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`United States of America,
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` Plaintiff,
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` v.
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`Sidoo et al,
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` Defendants.
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`
`United States District Court
`District of Massachusetts
`)
`)
`)
`)
`)
`) Criminal Action No.
`) 19-10080-NMG
`)
`)
`)
`)
`
`
`
`MEMORANDUM & ORDER
`
`
`GORTON, J.
`The government has charged defendants with conspiring with
`William “Rick” Singer (“Singer”) to have their children
`fraudulently admitted to elite universities by, inter alia,
`fabricating applications, falsifying academic and athletic
`credentials, cheating on standardized tests, making payments to
`corrupt exam proctors and bribing university employees and
`athletic coaches. The defendants have moved to dismiss the
`indictment on the basis that venue is improper in the District
`of Massachusetts. For the following reasons that motion will be
`denied.
`I.
`Background
`The facts of this case have been extensively recited
`several times by this Court. See Docket Nos. 1169, 1334 and
`1373. Relevant to venue in this District, the Fourth
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`Superseding Indictment (“the FSI”) alleges that defendants
`engaged in the following acts in furtherance of the conspiracy
`to gain admission for their children to universities, including
`those located in the District of Massachusetts:
`
`(1) Defendants submitted fraudulent transcripts to
`universities, including those in the District of
`Massachusetts.
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`(2) Singer mailed at least one check from Massachusetts to
`USC athletics administrator Donna Heinel in exchange for
`her participation in the “side-door” scheme.
`(3) Fraudulent ACT scores obtained by Mark Riddell (a corrupt
`test proctor) were submitted on behalf of defendant Chen
`via interstate wire to Emerson College in Boston,
`Massachusetts and on behalf of Defendant McGlashan to
`Northeastern University in Boston.
`(4) Defendant Wilson, via his company, wired funds totalling
`$1 million to an account, located in the District of
`Massachusetts, in the name of The Key Worldwide
`Foundation (“KWF”).
`(5) The high school transcript of Defendant Zangrillo’s
`daughter which reflected credits earned in a fraudulent
`class-taking scheme, was emailed by Singer’s associates
`to Boston University in Boston, Massachusetts.
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`(6) Consensually recorded calls between Singer and a number
`of defendants occurred while Singer was located in
`Massachusetts.
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`(7) Defendants conspired to conceal their payments by
`funneling them through The Key and/or KWF, both of which
`had accounts located in Massachusetts. The FSI alleges
`that Singer used those fraudulent entities to bribe
`athletic coaches and to conceal the scheme.
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`Defendants protest that venue is improper in the District of
`Massachusetts as to Counts One, Two and Three. Count One of the
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`FSI charges the defendants with conspiracy to commit mail and
`wire fraud and honest services mail and wire fraud, in violation
`of 18 U.S.C. § 1349. Count Two of the FSI charges nine of the
`defendants with conspiring to commit federal programs bribery by
`bribing agents of the University of Southern California (“USC”)
`in order to secure the admission of their children to that
`university. Count Three of the FSI charges the defendants with
`conspiracy to commit money laundering in connection with
`payments made to KWF and The Key in furtherance of the
`admissions scheme.
`II. Motion to Dismiss for Lack of Venue
`A. Legal Standard
`
`The Sixth Amendment to the United States Constitution
`guarantees a defendant’s right to trial “by an impartial jury of
`the State and district wherein the crime shall have been
`committed.” U.S. Const. amend. VI. In order to address
`continuing offenses like conspiracy, Congress enacted 18 U.S.C.
`§ 3237(a) (1994) which states that:
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`any offense against the United States begun in one district
`and completed in another, or committed in more than one
`district, may be inquired of and prosecuted in any district in
`which such offense was begun, continued, or completed.
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`And, as set forth by Federal Rule of Criminal Procedure 18:
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`Unless a statute or these rules permit otherwise, the
`government must prosecute an offense in a district where the
`offense was committed.
