Opinion
Case No. 3:10-cr-00260-8
02-23-2012
William J. Haynes
Federal District Judge
MOTION TO SEVER COUNTS
Comes now the accused, through her appointed Counsel, and would move this Honorable Court, pursuant to Rules 8 and 14 of the Federal Rules of Criminal Procedure, to sever Count 23 from Counts 1, 2 and 11 in this cause. In support thereof the accused would state the following:
1. According to the Government's indictment, filed May 4, 2011, (Document No. 591], Count 23 charges Mrs. Farah with violation of 18 U.S.C. § 1001 for allegedly making a material false statement in a matter within the jurisdiction of a department or agency of the United States. More specifically, the Government alleges that the accused, on or about August 21, 2009, stated:
1. That in the past 10 years she had not procured anyone for prostitution, or intended to engage in such activities.Well knowing and believing the following:
2. That she had not received public assistance in the United States from any source, including the United States government, or any state, county, city or municipality (other than emergency medical treatment), and that she was not likely to receive public assistance in the future.