United States v. Elena Szilvagyi

JULIA SMITH GIBBONS, Circuit Judge.

Defendant-appellant Elena Szilvagyi appeals the district court’s denial of her motion to dismiss the charge of naturalization fraud, in violation of 18 U.S.C. § 1425(a). Szilvagyi was convicted of this charge by a jury and was sentenced to six months’ imprisonment. She contends that the district court should have granted her motion to dismiss the naturalization fraud charge on the following bases: (1) a violation of the statute of limitations, (2) improper sealing of the indictment, and (3) a violation of her Fifth Amendment due process rights arising from…