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UNITED STATES DISTRICT COURT
DISTRICT OF MINNESOTA
United States of America, Court File No. 22-cr-124 (NEB/TNL)
Plaintiff,
v. MEMORANDUM OF LAW IN
SUPPORT OF JOINT MOTION FOR
Abdiaziz Shafii Farah et al., CHANGE OF VENUE
Defendants.
Defendants Abdiaziz Shafii Farah, Mohamed Jama Ismail, Mahad Ibrahim, Said
Shafii Farah, Abdiwahab Maalim Aftin, and Mukhtar Mohamed Shariff (“Defendants”)
individually and for the benefit of all Defendants, submit this memorandum in support of
their Motion for Change of Venue. Due to the Government’s actions, including holding
multiple press conferences, the media attention in this case has been expansive and
inflammatory. In particular, the Government’s September 20, 2022 press conference—
which included displaying what may be grand jury material to the public in violation of
Federal Rule of Evidence 6(e)—was essentially a closing argument that primed the public
to presume the Defendants guilty. The hundreds of media articles that followed have been
just as or more inflammatory, concluding that the Defendants are guilty and stating
allegations as fact, even though discovery in this case has demonstrated that many of the
Government’s statements are inaccurate. Public comments to these articles, many of which
are alarmingly racist, demonstrate the degree to which the jury pool has been tainted.
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The inflammatory media coverage, which was precipitated by the Government’s
statements, has primed the jury pool to find the Defendants guilty such that they will be
unable to receive a fair trial in this District. Accordingly, Defendants respectfully request
the Court transfer venue for the trial to the Northern District of Illinois.
BACKGROUND
On January 11, 2022, the Government obtained search warrants for its investigation
into allegations of federal child nutrition program fraud. See Declaration of Steven L.
Schleicher in Support of Motion for Change of Venue (“Schleicher Decl.”), Ex. A. On
January 20, 2022 the Government filed a motion to unseal those search warrants, which
was granted the same day. See Id., Exs. B-C. On February 1, 2022, the order was amended
to unseal the warrants, applications, and affidavits as well. Id. Ex. D. This spurred an initial
flurry of media attention, including articles such as the creatively titled “Crook Bastard
Nonprofits Took Pandemic Money, Put Fraud on Minnesota Food Programs, Allegedly.”
Id., Ex. E. Other inflammatory and prejudicial articles included one titled “‘Outrageous’
$197 million fraud scheme bought houses, cars and luxury goods instead of food for
starving children.” Id. Ex. F. Articles routinely report allegations as fact, claiming that the
Government has “discovered a ‘massive fraud scheme’” and routinely repeating the
Government’s statements that “[a]lmost none of this money was used to feed children.” Id.
Ex. G.
Then, on September 20, 2022, the Department of Justice issued a press release
proclaiming that the Defendants had
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exploited a program designed to provide nutritious food to
needy children during the COVID-19 pandemic. Instead, they
prioritized their own greed, stealing more than a quarter of a
billion dollars in federal funds to purchase luxury cars, houses,
jewelry, and coastal resort property abroad.
See Schleicher Decl., Ex. H. That same day, the United States Attorney’s office held an
extensive press conference, the video of which remains available and accessible on The
Justice Department’s YouTube Page. See The Justice Department, USAO-MN Announces
Charges Against 47 Defendants in $250 Million Feeding Our Future Fraud Scheme,
YOUTUBE (Sept. 20, 2022), https://www.youtube.com/watch?v=lXBVWVnXJrg. In that
press conference, the Government made sweeping claims about all of the defendants
charged—many of which were simply not accurate with respect to these Defendants. See,
e.g., Id. at 7:00-7:14 (“[T]he defendants primarily pocketed the money for themselves.
Spending little on food, staff, and logistics.”). This press conference ignited a new flurry
of media attention, including coverage of the public inflammatory comments by the
Minnesota Governor suggesting that the judge in the Feeding our Future civil case should
be investigated. Schleicher Decl., Ex. I. In a gubernatorial debate, the Governor, referring
to the Defendants, said that he “doesn’t want to ‘jeopardize any opportunity to put these
people in prison’ while the federal investigation is ongoing.” Id., Ex. J. Even the Minnesota
Attorney General’s office weighed in, releasing an extensive press release claiming that
without the Attorney General’s office “there would likely have been no federal
investigation or indictments.” Id. Ex. K.
Significant media attention has continued since then; a google news search for
articles after the date of the January 11, 2022 search warrant reveals nearly a thousand
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results for “Feeding our Future” with over a hundred results in the last month alone.
