Under § 287, if a false claim is made in one district and presented in another, venue is proper in either location. See, e.g., United States v. Salinas, 373 F.3d 161, 166 (1st Cir. 2004) ("when a statute criminalizes the making and presentment of false claims or statements, venue is proper either where the proffer is made or where it is received"); United States v. Curtiss, 407 Fed.Appx. 663, 667 (4th Cir. 2011) ("[under 18 U.S.C. § 287] venue is proper in any district in which the claims were made, prepared, or presented to the government"); see also United States v. Leahy, 82 F.3d 624, 633 (5th Cir. 1996). In addition, § 287 does not require presentment of a false claim to be made directly to the government.

(ECF No. 39.) Curtiss appealed his conviction to the United States Court of Appeals for the Fourth Circuit, which affirmed the decision on January 13, 2011. United States v. Curtiss, 407 F. App'x. 663, 669 (4th Cir. 2011). That Court subsequently denied Curtiss's motion for rehearing on March 8, 2011.