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Home Source documents Court filing — United States v. Farah (Dkt. 261, D. Minn.)

Court filing — United States v. Farah (Dkt. 261, D. Minn.)

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       CASE 0:22-cr-00124-NEB-TNL Doc. 261 Filed 05/04/23 Page 1 of 19




                           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.
         CASE 0:22-cr-00124-NEB-TNL Doc. 261 Filed 05/04/23 Page 2 of 19




         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




                                    19


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