Schleicher Decl. ¶ 13. Not only have articles remained inflammatory, reporting as fact the
explosive and inaccurate allegations pulled from the Government’s extensive press
conference, but many public comments to those articles contain shocking and racist
comments directed at the Defendants. For example, in response to an article published on
March 13, 2022, commenters posted over a hundred racist comments, including that “the
element of grifting [is] a virtue in Somali culture,” “black lies matter” and “[c]an I hear a
call for a stoning followed by a garroting?” Id., Ex. L. Comments on an Alpha News Article
released the day of the Government’s first press-conference likewise were filled with
statements such as “[d]eport the Somalis . . . American jails are too good for these
criminals!” and “[t]hese scammers are born with the ability to cheat, lie & steal! No rules
when the victim is an Infidel! . . . Each should be tried, convicted, sentenced to long prison
sentences (preferably Guantanamo) deported back to their shit holes on release, NEVER
to live again in America!” Id. Ex. M. Sadly, these comments are not isolated and can be
found on many, if not most, of the articles about this investigation which continue to be
published to this day.
Meanwhile, the Government continues to hold press conferences, which lead to
additional media coverage. See, e.g., Fox 9 Minneapolis-St. Paul, LIVE: U.S. Attorney
announcing more charges in Feeding Our Future fraud scheme, Y OUTUBE (Mar. 13, 2023),
https://www.youtube.com/watch?v=3YoTexedQr8. And the presence of the September 20,
2022 press conference on the Justice Department’s YouTube Page constitutes on-demand
republication of the statements made and documents displayed every single day.
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ARGUMENT
I. STANDARD
The Defendants are entitled to a “fair[] [trial] in a public tribunal free of prejudice,
passion, excitement, and tyrannical power.” Sheppard v. Maxwell, 384 U.S. 333, 350
(1966). That entitlement is precisely why the Federal Rules of Criminal Procedure provide
that
the court must transfer the proceeding against that defendant to
another district if the court is satisfied that so great a prejudice
against the defendant exists in the transferring district that the
defendant cannot obtain a fair and impartial trial there.
Fed. R. Crim. P. 21(a). Rule 21 is discretionary, and as such this Court has broad discretion
to determine whether Defendants have demonstrated sufficient prejudice to warrant
transfer of venue.
Appellate courts have held transfer is mandatory where “pretrial publicity was so
extensive and corrupting that a reviewing court is required to ‘presume unfairness of
constitutional magnitude.’” United States v. Blom, 242 F.3d 799, 803 (8th Cir. 2001)
(quoting Pruett v. Norris, 153 F.3d 579. 585 (8th Cir. 1998)). Even if that standard is not
satisfied, transfer may still be mandatory where “the voir dire testimony of those who
became trial jurors demonstrated such actual prejudice that it was an abuse of discretion to
deny a timely change-of-venue motion.” Id. (reviewing for abuse of discretion). Here,
pretrial publicity has been so extensive and corrupting that this Court can presume
unfairness of constitutional magnitude. However, regardless of whether transfer is
mandatory, it is within this Court’s discretion to, and the Court should, order transfer under
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Rule 21 because pretrial publicity has created so great a prejudice that that Defendants
cannot obtain a fair and impartial trial in this District.
II. TRANSFER OF VENUE IS REQUIRED DUE TO SIGNIFICANT
GOVERNMENT-GENERATED UNFAIRLY PREJUDICIAL PRETRIAL
PUBLICITY.
District Courts have wide discretion in determining whether change of venue based
upon pretrial publicity is warranted, and consider factors including (1) the Government’s
culpability in generating pretrial publicity, (2) the extent of the media coverage and
whether it is ongoing; (3) the objectivity of the media coverage; and (4) public opinion
data. See, e.g., United States v. Rodriguez, 581 F.3d 775, 785–86 (8th Cir. 2009)
(discussing public opinion data); United States v. Nelson, 347 F.3d 701, 709 (8th Cir. 2003)
(looking at time elapsed between crime and trial); United States v. Allee, 299 F.3d 996,
1000 (8th Cir. 2002) (considering the objectivity of news reports); United States v. Blom,
242 F.3d 799, 804 (8th Cir. 2001) (looking at extent, timing, and objectivity of reports);
United States v. Maldonado-Rivera, 922 F.2d 934, 967 (2d Cir. 1990) (“In assessing the
motion, the district court may take into account, inter alia, the extent to which the
Government is responsible for generating the publicity.”). The balance of these factors, and
especially the Government’s culpability in generating inaccurate and inflammatory
publicity in violation of the federal rules of criminal procedure, warrants transfer of venue
in this matter.
