name was still officially sealed, and Kirton was required to blank it out despite the fact that The New York Times had revealed it a month earlier.) “How then can law enforcement use this man to engage the same person as part of a reverse sting operation? What choice did Mr. Hunter have? The answer is death.”

Hunter’s argument was a thin reed, laced with the freakish irony that a man who had carried out hits for Le Roux claimed to be doing so out of fear of Le Roux’s hit men. But given the evidence against Hunter, it appeared to be the only reed available.

Federal prosecutors in the Southern District of New York re- sponded that even if Le Roux had threatened Hunter, it had hap- pened long ago. Hunter had ample time to quit the organization and go to the police. Indeed, he himself admitted to having left the organization for a time, returning after his former boss, Dave Smith, was murdered.

Scott Stammers, in the North Korean methamphetamine case, made motions suggesting he might also pursue a duress defense. His lawyer demanded that the prosecution hand over, among other