United States District Court, D. Nevada
before the court is defendant Maria Larkin's motion
in limine. (ECF No. 260). The government filed a
response (ECF No. 270), to which defendant replied (ECF No.
November 16, 2016, the government filed a second superseding
indictment, charging defendant with one count-tax evasion in
violation of 21 U.S.C. § 7201. (ECF No. 135). Trial is
currently set for March 13, 2017.
second superseding indictment alleges that defendant
willfully attempted to evade and defeat the payment of trust
fund recovery penalties by concealing and attempting to
conceal her access to personal funds and assets from the IRS
through acts, including, but not limited to the following:
• engaging in currency transactions with financial
institutions in amounts less than $10, 000 to prevent
financial institutions from filing currency transaction
reports disclosing that she had possession of substantial
amounts of currency;
• purchasing a home in the name of a nominee;
• dealing extensively in cash, including causing checks
to be drawn on a business bank account payable to certain
individuals and directing those individuals to cash
• the checks and deliver the funds to her;
• changing the name of FSHHC to Five Star Healthcare,
• putting Five Star Healthcare, LLC in the name of a
• providing false information to the IRS regarding
FSHHC's ability to pay trust fund taxes and her ability
to pay trust fund recovery penalties.
(ECF No. 135 at 4-5).
instant motion in limine, defendant moves to
preclude the government from introducing various exhibits
into evidence during trial. (ECF No. 260).