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A. The Government’s Press Conference Violated Federal Regulations, May
have Violated Federal Rule of Criminal Procedure 6(e) and Improperly
Generated Significant Inflammatory Publicity.
One of the major factors courts consider for transfer of venue related to publicity is
“the extent to which the Government is responsible for generating the publicity.” See
Maldonado-Riviera, 922 F.2d at 967; see also Sheppard v. Maxwell, 384 U.S. 333, 361
(1966) (“The fact that many of the prejudicial news items can be traced to the prosecution,
as well as the defense, aggravates the judge’s failure to take any action.”); United States v.
Burge, No. 08 CR 846, 2009 WL 2386147, at *5 (N.D. Ill. July 29, 2009) (considering
“whether the Government was responsible for the publication of the objectionable
material”); United States v. Jamieson, 264 F. Supp. 2d 603,605 (N.D. Ohio 2003)
(explaining that the “source of the publicity” can be considered in the court’s decision to
grant or deny a rule 21(a) motion).
On September 20, 2022, the United States Attorney’s office issued a press release
and held a press conference to announce charges in its Feeding our Future investigation.
See The Justice Department, USAO-MN Announces Charges Against 47 Defendants in
$250 Million Feeding Our Future Fraud Scheme, YOUTUBE (Sept. 20, 2022),
https://www.youtube.com/watch?v=lXBVWVnXJrg. There are specific guidelines for the
release of information by DOJ personnel related to criminal proceedings. These rules were
formulated because the availability information to the news media has become a “subject
of concern in the administration of justice.” 28 C.F.R. 50.2(a)(1). Accordingly, DOJ
employees shall not “furnish any statement or information for the purpose of influencing
the outcome of a defendant's trial… [or] furnish any statement or information, which could
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reasonably be expected to be disseminated by means of public communication, if such a
statement or information may reasonably be expected to influence the outcome of a
pending or future trial.” 28 C.F.R. 50.2(b)(2). The information that is authorized for
disclosure is generally factual and non-inflammatory, including the defendant's name, age,
residence, employment, marital status, and similar background information; the substance
or text of the charge, such as a complaint, indictment, or information; the identity of the
investigating and/or arresting agency and the length or scope of an investigation; the
circumstances immediately surrounding an arrest, including the time and place of arrest,
resistance, pursuit, possession and use of weapons, and a description of physical items
seized at the time of arrest. See 28 C.F.R. 50.2(b)(3). “Disclosures should include only
incontrovertible, factual matters, and should not include subjective observations. In
addition, where background information or information relating to the circumstances of an
arrest or investigation would be highly prejudicial or where the release thereof would serve
no law enforcement function, such information should not be made public.” Id. The
September 20, 2022 press conference went well beyond these rules. The Government made
arguments, statements of opinion, provided inaccurate information and improperly
displayed documents.
For example, the Government’s press conference featured a slideshow, during
which on two separate occasions, the Government displayed “Summer Meal Counts”
forms, and discussed the contents of those forms in detail:
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REDACTED
Id. at 13:36.
REDACTED
Id. at 22:53. The Government subsequently produced those two forms in discovery. Upon
review, it appears that those two forms are grand jury materials obtained pursuant to grand
jury subpoenas and BATES labeled GJM-0000748 (signifying “Grand Jury Material”) and
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GJS-00382317 (signifying “Grand Jury Subpoena”). 1 See Schleicher Decl. ¶ 16. If true,
this disclosure violated not only the Department of Justice’s own guidelines for the
dissemination of information, see 28 C.F.R. 50.2(b)(2), but directly violated the Federal
Rule of Criminal Procedure 6(e) prohibition on dissemination of grand jury materials to
the public. Fed. R. Crim. P. 6(e)(2)(B) provides that an attorney for the Government must
not disclose a matter occurring before the grand jury. Records, orders, and subpoenas
relating to grand-jury proceedings must be kept under seal to the extent and as long as
necessary to prevent the unauthorized disclosure of a matter occurring before a grand jury.
Fed. R. Crim. P. 6(e)(6).
Rule 6(e) “establishes a ‘general rule of confidentiality for all matters occurring
before the grand jury.’” United States v. McDougal, 559 F.3d 837, 840 (8th Cir. 2009)
(noting the rule applies to all sealed grand jury materials). Rule 6(e) protects the integrity
and legitimacy of the both the grand jury and subsequent criminal proceedings by
preventing disclosure of secret materials to the public that could improperly taint the
investigation and, ultimately, the jury pool.
