UNITED STATES DISTRICT COURTFOR THE DISTRICT OF COLUMBIAUNITED STATES OF AMERICA:Case No. 11-cr-276 (EGS):v.::KERRY F. KHAN, LEE A. KHAN,:and HAROLD F. BABB, ::Defendants.: ____________________________________:GOVERNMENT’S CONSENT MOTION TO CONVERT THE STATUS HEARINGFOR DEFENDANT HAROLD F. BABB TO A PLEA HEARING AND TO CONTINUETHE STATUS HEARING FOR DEFENDANTS KERRY F. KHAN AND LEE A. KHAN
The United States of America, through undersigned counsel, respectfully submits this consentmotion to convert the status hearing scheduled to take place on March 13, 2012 at 2:00 p.m. for defendant Harold F. Babb to a plea hearing and to continue the status hearing for defendants KerryF. Khan and Lee A. Khan. In support of the motion, the government states as follows:1.On September 16, 2011, the grand jury returned an indictment against the defendants,Kerry F. Khan, Lee A. Khan, and Harold F. Babb. The indictment charged each defendant withconspiracy to defraud the United States and to commit bribery, in violation of Title 18, United StatesCode, Section 371 (Count One), and conspiracy to launder monetary instruments, in violation of Title 18, United States Code, Section 1956(h) (Count Four). The indictment also charged Kerry F.Khan with bribery, in violation of Title 18, United States Code, Section 201 (Count Two). Further,the indictment charged Harold F. Babb with unlawful kickbacks, in violation of Title 41, UnitedStates Code, Section 8702 (Count Three).2.On October 4, 2011, the defendants were arrested and arraigned on the indictment.
Case 1:11-cr-00276-EGS Document 60 Filed 03/07/12 Page 1 of 3