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`In a conspiracy prosecution, venue is proper “so long as
`any act in furtherance of the conspiracy was committed in the
`district.” United States v. Uribe, 890 F.2d 554, 558 (1st Cir.
`1989). A defendant need not have been physically present in the
`district. Id.; see also United States v. Josleyn, 99 F.3d 1182,
`1191 (1st Cir. 1996)(noting that “[a]s a general rule, venue in
`a conspiracy case depends upon whether an overt act in
`furtherance of the alleged conspiracy occurred in the trial
`district. The defendant need not have been physically present
`in the trial district during the conspiracy”)(internal citation
`omitted).
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`When considering a motion to dismiss in a criminal case, a
`court accepts the factual allegations in the indictment as
`true. Boyce Motor Lines, Inc. v. United States, 342 U.S. 337,
`343 n.16 (1952). A motion to dismiss for lack of venue should
`be granted, therefore, only if the “indictment does not
`‘sufficiently allege[ ] conduct occurring in the District of
`Massachusetts in furtherance of the conspiracy...’” United
`States v. Acherman, 140 F. Supp. 3d 113, 117 (D. Mass.
`2015)(quoting United States v. Condo, No. 11–cr–30017–NMG, 2014
`WL 1400817, at *1 (D. Mass. Apr. 7, 2014).
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`B. Application
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`1. Count One
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`Defendants’ argument that venue is improper as to Count One
`is premised on their contention that the government has failed
`properly to allege a single conspiracy. They maintain that
`because no single conspiracy exists, the Court must analyze each
`defendant’s distinct relationship to this District and that the
`specific allegations in the FSI are insufficient to establish
`venue as to each defendant individually.
`This Court has previously held that, on its face, the FSI
`adequately alleges a single over-arching conspiracy. Because
`the FSI properly alleges a single conspiracy, a single act in
`furtherance of the conspiracy by a co-conspirator in this
`District is sufficient to confer venue. See United States v.
`Santiago, 83 F.3d 20, 25 (1st Cir. 1996).
`As detailed above, the FSI alleges numerous acts by co-
`conspirators in furtherance of the conspiracy which occurred in
`Massachusetts. For example, in the case against Defendant
`Zangrillo, this Court previously explained that the FSI
`sufficiently alleges that when he submitted fraudulent
`transcripts to Boston University on behalf of his daughter, he
`did so as part of the larger fraud and in furtherance of the
`fraudulent scheme. Venue is therefore proper in this District.
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`2. Count Two
`Defendants next contend that venue in this District is
`improper as to the federal programs bribery conspiracy alleged
`in Count Two because (1) it is centered around the University of
`Southern California and (2) the FSI does not allege that overt
`acts in furtherance of that conspiracy occurred in
`Massachusetts.
`Specifically, defendants submit that the allegation that
`Singer mailed a check from Massachusetts to Heinel in exchange
`for facilitating the admission of Defendant Abdelaziz’s daughter
`to USC as a purported athletic recruit does not support venue.
`Defendants maintain that (1) the Singer-Heinel agreement was a
`separate and distinct arrangement formed after Singer had
`already agreed with the defendants to effectuate the over-
`arching admissions scheme and (2) because Singer was, at that
`point, a cooperating witness he cannot have been a co-
`conspirator.
`
`The government rejoins that (1) the Singer-Heinel
`arrangement was part of the larger conspiracy and (2) the fact
`that Singer was cooperating with the government when he mailed
`the check is irrelevant for the purpose of determining venue.
`The government further explains that all the overt acts alleged
`with respect to Count One are re-alleged and incorporated by
`reference in Count Two.
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`The FSI properly alleges that at the time Singer mailed the
`checks to Heinel a single over-arching conspiracy was ongoing.
`According to the government, those checks were sent in
`furtherance of that conspiracy, not as part of a distinct
`agreement. That the defendants may not have been aware of the
`exact arrangement between Singer and Heinel is immaterial at
`this stage. United States v. Berroa, 856 F.3d 141, 154 (1st
`Cir. 2017)(noting that “[t]he government need not show that . .