Displaying any document or potential exhibit to the general public is problematic.
“The possible exposure of jurors to such information that is not admitted could lead to
grounds for reversal” in future possible appeals. United States v. McNally, 485 F.2d 398,
404 (8th Cir. 1973) (condemning a district attorney’s release of medical information before
1
During a meet and confer on May 3, 2023, undersigned counsel requested the Government
disclose whether the two referenced documents were obtained outside of the grand jury
process prior to September 20, 2022. The Government has not yet responded.
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it was admitted into evidence at trial). Improperly publishing these documents to the public
during a press conference served no purpose other than to taint the jury pool, requiring
transfer in addition to other possible remedies deemed appropriate by the Court to prevent
jurors from impermissibly using inadmissible evidence in their determination at the
upcoming trial.
Compounding the prejudice, and using potential 6(e) material as a visual aid, the
Government essentially delivered its closing argument and rebuttal, arguing: that “[n]o one
participating in this . . . program legitimately would ever imagine that they could hire staff,
purchase food, store food, handle the logistics involved in this process, make meals, serve
them to children, and still make millions of dollars. It’s not possible.” Id. at 6:17-6:40.
Defendants maintain their presumption of innocence and it is the Government’s burden to
prove knowing participation in a fraudulent scheme. The Government’s blanket statement,
however, serves to prime the jury pool for a “willful blindness” argument as a substitute
for the lack of direct evidence connecting Defendants to a knowing participation in the
alleged fraud. These statements, and indeed the entirety of the press conference, violated
the Department of Justice’s own regulations that prohibit making statements “concerning
evidence or argument in the case” as well as statements as to “[a]ny opinion as to the
accused’s guilt . . . .” 28 C.F.R. 50.2(b)(6)(v-vi). This public closing argument provided
the basis for the hundreds of news stories that would follow, and guaranteed that any
prospective jurors in this district will repeatedly hear the Government’s arguments before
they ever enter the courtroom. At the very least, the Government should be precluded from
making a willful blindness argument or obtaining a willful blindness instruction at trial.
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In the live press conference, the Government also argued that “[h]ere, the defendants
primarily pocketed the money for themselves. Spending little on food, staff, and logistics.”
Id. at 7:00-7:14. This statement is not accurate as to the Defendants herein, who in fact
spend significant sums of money on food, staff, and logistics. The claim that they spent
the vast majority of Government funds on luxury goods is unsupported. Nonetheless, the
Government’s public statements, both in the press conferences and unsealed warrant
documents, spawned volumes of news articles reaching the same, consistent conclusion:
that Defendants are guilty, and that they served little or no food. See, e.g., Id. Exs. E-K. By
placing these statements in the public domain, the Government spread a false narrative that
has now primed the public to presume the Defendants’ guilt.
B. The Media Coverage in this Case is Extensive and Ongoing.
There may be a “presumption of inherent prejudice” when media coverage is so
extensive, “inflammatory or accusatory as to presumptively create ‘a trial atmosphere that
had been utterly corrupted by press coverage.’” Blom, 242 F.3d at 804. Courts consider
whether there has been a “substantial delay between the criminal act and the trial” when
determining whether a “presumption of inherent unfairness” exists requiring transfer.
United States v. Nelson, 347 F.3d 701, 709 (8th Cir. 2003) (finding that “media coverage
decreased significantly to the point of vanishing” between the time of the crime and the
time of trial). Here, a google news search for articles published after the date of the January
11, 2022 search warrant reveals nearly a thousand results for “Feeding our Future” with
over a hundred results in the last month alone. Schleicher Decl. ¶ 13. The Government has
held multiple press conferences, one recently, and stated that there are more to come. See
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The Justice Department, USAO-MN Announces Charges Against 47 Defendants in $250
Million Feeding Our Future Fraud Scheme, YOUTUBE (Sept. 20, 2022),
https://www.youtube.com/watch?v=lXBVWVnXJrg; Fox 9 Minneapolis-St. Paul, LIVE:
U.S. Attorney announcing more charges in Feeding Our Future fraud scheme, Y OUTUBE
(Mar. 13, 2023), https://www.youtube.com/watch?v=3YoTexedQr8. It is clear from the
thousands of articles, repeated press conferences, and hundreds of recent articles that media
coverage of this case will not die down, and is likely to expand once trial approaches.
