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Motion for Preliminary Order of Forfeiture as to Mohammad Ribhi Farraj — No. 4:22-cr-00140-JD-1 (Dkt. 198, D.S.C.)

Summary

In this motion dated March 29, 2023, Assistant U.S. Attorney Carrie Fisher Sherard asks the United States District Court for the District of South Carolina, Florence Division, to enter a Preliminary Order of Forfeiture as to Mohammad Ribhi Farraj in Criminal No. 4:22-cr-00140-JD-1. The motion, brought under Fed. R. Crim. P. 32.2(b), rests on Farraj's conviction of conspiracy to commit wire fraud related to Unemployment Insurance programs in New York, Florida and South Carolina, in violation of Title 18, United States Code, Sections 1343 and 1349. It asks that the order be entered far enough ahead of sentencing for the parties to suggest revisions or modifications, as Rule 32.2(b)(2)(B) requires unless doing so is impractical. The motion is filed for United States Attorney Adair F. Boroughs.

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Full text

                     IN THE UNITED STATES DISTRICT COURT
                          DISTRICT OF SOUTH CAROLINA
                               FLORENCE DIVISION

UNITED STATES OF AMERICA                 )       CRIMINAL NO.: 4:22-cr-00140-JD-1
                                         )
              vs.                        )
                                         )
MOHAMMAD RIBHI FARRAJ                    )


               MOTION FOR PRELIMINARY ORDER OF FORFEITURE
                      AS TO MOHAMMAD RIBHI FARRAJ

      Pursuant to Fed. R. Crim. P. 32.2(b), the United States of America, by and through

its undersigned Assistant United States Attorney, Carrie Fisher Sherard, moves this Court

for the entry of a Preliminary Order of Forfeiture as to Mohammad Farraj, (“Farraj”,

“Defendant”), based on the Defendant=s conviction of conspiracy to commit wire fraud

related to Unemployment Insurance programs in New York, Florida, and South Carolina,

in violation of Title 18, United States Code, Sections 1343 and 1349.

      The Government further requests that such order be entered by this Court

sufficiently in advance of sentencing to permit time for the Government and the Defendant

to suggest revisions or modifications. Fed. R. Crim. P. 32.2(b)(2)(B) (AUnless doing so is

impractical, the court must enter the preliminary order sufficiently in advance of

sentencing to allow the parties to suggest revisions or modifications before the order

becomes final as to the defendant under Rule 32.2(b)(4).@)



                          [SIGNATURE PAGE TO FOLLOW]


                                             1
                 Respectfully submitted,

                 ADAIR F. BOROUGHS
                 UNITED STATES ATTORNEY

                 By:     s/Carrie Fisher Sherard
                       Carrie Fisher Sherard #10134
                       Assistant United States Attorney
                       55 Beattie Place, Suite 700
                       Greenville, SC 29601
                       (864) 282-2100
March 29, 2023




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