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Motion for Furlough — United States v. Farah (Dkt. 708, D. Minn.)

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        CASE 0:22-cr-00124-NEB-DTS        Doc. 708   Filed 11/08/24    Page 1 of 2




                            UNITED STATES DISTRICT COURT
                               DISTRICT OF MINNESOTA

  United States of America,           )
                                      )    DEFENDANT ABDIAZIZ SHAFII
               Plaintiff,             )    FARAH'S MOTION FOR A FURLOUGH
  vs.                                 )
                                      )    Crim. No. 24-173 (DSD/DLM)
  Abdiaziz Shafii Farah,              )    Crim. No. 22-124 (NEB-DTS)
                                      )
               Defendant.             )


        Defendant Abdiaziz Shafii Farah through his undersigned counsel respectfully

moves the Court for an Order granting him a furlough from his pretrial detention for a

period of four weeks to assist his wife after the birth of their new child earlier this

week.

        Counsel understands the birth of the new child earlier this week had to be

induced early because of the risks to both mother and child. Counsel understands the

child suffers from a heart condition and mother suffered from a variety of health

conditions during the pregnancy, and they remain at the hospital at the time of this

writing, but both are doing well.

        Counsel also understands the couple already are parents to three children, aged

6, 2½, and 11 months (a special-needs daughter, requiring significant, daily, hands-on

attention and support). Counsel’s understanding is Defendant Farah seeks this

parental-leave furlough for the purpose of assisting his wife in navigating the first few
     CASE 0:22-cr-00124-NEB-DTS        Doc. 708       Filed 11/08/24   Page 2 of 2




weeks of difficulties in caring for a new-born, a special needs child, and two other

young children.

      Defendant Farah is willing to submit to any appropriate conditions during the

furlough, including total home-confinement, with an ankle monitor, and daily or even

hourly check-in with probation or the police. Mr. Gerdts, Mr. Farah’s Counsel in case

number 24-cr-173 (DSD/DLM), sought the Government’s position regarding this

motion, but the Government has not as of yet responded.

Dated: 8 November 2024                 Respectfully submitted,

                                       DANIEL L. GERDTS, LAWYER

                                       s/ Daniel L. Gerdts

                                       Daniel L. Gerdts (#207329)
                                       331 Second Avenue South, Suite 705
                                       Minneapolis, MN 55401
                                       612.800.5086
                                       Counsel in Case 24-Cr-173 (DSD/DLM)



                                       Birrell Law Firm PLLC

                                       s/ Andrew S Birrell

                                       Andrew S. Birrell (#0133760)
                                       Ian S. Birrell (#0396379)
                                       333 South Seventh Street
                                       Ste 3020
                                       Minneapolis, MN 55402
                                       Counsel in Case 22-Cr-124 (NEB/DTS)



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