Although some time has passed since the execution of the Government’s search
warrants, and more will likely pass before trial, it is clear that the Government’s repeated
public statements are working, and media coverage of this investigation will only intensify
before trial. Just as coverage explodes every time the government holds a press conference,
media coverage will continue and expand the closer this case moves to trial. The extensive
and ongoing nature of media coverage in this case creates a presumption of inherent
prejudice based upon the pervasiveness of inflammatory and accusatory public statements
by the Government and media coverage that follows. This warrants transfer of venue
outside of Minnesota, where the public is not so saturated with news articles and statements
from federal and elected state officials unequivocally claiming Defendants’ guilt.
C. Media Coverage has Not Been Objective and has Presumed Defendants
Guilty.
“[I]nflammatory publicity” can create an environment where “jurors cannot help but
feel the pressures of knowing that friends and neighbors have their eyes upon them”
resulting in inherent prejudice to a defendant. See Estes v. Tex., 381 U.S. 532, 545 (1965);
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Maxwell, 384 U.S. at 363 (reversing based upon “inherently prejudicial publicity which
saturated the community”). This is especially true when media coverage is not “largely
factual in nature.” Murphy v. Florida, 421 U.S. 794, 802 (1975). Here, the Government
generated massive coverage, which continues as the Government holds additional press
conferences, generating media coverage that conclusively presumes Defendants guilty and
reiterates the factually inaccurate statements made during the Government’s first press
conference.
Far from reporting pure facts and allegations, many of the hundreds of articles
published every month heavily reference the Government’s statement that “[a]lmost none
of that money was used to feed children.” Schleicher Decl. Exs. E-G. The Government’s
press release stated these allegations as if they were fact, quoting the United States Attorney
as saying that “[t]hese defendants exploited a program designed to provide nutritious food
to needy children during the COVID-19 pandemic.” Id., Ex. H. Defendants obviously
contests these claims, which are mere allegations and, Defendants contend, not
representative of the evidence which will be presented at trial. Media coverage has,
however, been as one-sided as the Government’s press releases because the media has only
been exposed to the Government’s one-sided opinions. Unlike the Government,
Defendants have not held press conferences or released documents to the media. Nor do
they plan to do so—the discovery documents were provided pursuant to the Court’s
protective order.
As was identified in Estes, these false, inflammatory statements have inherently
prejudiced defendants, requiring transfer to a venue where these statements have not been
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so pervasive a part of the news cycle such that jurors will not “feel the pressures of knowing
that friends and neighbors have their eyes upon them.”
D. Public Comments On News Stories Have Been Inflammatory,
Demonstrating the Need for Transfer.
Courts look to public opinion data, including public comments, when assessing
whether public opinion is unfairly prejudiced towards guilt. See, e.g., United States v.
Petters, No. 08-cr-364 (RHK/AJB), 2009 WL 3430133, at *2 (D. Minn. Oct. 16, 2009)
(finding in that case that “[a] few derogatory comments” were not enough to indicate
substantial prejudice). Although Defendants have not yet undertaken the significant effort
and expense of public opinion polling, the public commentary sufficiently demonstrates
that the potential jury pool in the District has been inflamed and the Defendants would be
unable to receive a fair trial. This goes far beyond the “few derogatory comments” in
Petters, and constitutes hundreds of inflammatory comments on individual articles. Many
commenters focus primarily on the Somali heritage of the Defendants, making racist claims
that “the element of grifting [is] a virtue in Somali culture,” and that the Defendants are
“scammers” who were “born with the ability to cheat, lie & steal!” See Schleicher Decl.
Exs. K, L. They also focus on extreme punishments for the Defendants, including “stoning
followed by a garroting,” deportation “back to their shit holes,” and “sentenc[ing] to long
prison sentences (preferably Guantanamo) . . . .” Id. Exs. L, M.
These comments sections provide just two examples of public comments on the
more than one thousand articles that discuss the Feeding our Future investigation. Many
articles contain similar commentary, demonstrating the extent to which the extensive
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coverage based upon the Government’s accusatory public statements has poisoned public
sentiment against the Defendants. Whereas in Petters the Government publicly stated that
his victims were only his investors, here multiple federal and elected state officials have
repeatedly told Minnesotans, and indeed all Americans, that they as taxpayers are victims
of Defendants’ alleged wrongdoing, as well as, of course “needy children.” Id. Ex. H. This
has deeply prejudiced the jury pool against Defendants, presumptively warranting transfer.
