United States’ Motion to Dismiss — No. 0:21-cr-60020 (Dkt. 546, S.D. Fla.)

Summary

United States' Motion to Dismiss, Document 546 in Case No. 21-CR-60020-DIMITROULEAS/SNOW in the Southern District of Florida, entered on the docket on 03/08/2022. The government moves under Rule 48(a) of the Federal Rules of Criminal Procedure to dismiss the indictment as to one defendant only, because that defendant passed away on February 27, 2022. The motion is signed for the United States Attorney and the Acting Chief of the Criminal Division's Fraud Section by Senior Litigation Counsel and Trial Attorneys of the Fraud Section, with a certificate of electronic filing dated March 8, 2022.

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Case 0:21-cr-60020-WPD Document 546 Entered on FLSD Docket 03/08/2022 Page 1 of 2




                             UNITED STATES DISTRICT COURT
                             SOUTHERN DISTRICT OF FLORIDA

                         Case No. 21-CR-60020-DIMITROULEAS/SNOW

  UNITED STATES OF AMERICA

  vs.

  MARIO KUSTURA,

                         Defendant.
                                           /

                           UNITED STATES’ MOTION TO DISMISS

         The United States of America respectfully moves the Court to dismiss the Indictment filed

  in this case pursuant to Rule 48(a) of the Federal Rules of Criminal Procedure as to defendant

  Mario Kustura only. Mr. Kustura passed away on February 27, 2022.

  Dated: March 8, 2022                               Respectfully submitted,

                                                     JUAN ANTONIO GONZALEZ
                                                     UNITED STATES ATTORNEY

                                                     JOSEPH S. BEEMSTERBOER
                                                     ACTING CHIEF, FRAUD SECTION
                                                     CRIMINAL DIVISION
                                                     DEPARTMENT OF JUSTICE

                                               By:   /s/ Jamie de Boer____________________
                                                     JAMES V. HAYES (FL Bar # A5501717)
                                                     Senior Litigation Counsel
                                                     JAMIE DE BOER (FL Bar # A5502601)
                                                     Trial Attorney
                                                     ANDREA SAVDIE (FL Bar # A5502799)
                                                     Trial Attorney
                                                     United States Department of Justice
                                                     Criminal Division, Fraud Section
                                                     1400 New York Avenue, N.W.
                                                     Washington, D.C. 20005
                                                     Telephone: (202) 304-6801 (de Boer)
                                                     James.Hayes@usdoj.gov
                                                     Jamie.DeBoer@usdoj.gov
                                                     Andrea.Savdie@usdoj.gov
                                                 1
Case 0:21-cr-60020-WPD Document 546 Entered on FLSD Docket 03/08/2022 Page 2 of 2




                                CERTIFICATE OF SERVICE
         I HEREBY CERTIFY that on March 8, 2022, I electronically filed the foregoing document
  with the Clerk of the Court using CM/ECF.
                                                   /s/ James V. Hayes




                                               2


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