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Letter to Magistrate Judge — United States v. Farah (Dkt. 164, D. Minn.)
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CASE 0:22-cr-00124-NEB-TNL Doc. 164 Filed 11/14/22 Page 1 of 1
TEL: (612) 238-1939
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333 S. 7th St., Suite 3020
Minneapolis, MN 55402
November 14, 2022
The Honorable Tony N. Leung VIA ECF ONLY
Magistrate Judge, District of Minnesota
United States District Court
300 S. 4th St.
Minneapolis, MN 55415
Re: United States of America v. Abdiaziz Shafii Farah, 22-CR-124(1)
Good morning Your Honor and Chambers Staff:
I write to request this Court issue a ruling on the Motion for a Protective Order before this
Court (as articulated and discussed in ECF No.s 151, 157, and 158).
The government has represented it will not provide discovery in this case to defense counsel
until a protective order is issued but will provide discovery promptly after one is issued. Mr.
Farah is detained in jail pending trial and has made a speedy trial demand. He thus wishes to
do everything possible to ensure the case is handled as expeditiously as reasonably possible.
The government has represented in its filings that “discovery will total several millions of
pages of documents.” In its proposed case management schedule, the government suggested
that, after it provides discovery, the Court Order the defendants in the case have 120 days to
file pretrial motions. (ECF No. 160). Mr. Farah and one codefendant proposed a quicker
schedule (ECF No.s 155, 156). Other codefendants proposed this Court hold a scheduling
conference. (ECF No. 159). Mr. Farah respectfully submits that, regardless of the schedule
this Court ultimately sets, his constitutional rights are best protected by this Court granting the
Motion for a Protective Order and issuing an Order so that he and counsel can begin reviewing
the millions of pages of documents at issue.
Mr. Farah emphasizes the time he is spending in jail as a presumptively innocent citizen
prejudices him greatly, and the discovery provision process being handled as quickly as
possible hopefully helps protect his constitutional rights. Mr. Farah submits that the Court
issuing such an Order prejudices no party but helps protect his rights. He thus respectfully
requests the Court act accordingly.
Thank you very much for your consideration.
Respectfully,
/s/ Ian S. Birrell
Ian S. Birrell
BIRRELL LAW FIRM, PLLC ian@birrell.law (612) 238-1939