III. THE NORTHERN DISTRICT OF ILLINOIS IS AN APPROPRIATE
VENUE FOR TRANSFER.
This Court has broad discretion to determine which “less prejudicial district” is
appropriate for transfer of venue. See United States v. Angiulo, 497 F.2d 440, 441 (1st Cir.
1974). When assessing where to transfer, courts generally consider locations that are
outside the zone of the case’s negative media coverage, in a larger city, with convenient
flights and lodging options, and the capacity to take on additional cases. See United States
v. Moody, 762 F. Supp. 1485, 1490 (N.D. Ga. 1991) (citing United States v. Dioguardi,
428 F.2d 1033, 1039 (2d Cir. 1970). Here, there has been national media coverage of this
case but state and local media outlets outside of Minnesota have far less extensively
reported on this story. Looking at places with larger populations, outside of Minnesota,
with convenient flights and capacity, Defendants recommend that the Court transfer this
case to the Northern District of Illinois which would satisfy those appropriate
considerations. See, e.g., United States Courts, Federal Judiciary Caseload Statistics,
Comparison of Districts (March 31, 2022), https://www.uscourts.gov/
sites/default/files/data_tables/fcms_na_distcomparison0331.2022.pdf. Transfer to the
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Northern District of Illinois would be convenient for all parties, while mitigating some of
the significant prejudice caused by the Government’s press conferences and disclosures,
and the significant inflammatory prejudicial news coverage that followed. Although news
articles on the case are available nation-wide, there is no question that articles have been
most widely released and consumed in Minnesota, and elected officials of other states have
not publicly commented on this investigation in the same way that those in Minnesota have.
Therefore, due to its convenience and amenability to transfer, the Northern District of
Illinois would be an appropriate venue for transfer.
CONCLUSION
For all of these reasons, Defendants respectfully requests the Court order that venue
be transferred to the Northern District of Illinois for trial.
Respectfully submitted,
Dated: May 4, 2023 MASLON LLP
By: /s/ Steven L. Schleicher
Steven L. Schleicher (#0260587)
Clayton J. Carlson (#0401182)
3300 Wells Fargo Center
90 South Seventh Street
Minneapolis, MN 55402-4140
(612) 672-8200
Email: steve.schleicher@maslon.com
clayton.carlson@maslon.com
ATTORNEYS FOR DEFENDANT SAID
SHAFII FARAH
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Dated: May 4, 2023 BIRRELL LAW FIRM PLLC
By: /s/ Ian S. Birrell
Andrew S. Birrell (#133760)
Ian S. Birrell (#0396379)
333 South 7th Street, Suite 3020
Minneapolis, MN 55402
(612) 238-1939
Email: andy@birrell.law
ian@birrell.law
ATTORNEYS FOR DEFENDANT ABDIAZIZ
SHAFII FARAH
Dated: May 4, 2023 SIEBEN & COTTER PLLC
By: /s/ Patrick Cotter
Patrick Cotter (#0319120)
105 Hardman Ct., #110
South St. Paul, MN 55075
(651) 455-1555
Email: patrick@siebencotterlaw.com
ATTORNEYS FOR DEFENDANT MOHAMED
JAMA ISMAIL
Dated: May 4, 2023 MAUZY LAW FIRM
By: /s/ William Dooling
William J. Mauzy (#68974)
William R. Dooling (#0402244)
650 Third Avenue South, Suite 260
Minneapolis, MN 55402
(612) 504-5533
Email: wmauzy@mauzylawfirm.com
wdooling@mauzylawfirm.com
ATTORNEYS FOR DEFENDANT MAHAD
IBRAHIM
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Dated: May 4, 2023 KOCH & GARVIS, LLC
By: /s/ Andrew S. Garvis
Andrew S. Garvis (#257989)
3109 Hennepin Avenue South
Minneapolis, MN 55408
(612) 827-8101
Email: andrew@uptownlawyer.com
ATTORNEYS FOR DEFENDANT
ABDIWAHAB MAALIM AFTIN
Dated: May 4, 2023 GOETZ & ECKLAND P.A.
By: /s/ Frederick J. Goetz
/s/ Andrew H. Mohring
Frederick J. Goetz (#185425)
Andrew H. Mohring (#190731)
Banks Building
615 1st Avenue NE, Suite 425
Minneapolis, MN 55413
(612) 874-1552
Email: FGoetz@goetzeckland.com
amohring@goetzeckland.com
ATTORNEYS FOR DEFENDANT MUKHTAR
MOHAMED SHARIFF
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