Motion to Allow Travel by Defendant — United States v. Hamdi Hussein Omar (D. Minn., Doc. 201)

Summary

A Motion to Allow Travel by Defendant, filed 12/21/23 as Doc. 201 in United States v. Hamdi Hussein Omar (12), Criminal No. 22-CR-223 (NEB/TNL), in the U.S. District Court for the District of Minnesota. Omar asks for an order returning her passport and allowing her to travel to Saudi Arabia for Hajj from January 24, 2024 and returning on February 13, 2024. Her counsel states that she will travel with her mother, who has ongoing health concerns, and that he has her itinerary. He states that AUSA Joseph Thompson opposes the request, citing among other reasons that the United States has no extradition treaty with Saudi Arabia. Counsel states that Omar has complied with her conditions of release. The motion is dated December 21, 2023.

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       CASE 0:22-cr-00223-NEB-TNL Doc. 201 Filed 12/21/23 Page 1 of 2




                     UNITED STATES DISTRICT COURT
                         DISTRICT OF MINNESOTA
                    Criminal No.: 22-CR-223 (12) (NEB/TNL)

UNITED STATES OF AMERICA,               )
                                        )
                           Plaintiff,   )
vs.                                     )       MOTION TO ALLOW TRAVEL BY
                                        )               DEFENDANT
                                        )
Hamdi Hussein Omar,                     )
                                        )
                                        )
       Defendant.                       )



      The defendant, Hamdi Hussein Omar, respectfully moves the Court for an

Order allowing her to travel to Saudia Arabia for Hajj. Specifically, Ms. Omar seeks

an order to return her passport and to allow her travel to Saudi Arabia from January

24, 2024, and returning on February 13, 2024. Counsel for Ms. Omar has obtained

her specific travel itinerary including her proposed flights and hotel information if

requested. Ms. Omar will be traveling with her mother, who has ongoing health

concerns requiring some degree of assistance by Ms. Omar.

      Counsel has spoke with Mr. Joseph Thompson the AUSA of record regarding

this request and he opposes it, citing among other reasons that the United States has

no extradition treaty with Saudi Arabia. Counsel states upon information and belief




                                            1
        CASE 0:22-cr-00223-NEB-TNL Doc. 201 Filed 12/21/23 Page 2 of 2




that Ms. Omar has to date been in compliance with all the terms of her conditional

release in this matter.



Respectfully submitted,

Dated: This 21st day of December, 2023       /s/ Robert M. Paule
                                             Robert M. Paule (#203877)
                                             Robert M. Paule, P.A.
                                             920 Second Avenue South
                                             Suite 975
                                             Minneapolis, MN 55402
                                             T: (612) 332-1733
                                             F: (612) 332-9951




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