`. the conspirators knew all of the details of the conspiracy or
`participated in every act in furtherance of the conspiracy”).
`Whether the defendants were aware that their payments were going
`to corrupt insiders or possessed the requisite corrupt intent is
`an issue of fact for the jury. Because the FSI alleges that
`Singer mailed a January, 2019, check from Massachusetts in
`furtherance of the conspiracy, venue as to Count Two is proper.
`Moreover, that Singer was cooperating at the time he mailed
`the check does not negate venue in this District. As the Court
`has explained, the FSI properly alleges one over-arching
`conspiracy which includes Singer, the defendants and Heinel. As
`the government notes, the FSI alleges that all defendants and
`co-conspirators remained a part of the continuing conspiracy
`after Singer began cooperating with the government. See United
`States v. Portela, 167 F.3d 687, 700 n.8 (1st Cir. 1999)(noting
`that “[t]he rule that government agents do not count as co-
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`conspirators has relevance only in situations where the
`conspiracy involves only one defendant and a government
`informer.”); United States v. Cordero, 668 F.2d 32, 43 (1st Cir.
`1981). Because Singer mailed a check from Massachusetts in
`furtherance of the ongoing conspiracy, venue is proper in this
`District regardless of the fact that he may have been
`cooperating with the investigation at that time.
`3. Count Three
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`Finally, defendants argue that the FSI’s allegations
`describing the money laundering conspiracy do not identify
`payments made to or from accounts located in this District. As
`the Court has previously held, the FSI sufficiently alleges a
`money laundering conspiracy. According to the government, the
`scheme operated in stages. Defendants first allegedly made
`payments to KWF and The Key with the intent that Singer would
`use the proceeds to pay Heinel and others. Singer then used
`that money to pay the corrupt insiders and effectuate the
`admissions scheme.
`The FSI alleges that Singer mailed a check to Heniel from
`Massachusetts and that Defendant Wilson made payments from
`accounts located in Massachusetts to Singer’s fraudulent
`entities. Both payments are alleged to have been made in
`furtherance of the money laundering conspiracy and establish
`that venue is proper in this District. Moreover, the FSI
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`alleges generally that Singer funneled bribes through his
`fraudulent entities to athletic coaches and administrators in
`the District of Massachusetts. Because, with respect to a
`motion to dismiss, the Court is to construe the allegations in
`an indictment as true, those allegations are sufficient to
`establish venue.
`4. Foreseeability
`
`Defendants next argue that even if the FSI properly alleges
`a single conspiracy, this Court should adopt the foreseeability
`test articulated by the Second Circuit Court of Appeals. United
`States v. Svoboda, 347 F.3d 471, 483 (2d Cir. 2003). The Second
`Circuit test requires that
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`(1) defendant intentionally or knowingly causes an act in
`furtherance of the charged offense to occur in the district
`of venue or (2) it is foreseeable that such an act would
`occur in the district of venue.
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`Id.
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`As the government notes (and defendants concede) the First
`Circuit has not adopted such a foreseeability requirement and
`several other circuits have explicitly rejected such as test in
`the context of section 3237(a). See United States v. Renteria,
`903 F.3d 326, 329-30 (3d Cir. 2018); United States v. Gonzalez,
`683 F.3d 1221, 1226 (9th Cir. 2012). A foreseeability test is
`required by “neither the text of the Constitution nor of
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`§ 3237(a)” and this Court will not adopt such a test. Renteria,
`903 F.3d at 330.
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`
`ORDER
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`For the foregoing reasons, defendants’ motions to dismiss
`the indictment for improper venue (Docket No. 1019) is DENIED.
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`So ordered.
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`Dated July 16, 2020
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` /s/ Nathaniel M. Gorton
` Nathaniel M. Gorton
` United States District Judge
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