United States v. Kheir Al-Marimi

CourtDistrict Court, District of Columbia
DecidedJanuary 8, 2026
DocketCriminal No. 2022-0392
StatusPublished

This text of United States v. Kheir Al-Marimi (United States v. Kheir Al-Marimi) is published on Counsel Stack Legal Research, covering District Court, District of Columbia primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
United States v. Kheir Al-Marimi, (D.D.C. 2026).

Opinion

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA

UNITED STATES OF AMERICA,

v. No. 22-cr-392 (DLF) ABU AGILA MOHAMMAD MAS’UD KHEIR AL-MARIMI,

Defendant.

MEMORANDUM OPINION AND ORDER

Before the Court are sealed motions by the United States to depose three witnesses pursuant

to Federal Rule of Criminal Procedure 15. Dkts. 129, 130, 131. The government seeks to depose

all of whom reside outside of the United States. While

the government initially moved to conduct all three depositions abroad, it now believes that

may be able to travel to the United States for their depositions. For the

following reasons, the Court will grant the motions, subject to the procedures outlined below.

I. LEGAL STANDARDS

Under Rule 15, a party “may move that a prospective witness be deposed in order to

preserve testimony for trial.” Fed. R. Crim. P. 15(a)(1). The Court “may grant the motion because

of exceptional circumstances and in the interest of justice.” Id. “To demonstrate that ‘exceptional

circumstances’ necessitate a Rule 15 deposition, the party seeking the deposition must show:

‘(1) the materiality of the testimony; and (2) the unavailability of the witness to testify at trial.’”

United States v. Trabelsi, No. 06-cr-89 (RDM), 2023 WL 4341429, at *2 (D.D.C. Apr. 5, 2023)

(quoting United States v. Cooper, 947 F. Supp. 2d 108, 112 (D.D.C. 2013); United States v. Kelley,

36 F.3d 1118, 1125 (D.C. Cir. 1994)). II. ANALYSIS

The pa11ies agree that the Com1 should "pe1mit depositions to be taken of all three

witnesses to prese1ve their testimony" for trial, Dkt. 136 at 1, but the defendant objects to any

deposition occmTing outside his physical presence, id. at 1- 2. Because the government has not

yet dete1mined whether any of the witnesses are miable to travel to the United States for trial, the

Comi will not decide that issue.

The Comi will, however, grant the government's motion to depose the witnesses before

trial. The government has satisfied its burden in showing that the testimony of these witnesses is

material. And the Court has provisionally dete1mined that the witnesses are substantially likely

not to be available to testify at trial. 1 See United States v. Mann, 590 F.2d 361, 366 (1st Cir. 1978).

A.

First, materiality. "In assessing whether testimony is material for Rule 15(a)(l) purposes,

com1s have used the standards developed for applying and interpreting Brady v. Maryland, 373

U.S. 83 (1963)." United States v. Vo, 53 F. Supp. 3d 77, 81 (D.D.C. 2014). "Evidence is material

1 This Order authorizes only the talcing of these three depositions. The Comi defers any decision on the admissibility of the depositions until a date closer to trial. See Fed. R. Crim. P. 15(f). At this time, the Com1 does not make any final dete1mination that the witnesses are unavailable for trial, a decision the Com1 will also defer until a date closer to trial. Nor does the Comt address the parties' arguments concerning the defendant's rights under the Confrontation Clause. The Comt will request supplemental briefing on these issues as necessa1y.

2 within the meaning of Brady when there is a reasonable probability that, had the evidence been

disclosed, the result of the proceeding would have been different." Id. (citation modified).

Second, the government argues that I I is substantially likely to be unavailable for trial. The government "need not prove conclusively that the prospective deponent will be

unavailable to testify at trial." Cooper, 947 F. Supp. 2d at 11 3 (citing United States v. Drogoul, 1

F.3d 1546, 1553 (11th Cir. 1993)). For pmposes of Rule 15, the Comt may make a provisional

dete1mination that the witness is substantially likely not to testify at trial and defer a final

dete1mination of unavailability at trial. See Mann, 590 F.2d at 366 ("When the question is close a

comt may allow a deposition in order to prese1ve a witness' testimony, leaving until trial the

question of whether the deposition will be admitted as evidence."). The Comt focuses on the

witness's ''unavailability 'for trial' and not [on] whether they have actually consented to make

themselves available for the deposition." United States v. Vilar, 568 F. Supp. 2d 429, 439

(S.D.N.Y. 2008).

-- 3 Finally, because I I testimony will prese1ve critical evidence for trial and because the defendant will be present for the deposition, the Court concludes that - -deposition is

in the interest of justice.

The Comt will authorize - - deposition under Rule 15. - has expressed a

present willingness to travel to the United States, and the government "will continue to make

effo11s to secme . . . . appearance in the United States for a deposition." Dkt. 139 at 1.

Accordingly, the deposition shall take place at the U.S. District Comt for the District of Columbia,

in the presence of the defendant.

B. -

....

4 The Court will therefore authorize I I deposition under Rule 15. Because he has expressed a present willingness to travel to the United States and because the government "will

continue to make eff01ts to secure appearance in the United States for a deposition," Dkt.

139 at 1, the deposition shall take place at the U.S. District Com1 for the District of Columbia in

the presence of the defendant.

C.

- - - testimony is material for the reasons stated by the government. 1111111111111

The Comt will also make the provisional finding that - is unavailable for trial for

the reasons given by the government, with which the defendant agrees. Dkt. 136 at 15.

5 The Court will therefore authorize I I deposition under Rule 15.

The paiiies disagree over the defendant's location during the deposition. The government

contends that the defendant, who is in federal custody, "cannot travel to . . . .,, because it

lacks the authority to maintain custody over the defendant in a foreign com1tty. Dkt. 130 at 13-

14. The government notes that the Department of Justice's Office of International Affairs (OIA)

believes that- authorities ai·e "unlikely to accept custody of the defendant," but that "OIA has

asked the - authorities for their position directly, and the government will file a notice when

it receives the- response." Dkt. 139 at 3-4. Invoking Rule 15(c)(3), the govemment proposes

that the defendant pruticipate in the deposition by videoconference from the United States. Dkt.

130 at 13-14. The defendant objects and argues that the government has offered insufficient

grounds to establish that it cannot make him available for a deposition in. . . .. Dkt. 136

at 6--8.

Although the Comt will authorize- - deposition in _ _ , at this juncture, it

will not authorize the defendant's absence.

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Related

Brady v. Maryland
373 U.S. 83 (Supreme Court, 1963)
Seattle Times Co. v. Rhinehart
467 U.S. 20 (Supreme Court, 1984)
United States v. Rony Mann
590 F.2d 361 (First Circuit, 1978)
United States v. Christopher P. Drogoul
1 F.3d 1546 (Eleventh Circuit, 1993)
United States v. John C. Kelley
36 F.3d 1118 (D.C. Circuit, 1994)
United States v. Vilar
568 F. Supp. 2d 429 (S.D. New York, 2008)
United States v. Cooper
947 F. Supp. 2d 108 (District of Columbia, 2013)
United States v. Binh Tang Vo
53 F. Supp. 3d 77 (District of Columbia, 2014)

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United States v. Kheir Al-Marimi, Counsel Stack Legal Research, https://law.counselstack.com/opinion/united-states-v-kheir-al-marimi-dcd-2026.