IN THE UNITED STATES DISTRICT COURT

FOR THE SOUTHERN DISTRICT OF IOWA

)
UNITED STATES OF AMERICA,
)
)
v.
)
)
IBRAHIM ABDELRAHMAN DREMALI, and )
SAFAA RASHAD EISSA,
)
)
Defendant.
)
)

Criminal No. 4:10-CR-059

JOINT MOTION TO DISMISS
WITHOUT PREJUDICE

Pursuant to Rule 48(a) of the Federal Rules of Criminal Procedure, the

United States Attorney for the Southern District of Iowa hereby moves to dismiss
the indictment in the above-captioned case without prejudice.
1.

On May 27, 2010, a Southern District of Iowa grand jury returned a

two-count indictment charging the defendants, Ibrahim Abdelrahman Dremali and

Safaa Rashad Eissa, with Count 1, conspiracy to commit naturalization fraud and
Count 2, fraud in the naturalization process. (Dkt. 1).
2.

On July 25, 2013, the Court scheduled an evidentiary hearing to assess

defendant Dremalis ability to travel to Des Moines for trial. (Dkt. 100).
3.

On October 25, 2013, Magistrate Judge Ross A. Walters issued a

written opinion based upon medical testimony taken during an October 10, 2013
evidentiary hearing. (Dkt. 109). As part of the order, Judge Walters found [i]t is
evident that Defendant Dremali is seriously ill and that he is currently unable to
travel to Des Moines for trial or to sit through what is estimated to be a two week
trial. His present infirm condition is likely to continue for the foreseeable future

and that he will ever sufficiently recover his health to permit travel and attendance
is uncertain. (Dkt. 109, P. 2).
4.
regressed.

Defendant Dremalis condition has not improved, and has, in fact,

Recent medical records disclosed by defense counsel document the

deteriorating condition of Dremalis health.

As a result, counsel for defendant

Dremali, defendant Eissa, and the government have joined in numerous motions to
continue the trial date.
5.

Counsel for codefendant Eissa joined in each and every request for

continuance based upon her role as wife and sole caretaker of defendant Dremali.
6.

Because there has been no improvement in defendant Dremalis

condition, and defendant Eissa continues to be the sole caretaker of Defendant

Dremalis medical needs, the parties now jointly move the court to dismiss the
above entitled case without prejudice.
7.

The parties agree that this case may be refiled at a later date against

either defendant as circumstances warrant and in the governments sole discretion.

8.

Both defendant Dremali and defendant Eissa waive any and all

statute of limitations with respect to the offenses alleged in the above entitled case.
The defendants further agree that the government may, in its sole discretion, refile
said charges at a later date.

Respectfully Submitted,

______________
Date

Nicholas A. Klinefeldt
United States Attorney
By:

Jason T. Griess
Assistant United States Attorney
U.S. Courthouse Annex, Suite 286
110 East Court Avenue
Des Moines, Iowa 50309
Tel: (515) 473-9300
Fax: (515) 473-9288
Email: Jason.Griess2@usdoj.gov

By signing this document, I knowingly and voluntarily waive any rights I

may have under the statute of limitations regarding the charges contained in the
Indictment filed in Criminal No. 4:10-CR-059 on May 27, 2010.
______________
Date
______________
Date

_______________
Date

____________________________________
Ibrahim Abdelrahman Dremali
Defendant
____________________________________
Alfredo Parrish
Attorney for Ibrahim Abdelrahman
Dremali
____________________________________
Mr. Richard B. Roper
Attorney for Ibrahim Abdelrahman
Dremali

By signing this document, I knowingly and voluntarily waive any rights I

may have under the statute of limitations regarding the charges contained in the
Indictment filed in Criminal No. 4:10-CR-059 on May 27, 2010.
______________
Date

____________________________________
Saffa Rashad Eissa
Defendant

______________
Date

____________________________________
Ahmed Ghappour
Attorney for Saffa Rashad Eissa

______________
Date

____________________________________
Nancy Hollander
Attorney for Saffa Rashad Eissa

LEAVE OF COURT IS HEREBY GRANTED TO FILE THE ABOVE DISMISSAL.

____________________
Date

___________________________
Hon. Robert W. Pratt
United States District Judge